Law / Canada / Ontario

Employment Standards Act, 2000, use of artificial intelligence in job postings

Employment Standards Act 2000, S.O. 2000, c. 41, ss. 8.1, 8.4, as enacted by the Working for Workers Four Act, 2024, S.O. 2024, c. 3, Sched. 2, s. 2(1), and Ontario Regulation 476/24 (Rules and Exemptions re Job Postings), ss. 1, 2(1)

A citation is an address, not a summary. The first part names the law; what follows narrows it to the exact section, article or paragraph.

What follows is LexLint's own research summary of this law, not legal advice.

In force 9 months, effective 1 January 2026.

An AI sector rules rule binding public and private bodies.

As of 24 September 2026.

What it requires

  • If you are an employer that has 25 or more employees on the day you post a publicly advertised job posting, and you use artificial intelligence to screen, assess or select applicants for the position, include a statement in the posting disclosing that you use artificial intelligence for that purpose.
  • This duty applies only to an external job posting you advertise to the general public. It does not reach a posting restricted to your existing employees, a general recruitment campaign or help wanted sign that does not advertise a specific position, or a posting for a position whose work is to be performed outside Ontario, or partly outside Ontario where the work outside Ontario is not a continuation of work performed in Ontario.

If you get it wrong

Criminal exposureYes

Private right of actionNo

Criminal exposure note

Section 132 makes it an offence, prosecuted under Ontario's Provincial Offences Act, to contravene the Employment Standards Act, 2000 or its regulations, or to fail to comply with an order, direction or other requirement under them; a Part III.1 job-posting contravention, including a failure to include the artificial intelligence disclosure statement required by section 8.4(1), falls within this general offence. On conviction, an individual is liable to a fine of not more than $100,000 or to imprisonment for a term of not more than 12 months or to both; a corporation is liable to a fine of not more than $100,000 on a first offence, not more than $250,000 with one previous conviction under the Act, and not more than $500,000 with more than one previous conviction.

Penalty structure

The $500,000 figure is the ceiling for a corporation with more than one previous conviction under the Act (s. 132(c)(ii)); a corporation's first-offence cap is $100,000 and its one-prior-conviction cap is $250,000, and an individual's cap is $100,000, or up to 12 months' imprisonment, or both. This is the Act's general contravention offence under section 132, not a penalty specific to the artificial intelligence disclosure duty. A separate administrative monetary penalty (notice of contravention) process also exists under section 113, with the amount set by a regulation made under paragraph 16.1 of section 141(1), which is not read, so its content is not described here.

Rule
Fixed only
As of
24 September 2026
Currency
CAD
Fixed cap
500,000

Who enforces it

Enforcement body

The Director of Employment Standards and employment standards officers appointed under Part XXI of the Employment Standards Act, 2000 (Ontario Ministry of Labour, Immigration, Training and Skills Development); a prosecution under section 132 proceeds under Ontario's Provincial Offences Act.

What it reaches

How the hook was established

express

What makes it apply

Place of effect

Obligation class

Disclosure

What it makes you log

Logging duty

Section 8.4 requires an employer to include a statement in a publicly advertised job posting disclosing that artificial intelligence was used to screen, assess or select applicants; it creates no duty to keep a log, record, or audit trail of that use beyond the statement in the posting itself. Every publicly advertised job posting under Part III.1, including one carrying this disclosure statement, must be retained by the employer, or by another person on the employer's behalf, for three years after the posting is removed from public access, under section 15(7.1) of the Act. That retention duty reaches every publicly advertised job posting, whether or not it discloses artificial intelligence use.

Kind
None
As of
24 September 2026

Who checks it

Audit expectation

none

What this law does

Drafted with AI from the cited sources under the direction of UnGovr staff. UnGovr holds editorial responsibility for this page.

Section 8.4(1) requires an employer that advertises a publicly advertised job posting and uses artificial intelligence to screen, assess or select applicants for the position to include in the posting a statement disclosing that use. The duty binds an employer with 25 or more employees on the day the posting is posted, and a smaller employer is exempt from the whole of Part III.1 under Ontario Regulation 476/24.

That Regulation also supplies the regulation-defined terms artificial intelligence and publicly advertised job posting, the second excluding a general recruitment campaign or help wanted sign not for a specific position, a posting restricted to existing employees, and a posting for work to be performed outside Ontario, or partly outside Ontario where the work outside Ontario is not a continuation of work performed in Ontario.

Section 8.4(2) exempts a posting that meets criteria prescribed by regulation. Every publicly advertised job posting under this Part, including one carrying this disclosure statement, must be retained by the employer for three years after it is removed from public access, under section 15(7.1) of the Act, a duty that reaches every such posting whether or not it discloses artificial intelligence use.

When LexLint raises it

  • high_risk_decisions

Read the law

official consolidated statute text, e-Laws (King's Printer for Ontario)
Ontario Regulation 476/24 supplies the regulation-defined terms and the 25-employee exemption

Every line above is drawn from the primary source linked here, read on the date shown. This is a research summary, not legal advice.

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