Ontario Workers for Workers Four Act — AI Hiring Disclosure: AI Compliance Requirements
Ontario's Workers for Workers Four Act (2024), effective January 1, 2026, requires employers posting jobs accessible to Ontario residents to disclose whether artificial intelligence is used in the hiring process. This includes AI resume screening, AI interview assessment, or any automated tool that evaluates candidates. Ontario employers must also post their AI hiring disclosure policies internally. This is Canada's first province-level mandatory AI hiring disclosure law, ahead of any federal legislation.
Key Facts
January 1, 2026
Enforcement by Ontario Ministry of Labour; penalties under Employment Standards Act (up to $100,000 for repeat violations)
What Your Business Must Do
2 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.
AI Hiring Disclosure in Job Postings
High PriorityAll job postings accessible to Ontario residents must include a disclosure statement if AI is used at any stage of the hiring process — including resume screening, skills assessment, interview analysis, or final candidate selection. The disclosure must be in the job posting itself, not buried in terms of service. Example language: "We use AI-assisted tools to screen applications and assess candidate responses."
Deadline: January 1, 2026
Internal AI Hiring Policy
Medium PriorityDocument your AI hiring practices in writing: which tools are used, at what stages, how candidates are informed, and how human review is incorporated. Post this policy internally for HR staff. If you use third-party AI recruiting tools, obtain documentation from the vendor confirming their tool's role in decision-making.
Deadline: January 1, 2026
Frequently Asked Questions
Does Ontario Workers for Workers Four Act — AI Hiring Disclosure apply to my business?
Ontario's Workers for Workers Four Act (2024), effective January 1, 2026, requires employers posting jobs accessible to Ontario residents to disclose whether artificial intelligence is used in the hiring process. This includes AI resume screening, AI. Use ComplianceIQ's free scanner to get a personalized assessment in under 5 minutes.
What is the penalty for non-compliance?
The maximum penalty under Ontario Workers for Workers Four Act — AI Hiring Disclosure is: Enforcement by Ontario Ministry of Labour; penalties under Employment Standards Act (up to $100,000 for repeat violations). Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Ontario Workers for Workers Four Act — AI Hiring Disclosure?
The 2 requirements above cover the core obligations. The fastest path to compliance is: (1) conduct an AI risk assessment, (2) document your AI systems, (3) implement transparency disclosures where required. ComplianceIQ generates all required documents automatically.
Official Source
https://www.osler.com/en/insights/reports/2025-legal-outlook/canadas-2026-privacy-priorities-data-sovereignty-open-banking-and-ai/Last updated: 2026-04-12 — verify at source before relying on this information.
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