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Ontario Bill 149 (Working for Workers Act): AI hiring disclosure
Ontario’s Working for Workers Act amended the province’s Employment Standards Act to require disclosure when AI is used in hiring. It is Canada’s first in-force, HR-specific AI disclosure law.
Last reviewed: 29 September 2026
Scope and core requirement
Bill 149 applies to Ontario employers with 25 or more employees that use AI to screen, assess or select job applicants. This includes AI built in-house and AI embedded in third-party applicant-tracking platforms, which many employers don’t realise are switched on by default.
Job postings must carry a specific disclosure statement that the employer uses AI to assist in screening, assessing or selecting applicants for the role.
What it does not do
Bill 149 regulates disclosure only; it does not directly govern the hiring decision itself or require bias audits. However, discriminatory outcomes from an AI hiring tool can still trigger a separate complaint under Ontario’s Human Rights Code, regardless of whether the disclosure was made. The disclosure record itself can become evidence in such a complaint.
Penalties
Employment Standards Act violations carry fines of up to CAD 100,000 for individuals, with higher exposure for corporations. Human rights complaints under the Code carry no financial cap and can include compensation for injury to dignity and lost income, plus mandatory policy changes.
This page is general information, not legal advice. AI employment law is moving quickly; confirm your position with qualified counsel before relying on it.
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