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Bill 190 changes how Ontario employers write postings, run interviews, disclose AI, and follow up with candidates. This step-by-step checklist keeps every stage organized, consistent, and audit-ready for 2026.
Bill 190 adds mandatory rules for how roles are posted, how interviews are run, how AI is disclosed, and how candidates are followed up with. The gaps usually hide in plain sight.
EXPOSURE 01 / POSTINGS
Non-compliant postings
A missing salary range or AI disclosure on a public posting is the most visible gap, and the easiest for a candidate to flag.
EXPOSURE 02 / PROCESS
Undocumented interviews
Without consent and a consistent, recorded process, a single challenged decision can put your whole hiring approach in question.
EXPOSURE 03 / RECORDS
Incomplete records
Bill 190 expects specific documents kept for years. Gaps tend to surface at the worst possible moment, during an audit or a complaint.
What it covers
Every stage of the hiring process.
Each stage has its own checklist you can apply immediately, from the first posting to three-year recordkeeping.
The 5-stage checklist
Work it top to bottom, or jump straight to the stage you need.
01
Before posting
Confirm the salary range, vacancy type, and a compliant job description before anything goes live.
Covers Salary-range rules and new-vs-replacement disclosure.
02
Public posting
Make sure salary visibility, AI disclosure, follow-up language, and employer identification meet Ontario requirements.
Covers Public posting rules and AI-use transparency.
03
Interview & screening
Handle recording consent, document AI-assisted steps, keep questions consistent, and capture human decision points.
Covers Consent, AI documentation, and a consistent process.
04
45-day follow-up
Meet the mandatory follow-up window with consistent, logged communication for every interviewed candidate.
Covers The 45-day candidate follow-up rule.
05
Recordkeeping
Retain the right documents, in the right structure, for the required three-year period.
Covers Three-year record retention.
Inside the full checklist
More than an overview. The whole process.
The stages above are the map. The full checklist turns each one into specific, checkable steps, with plain-language notes on the rules and the records to keep.
01 The 5-stage checklist
Every stage as a working checklist
Pre-posting approval steps
Public-posting requirements
Interview consent and documentation
02 The rules in plain language
What Bill 190 actually requires
Salary-range disclosure
AI-use disclosure, kept high-level
The 45-day follow-up window
03 Records and proof
What to keep, and for how long
Document retention checklist
Three-year recordkeeping structure
Staying audit-ready
Free · PDF checklist
MayaTalent lead2dWe finally know we are audit-ready.DevinHR manager6dMade our 2026 prep painless.PriyaPeople ops1wEvery hiring stage, covered.
Everything you need, in one checklist.
Salary-range rules
AI disclosure
45-day follow-ups
Download the checklist.
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FAQ
Questions about the checklist, answered.
Bill 190 is part of Ontario's Working for Workers legislation, and here's who Bill 190 covers. If you post roles and hire in Ontario it applies to you, whether you are an enterprise HR team or a small business without dedicated HR. The checklist is written so any team can follow it.
Public postings are expected to show the compensation on offer, with only narrow exceptions. The checklist shows how to set a compliant salary range and flags the cases where the rules work differently, so nothing goes live without it.
If AI is used to screen, assess, or shortlist candidates, that use has to be disclosed. The checklist keeps the wording simple and high-level, so you stay compliant without giving away how your process works. Here's how to disclose AI use without inviting fraud.
Interviewed candidates need a response inside a set window. The checklist gives you a logged, consistent way to close the loop with everyone you interview, which also protects you if a hiring decision is ever questioned.
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