Ontario AI Disclosure in Hiring: Job Posting Language + Internal Policy
Understand Ontario AI hiring disclosure, who the job-posting rules cover, sample wording and a practical internal review checklist.
Ontario AI Disclosure in Hiring: What Employers Need to Know
Ontario’s public job-posting rules have applied since January 1, 2026. Employers with fewer than 25 Ontario employees on the posting date are generally exempt. Start by checking employer coverage, not by assuming every job advertisement has the same obligations.
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What Ontario Currently Requires: The AI Disclosure Rule
A covered employer using AI to screen, assess or select applicants must disclose that use in the public job posting. Check tools used by recruiters acting for you as well as tools your own team uses.
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Which Job Postings Are Covered
Check the official definition before applying the rule. Internal-only postings and general recruitment campaigns without a specific position are excluded; geographic exclusions also apply. Public career pages and job boards can carry covered advertisements.
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What Must Be Disclosed
Describe the AI use accurately and plainly. Ask the recruiting team what each tool actually does; do not rely only on a vendor’s product label. Keep the disclosure aligned with the workflow for that vacancy.
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Sample Disclosure Wording (Best Practice)
“We use artificial intelligence to help screen and assess applications for this position.”
This is an illustrative example, not a prescribed form. Adapt it to your process. Only promise human review of every application if that is what your team actually does.
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Effective Date
These requirements are in force, not awaiting proclamation. Review existing recruitment procedures now and assign an owner to check new postings before they go live.
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Internal AI Hiring Policy (Best Practice)
Keep a tool inventory, assign owners, review vendor data-handling terms, document human oversight and provide a route for accommodation requests. These are practical governance recommendations, not a substitute for required posting disclosures. Choose retention periods for AI logs based on the applicable law and purpose rather than retaining everything indefinitely.
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Human Rights and Privacy Considerations (Related Compliance Risk)
Assess privacy coverage separately. PIPEDA’s employee-information provisions concern federal works, undertakings and businesses; do not assume they cover every Ontario employer’s internal applicant records. Other obligations may apply. Limit access to applicant information, explain your actual practices, and provide a contact for questions.
AI disclosure does not replace human-rights responsibilities. Review screening criteria for discrimination and make accommodation requests accessible to applicants.
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- https://www.priv.gc.ca/en/privacy-topics/employers-and-employees/02_05_d_17/
- https://www.ohrc.on.ca/en/human-rights-workplace
Required Posting Records and Other Recruitment Records
Keep covered postings and associated application forms for three years after public access is removed. Keep required interview-status communications for three years after providing them. This does not establish one blanket retention period for every AI log or applicant document.
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How This Fits with Other Ontario Job Posting Rules
Covered postings also need compensation and vacancy information and must not require Canadian experience. The compensation range width is capped at $50,000 annually; disclosure has an exception when compensation, or the range’s upper end, exceeds $200,000 annually. The $50,000 figure is not a salary threshold. Track the required 45-day interview-status communication deadline.
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- https://www.ontario.ca/document/your-guide-employment-standards-act-0/recent-changes
- https://www.ontario.ca/document/your-guide-employment-standards-act-0/requirements-related-publicly-advertised-job
Employer Compliance Checklist: Ontario AI Disclosure
- Confirm coverage and the Ontario headcount.
- Ask internal and external recruiters about AI use.
- Review the advertisement and associated form together.
- Save the published version and record its removal date.
- Assign interview follow-up reminders and a record owner.
- Train hiring managers on your actual tools and procedures.
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Frequently Asked Questions: Ontario AI Disclosure in Hiring
Is an internal policy enough? No; it does not replace a covered advertisement’s disclosure.
Should the sample promise a human decision-maker? Only describe the oversight you actually provide.
How should we assess a tool? Check its function against the definition in the official guide and ask the vendor for an explanation you can retain.
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Next Step: Review One Live Job Posting
Review one advertisement with your recruiting lead. Identify the tools, posting owner, interview follow-up dates and record location. Use that exercise to improve the next posting. Continue with the employer guides and HR compliance checklist.
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Key Takeaways
- The job-posting rules took effect January 1, 2026 and generally cover employers with 25 or more Ontario employees.
- Check AI disclosure, compensation, vacancy information, Canadian-experience requirements and interview follow-up together.
- An internal AI policy supports consistent practice but does not replace information required in a covered job advertisement.
- Keep required posting and interview-communication records; use a separate, appropriate retention schedule for other applicant information.