Ontario’s Working for Workers Four Act took effect on January 1, 2026, introducing a binding requirement for employers to disclose the use of AI in hiring. Employers with 25 or more employees must state in every publicly advertised job posting whether AI is used to screen, assess, or select applicants. The same disclosure must appear in associated application forms.
A “publicly advertised job posting” covers any external posting an employer or recruiter makes to the general public in any medium. The requirement applies on the date a posting is published.
The Ontario Ministry of Labour had not yet issued detailed guidance as of early 2026 on how to interpret key terms such as “screen,” “assess,” or “select,” leaving employers to apply their own defensible interpretation. Legal commentary suggests employers should document their AI tool inventory and assess which functions fall within scope.
The Act also introduced pay transparency and vacancy status disclosure obligations effective the same date.
The disclosure requirement creates a legal right for job applicants to know when AI influences their recruitment process. It does not extend to existing employees, does not require explanation of the AI methodology, and carries no obligation to offer an alternative human-led process.
Score note: dimension 9 scores 1 (workers have a partial legal right when AI is used in employment decisions; confined to hiring stage and disclosure only; no appeal or explanation right).