Insights from the TechConnex People Strategies Peer Group
As Ontario prepares to implement Bill 190 in January 2026, HR professionals and business leaders are examining how these legislative updates will reshape recruitment, employee relations, and compliance obligations. This month’s People Strategies Peer Group brought together HR practitioners and business owners to explore what’s changing and how to prepare effectively.
Recruitment Transparency and Legislative Updates
The conversation began with the bill’s changes to recruitment transparency, including the requirement for organizations to disclose salary ranges and remove Canadian experience requirements from job postings. While these updates are designed to promote fairness and inclusivity, participants acknowledged the challenges they may pose—particularly for small and mid-sized organizations navigating limited HR capacity and diverse workforce structures.
One key clarification was that employment standards apply based on where the employee performs their work, not where the company’s head office is located. This distinction is especially important as hybrid and remote work arrangements become more common. Several members suggested that organizations begin reviewing their job posting templates and applicant tracking systems now, ensuring they can easily accommodate salary disclosures and AI-related statements ahead of the implementation date.
AI in Recruitment: Balancing Innovation and Compliance
The group also discussed the bill’s new requirement to disclose the use of AI in recruitment. Members emphasized the growing reliance on AI tools for resume screening and interview scheduling—but also the importance of maintaining human oversight to mitigate bias and ensure fair hiring outcomes.
Some organizations have already started updating their recruitment policies to specify when AI tools are used and how those tools are evaluated for accuracy and equity. Adding a brief statement to job postings about the use of AI in candidate assessment not only builds transparency and trust, but also prepares businesses for potential compliance reviews once the legislation takes effect.
Sick Leave and Medical Documentation
The discussion then turned to sick leave policies and medical documentation requirements. The group clarified that employees are entitled to three unpaid sick days without requiring medical documentation, but extended or paid sick time may necessitate a doctor’s note. Larger organizations often align these policies with short-term disability plans, which typically begin after seven consecutive days of illness.
Members shared that it’s important to communicate these policies clearly in employee handbooks and provide consistent guidance to both staff and managers. Doing so helps avoid misunderstandings and ensures that expectations are applied fairly across teams. For smaller organizations, adopting a “reasonable evidence” standard—requesting documentation only when truly necessary—can help strike the right balance between accountability and empathy.
Salary Transparency and Internal Equity
One of the liveliest parts of the discussion focused on salary transparency and its impact on internal equity. While public salary ranges may attract more applicants and foster a sense of fairness, they can also prompt existing employees to question their compensation levels.
Several members suggested using current employee averages as the midpoint when publishing salary bands to maintain internal consistency. Others shared that posting broader ranges allows flexibility while staying compliant with the law. Participants also noted that some companies are proactively conducting pay equity audits to benchmark salaries before making ranges public—an approach that not only ensures compliance but also strengthens employee trust and retention.
Remote Work Safety and Employer Liability
The conversation concluded with a look at remote work policies and the employer’s responsibility for maintaining a safe work environment outside the office. Many organizations have already implemented ergonomic checklists, incident reporting procedures, and home office allowances to address these responsibilities.
Several participants recommended treating home offices as extensions of the workplace, documenting any safety measures or equipment provided to employees. Taking these proactive steps can help demonstrate due diligence, reduce risk, and support both physical and psychological well-being for remote staff.
Final Thoughts
Ontario’s Bill 190 signals a continued shift toward greater transparency, accountability, and worker protection. While some of its details are still being clarified, the direction is clear: employers must prepare now by revisiting recruitment policies, pay structures, and HR documentation processes.
By updating systems, communicating policies clearly, and training hiring teams, organizations can move confidently into compliance—while positioning themselves as fair, forward-thinking employers in a changing legislative landscape.