The job posting your team put up last week is now a legal document.
That’s not hyperbole. As of January 1, 2026, Ontario employers with 25 or more employees are operating under new requirements that govern exactly what must appear in every publicly advertised job posting, how long candidate records must be retained, and what happens if a hiring decision isn’t communicated on time. The legislation applies right now, and the penalties for non-compliance are real.
For manufacturing operations, the implications go beyond HR administration. Compensation transparency changes how candidates evaluate your postings, how your current workforce perceives equity in pay, and how competitive your recruiting is against employers who have figured out how to use these requirements to their advantage. The companies that treat this as a compliance burden will manage it minimally. The ones that treat it as a hiring strategy will benefit from it.
What the Law Actually Requires
Ontario’s Working for Workers Four Act introduced several new job posting obligations through amendments to the Employment Standards Act. They apply to any employer with 25 or more employees on the day a public job posting goes live. The threshold is headcount on that specific date, which matters for manufacturing operations with seasonal or fluctuating workforces. If you’re regularly near 25 employees, assume coverage and build compliant posting templates as your default.
The headline requirement is compensation disclosure. Every publicly advertised posting must include either a specific rate of pay or a compensation range. If you post a range, the spread cannot exceed $50,000. Roles where the expected compensation, or the top of the range, exceeds $200,000 are exempt from the salary disclosure requirement, though other posting obligations still apply.
The compensation that must be disclosed is defined by the Employment Standards Act’s definition of wages: base salary, hourly rate, formula-based commissions, and guaranteed or non-discretionary bonuses. Discretionary bonuses, tips, and employer contributions to benefits plans are excluded. That distinction matters in manufacturing, where total compensation packages often include shift premiums, overtime structures, and performance bonuses. Only the guaranteed, non-discretionary elements need to be disclosed in the posting.
Three additional requirements apply to every covered posting. First, if you use artificial intelligence to screen, assess, or select candidates, the posting must say so. That covers tools like automated resume screening or algorithm-based ranking software when they’re used to make or influence a selection decision, not every piece of recruiting software in your stack. A general disclosure statement in the posting is sufficient; you don’t need to describe the system in detail. Second, the posting must state whether it represents a real, currently open vacancy. Third, any candidate interviewed for the publicly advertised posting must be notified of whether a hiring decision has been made within 45 days of their last interview.
Finally, every covered job posting, along with related application forms, must be retained for at least three years after the posting is taken down.
Where Manufacturing Operations Are Getting Caught Out
Several patterns are generating compliance risk for Ontario manufacturers that haven’t fully updated their recruiting processes.
The most common issue is posting language that doesn’t meet the compensation disclosure standard. “Competitive salary,” “compensation commensurate with experience,” and similar phrases are not compliant. Neither is a range so broad it provides no meaningful information. A millwright posting that says “$40 to $90 per hour” may technically include a range, but it spans $100,000 annually at full-time hours, well beyond the $50,000 spread limit. The range must reflect what you’re actually going to pay for the role, not a catch-all band designed to preserve negotiating flexibility.
This creates an internal problem that many manufacturers haven’t solved yet: they don’t have documented, defensible compensation ranges for every role they hire for. Before a posting can be compliant, the compensation structure for that role needs to exist and be accurate. For organizations that have historically set pay on a case-by-case basis, or whose pay bands have drifted from market reality over time, the pay transparency requirement is surfacing a compensation data problem that needs to be addressed before it becomes a posting problem.
The AI disclosure requirement is also catching manufacturers off guard. Many HR and talent teams have adopted applicant tracking systems and recruiting software without explicitly categorizing which features constitute AI-assisted screening. If your ATS ranks or filters candidates algorithmically before a human reviews them, that likely triggers the disclosure requirement. A review of your recruiting technology stack, and a decision about what to disclose, should be part of your compliance process if it hasn’t happened yet.
The 45-day candidate notification rule is operationally underestimated. For manufacturing roles where the hiring process spans multiple stages and a decision might be delayed by operational priorities, failing to communicate with an interviewed candidate within 45 days of their last interview creates an ESA exposure. This requires a process change, not just a policy update. Someone needs to own the follow-up timeline, and hiring managers who are accustomed to letting candidate communication trail off when a decision isn’t made need to understand that the rule applies regardless of the outcome.
The Compensation Audit You Should Have Done by Now
The practical prerequisite for pay transparency compliance is an accurate, documented compensation framework for every role you hire for. If that doesn’t exist, building it is the first step.
For manufacturing operations, this means establishing pay bands for each role tier, grounded in market data, internal equity, and the actual compensation you’re willing to offer. The band needs to be tight enough to be meaningful to a candidate evaluating whether to apply, and it needs to reflect what you’re genuinely going to pay, not a number pulled from a national median survey without adjustment for your location, your industry segment, and your specific operational environment.
Market benchmarking in skilled trades is particularly important right now because wages have moved significantly over the past several years. A compensation band built in 2022 or 2023 for a millwright or instrumentation technician role may no longer reflect what’s needed to attract qualified candidates in Ontario’s current labour market. Posting a range that’s below market is now visible to candidates in a way it wasn’t before, which means an outdated pay band is both a compliance risk and a talent acquisition problem simultaneously.
The internal equity dimension matters as well. When you post a salary range externally, your existing employees can see it. If the range you’re advertising for a new hire is meaningfully different from what your current employees in equivalent roles are earning, the transparency requirement will surface compensation inequity that was previously invisible. For operations leaders, this is a reason to get in front of compensation reviews before posting rather than after.
The Strategic Case for Doing This Well
Pay transparency compliance done minimally, a technically valid number posted to satisfy the requirement, is a missed opportunity.
Research from Robert Half Canada found that 44% of hiring managers believe including salary ranges in job postings is the most effective way to attract top talent in 2026. The same research found that 48% of Canadian professionals cite a lack of transparency about pay as their top frustration when job hunting. Manufacturing employers who post genuine, competitive, well-structured compensation ranges are differentiating themselves in a market where skilled trades candidates have multiple options and are making faster decisions than ever.
A posting that includes a clear, market-aligned wage range, specific role requirements, and honest information about the working environment signals something to a candidate: this organization knows what the role is worth and is willing to say so. In a sector where compensation has historically been opaque and candidates have routinely accepted offers without knowing whether they left money on the table, that transparency is a genuine differentiator.
It also changes who applies. A precise, accurate compensation range pre-qualifies applicants more effectively than a vague posting ever could. Candidates who know the role pays $38 to $44 per hour will self-select based on that information, which reduces the volume of under-qualified or misaligned applications and improves the conversion rate from application to interview.
TPD partners with manufacturing operations across Ontario to support compliant, competitive posting practices and to benchmark compensation for skilled trades and technical roles against current market data. If your team is navigating the transition to pay transparency and wants to do it in a way that improves recruiting outcomes rather than just satisfying the minimum, our manufacturing workforce team is ready to help.
Connect with TPD’s manufacturing team here.
This blog provides general information about Ontario’s pay transparency requirements and is not legal advice. Consult an employment lawyer for guidance specific to your organization.