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Bill 190 introduces new hiring and job‑posting requirements for Ontario employers. Many teams understand the basics, but the tough questions arise when they begin 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.
Bill 190 changed what a job advertisement has to contain before it goes live. These rules apply to publicly advertised postings from employers with 25 or more employees, and they cover compensation, the nature of the vacancy, and what you can no longer ask candidates for.
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.
AI Disclosure Requirements
If any tool screens, ranks, scores or shortlists candidates, you have to say so in the posting. The questions below cover what counts as AI for this purpose, how specific the disclosure needs to be, and where employers most often get the wording wrong.
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 such disclosures with confidence.
Recordkeeping Requirements
The three-year retention rule is what makes the rest of Bill 190 enforceable. A missing salary range is arguable; a missing record of who applied, who was interviewed and when they were notified is not.
These questions explain which hiring-related records must be archived and for how long. Bill 190 places greater emphasis on documentation and audit readiness, and this section helps employers understand what must be retained and why.
FAQ
Bill 190 questions, answered.
The hiring-related requirements came into force on January 1, 2026, and apply to employers with 25 or more employees on the day a position is posted. They cover pay transparency, AI disclosure, vacancy classification, candidate follow-up timelines, and recordkeeping. A separate set of new-hire information requirements under Ontario Regulation 285/01 took effect earlier, on July 1, 2025.
Yes. Any publicly advertised job posting in Ontario must include either a salary or a salary range, and the full set of posting obligations is covered in Bill 190 hiring requirements. If you post a range it cannot span more than $50,000 a year. There is a full exemption above $200,000: where the expected compensation exceeds $200,000 annually, or the top of the range does, the disclosure requirement does not apply at all, which covers most executive search. This applies to postings on your website, job boards, LinkedIn, and any platform that syndicates listings.
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 such disclosures with confidence.
You must disclose AI if any tool you use screens, ranks, scores, shortlists, or influences candidate selection. That includes ATS keyword filters, ranking algorithms, automated video assessment, and chat-based screening. Our guide to what counts as AI in hiring covers the grey areas in detail.
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.”
No. Bill 190 does not require the tools to be named. A general disclosure is acceptable. Some companies choose to list tools for added transparency, but it’s optional.
Every posting must state whether the role is: a newly created position, or an existing vacancy. This is a mandatory line item.
No. Bill 190 prohibits requiring or implying Canadian work experience. Approved replacement:“Candidates must be legally eligible to work in Canada.”
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.
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 greater emphasis on documentation and audit readiness, and this section helps employers understand what must be retained and why.
You must retain: job postings interview notes AI disclosures candidate communications Retention must cover a full three-year period.
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.
No. The rules apply only to publicly advertised postings. Internal postings shared only with current employees are exempt.
Yes, if the posting is public. However, when STACK IT posts a role under our own banner, we handle compliance on our side and your brand can remain confidential. Worth checking that any agency you use is licensed: see how to check Ontario's recruiter registry.
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.
Enforcement runs through the Ministry of Labour under the Employment Standards Act, so complaints are usually triggered by a candidate rather than an audit. Consequences may include investigation, administrative penalties, removal of postings by job boards, and the reputational cost of a public complaint. The recordkeeping requirement is what makes the rest enforceable: a missing salary range is arguable, a missing three-year log is not.
Six things, and if any are missing you are already exposed: job-posting templates carrying a salary range and AI disclosure language; vacancy type built into your requisition workflow; an ATS configured to track the 45-day notification deadline; a central archive covering postings and candidate communication for three years; hiring managers trained on what they can no longer ask; and a review of any agency posting on your behalf. See how Bill 149 and Bill 190 differ if you are unsure which obligation came from which statute. Our Bill 190 compliance checklist covers the same ground as a working document.
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 Checklist.
