Bill 190 introduces new hiring and job‑posting requirements for Ontario employers. Many teams understand the basics, but the tough questions come up when they start updating templates, adjusting ATS settings, or reviewing their internal processes.
This FAQ brings together the most common questions HR and hiring leaders are asking right now. It’s search-friendly, practical, and built for quick reference.
If you need the full step‑by‑step workflow, templates, and a readiness checklist, download the Bill 190 Compliance Guide at the end of this page.
Posting Requirements
These questions focus on what must appear in public job postings under Bill 190. They help HR teams understand what needs to be included before a job goes live: salary details, AI language, vacancy type, and other requirements that shape how candidates first see your role.
When do the Bill 190 hiring requirements take effect?
The hiring‑related requirements come into effect on January 1, 2026. These include salary transparency, AI disclosure, vacancy classification, candidate follow‑up timelines, and recordkeeping rules.
Do all job postings need a salary range?
Yes. Any publicly advertised job posting in Ontario must include either:
- a salary, or
- a salary range.
If you use a range:
- The spread must not exceed $50,000, unless the top end is above $200,000.
This applies to postings on your website, job boards, LinkedIn, and any platform that syndicates listings.
Can we still write “salary: competitive”?
No. Bill 190 requires a clear salary or range. Generic phrasing like “competitive” or “based on experience” doesn’t meet the requirement.
AI Disclosure Requirements
These questions cover how AI appears in hiring tools and what employers are required to disclose to candidates. Bill 190 requires clarity when technology influences screening or selection, and this section explains how to approach those disclosures confidently.
What counts as “AI” in hiring?
You must disclose AI if any tool you use:
- screens,
- ranks,
- scores,
- shortlists, or
- influences candidate selection.
Examples include:
- ATS keyword filters
- video‑interview intelligence
- résumé‑screening algorithms
- automated assessment scoring
Even light AI involvement requires disclosure.
Where do we put the AI disclosure?
In the job posting itself. Not in your privacy policy, careers page, or onboarding documents.
A simple, compliant example:
“This role uses AI‑assisted tools to support initial screening. All assessments and decisions are made by a human reviewer.”
Do we need to list the specific AI tools we use?
No. Bill 190 does not require naming the tools. A general disclosure is acceptable.
Some companies choose to list tools for added transparency, but it’s optional.
What is the “vacancy type” requirement?
Every posting must state whether the role is:
- a newly created position, or
- an existing vacancy.
This is a mandatory line item.
Can we still ask for “Canadian experience”?
No. Bill 190 prohibits requiring or implying Canadian work experience.
Approved replacement:
“Candidates must be legally eligible to work in Canada.”
What is the 45‑day candidate‑notification rule?
If a candidate is interviewed, whether it’s one interview or several, you must notify them of your final decision within 45 days.
This rule protects job seekers from long periods of silence and requires closure.
Does the 45‑day rule apply even if the candidate withdraws?
If the candidate formally withdraws, no. But if they simply stop replying, you still need to issue a closure message.
Recordkeeping Requirements
These questions explain which hiring-related records must be archived and for how long. Bill 190 places stronger expectations on documentation and audit readiness, and this section helps employers understand what needs to be retained and why.
What communications need to be stored for three years?
You must retain:
- job postings
- interview notes
- AI disclosures
- candidate communications
Retention must cover a full three‑year period.
Can we store everything inside our ATS?
Yes, if the ATS reliably archives postings and messages.
If your ATS doesn’t store all communication (e.g., Outlook emails, Teams messages), you’ll need a centralized process to ensure nothing is lost.
Do internal job postings need to follow Bill 190 rules?
No. The rules apply only to publicly advertised postings.
Internal postings shared only with current employees are exempt.
Do agencies posting on our behalf follow the same rules?
Yes, if the posting is public.
However, when STACK IT posts a role under our own banner, we handle compliance on our side. Your brand can remain confidential while the posting remains fully compliant.
What happens if a job board rejects our posting?
Job boards may begin enforcing compliance, especially around salary ranges. Non‑compliant postings may be:
- rejected,
- removed,
- or flagged for revision.
Providing complete salary information reduces that risk.
What happens if we don’t comply?
Consequences may include:
- government investigation,
- administrative penalties,
- job‑board removal,
- reputational impact,
- and erosion of candidate trust.
Bill 190 is designed to increase transparency. Non‑compliance often becomes visible quickly.
How should HR teams prepare between now and 2026?
A practical approach:
- Update all job‑posting templates.
- Add salary ranges and AI disclosure language.
- Incorporate vacancy type into requisition workflows.
- Configure your ATS to track 45‑day reminders.
- Centralize archives for postings + communication.
- Train hiring managers.
These updates create a consistent, repeatable structure.
Where can we learn more about the operational workflow?
The Bill 190 Compliance Guide includes:
- templates,
- sample postings,
- an ATS workflow outline,
- a 5‑minute readiness scan,
- and a full compliance checklist.
For a step‑by‑step checklist and the full compliance workflow, download the Bill 190 Compliance Guide.
