Many employers assume equity plans play by different rules. 

Different from employment contracts. 
Different from termination clauses. 
Different from Employment Standards Act (“ESA”) analysis. 

A recent Ontario decision suggests otherwise, and the implications are significant for employers who rely on equity‑based compensation. 

In Liggett v. Veeva Software Systems, Inc. and Veeva Systems Inc., the Court confirmed that restricted share unit (RSU) termination provisions are analyzed using the same legal framework as traditional termination clauses. If a termination clause fails ESA scrutiny, equity language that limits compensation during the notice period may fail as well. 

For employers, this decision reinforces a critical point: equity plans are not insulated from employment law risk. 

The Court’s Core Message: Equity Is Still Compensation 

The key takeaway from Liggett is relatively straightforward (but not uncontested). When equity compensation forms part of an employee’s remuneration, courts will analyze forfeiture provisions using the same principles that apply to salary, bonuses, and other compensation. 

Justice Des Rosiers stated clearly: 

“It is incumbent on employers to state clearly to the employees what will happen upon termination… language that violates the ESA voids the termination clauses because employees may be misled as to their entitlement and not recognize that they are forfeiting rights the common law gives them. I conclude that a similar approach must be used in interpreting contractual language that seeks to deprive employees of bonus or stock options to which they would have been available during the notice period.” 
(Liggett v. Veeva Software Systems, Inc., at para 54) 

The Court rejected the idea that employers can avoid scrutiny simply because a forfeiture clause appears in an equity plan rather than the employment agreement itself. If the clause affects compensation during the notice period, it will be reviewed through the same ESA‑compliance lens. 

ESA Compliance Is Not Optional, Even in Equity Plans 

Ontario courts have consistently held that termination clauses must clearly comply with the ESA. Any ambiguity that could mislead an employee about their minimum statutory entitlements risks rendering the clause unenforceable. 

Liggett confirms that this principle extends to equity plans. If RSU language attempts to cut off vesting or entitlement as of the last day worked, without properly accounting for statutory notice or pay in lieu, it may be vulnerable to challenge. 

Complexity Is Not a Defence 

The Court was also critical of the structure and readability of the agreement itself. Justice Des Rosiers observed: 

“The contract is particularly convoluted in its format and readability… To understand the applicable clause requires a cutting and pasting between different sections of a lengthy contract.” 
(Liggett, at para 52) 

This observation should resonate with many Canadian employers. 

Small and mid‑sized organizations (even large ones) often rely on: 

  • Template equity plans from U.S. parent companies 
  • Investor‑driven documents 
  • Multi‑jurisdictional global plans drafted for multiple legal regimes 

While these documents may satisfy corporate or investor expectations, they create risk when applied to Canadian employees. Courts expect clarity, especially where employees are being asked to give up valuable common‑law or statutory rights. 

Complexity does not shield employers from liability. In fact, it may do the opposite. 

A Potential Shift? The Pending Wigdor Appeal 

The decision also raises an interesting contrast with Wigdor v. Facebook Canada Ltd., 2025 ONSC 4861, which some commentators suggest reflects a different analytical approach to equity forfeiture. 

Notably, the Ontario Court of Appeal is scheduled to hear the Wigdor appeal in April of 2026. That decision may provide further guidance on how equity plans interact with common‑law notice entitlements. 

Until then, Liggett signals that courts are prepared to apply strict scrutiny to equity language, particularly where ESA compliance is in question. 

The Strategic Takeaway 

Liggett v. Veeva Software Systems, Inc. confirms that RSU clauses are not special and they are not immune. Courts will analyze them using the same playbook applied to termination clauses generally. 

For employers, the message is clear: if your termination clause would fail ESA scrutiny, your equity plan may be exposed as well. 

Clarity, compliance, and careful drafting remain the best risk‑management tools available. 

A quick review today can prevent a costly surprise tomorrow. Contact us. 

Workforce planning has always been a balancing act. Employers move between hiring, restructuring, and supporting employees through personal and medical challenges. The latest ESA updates covering layoffs, illness leave, and job seeking time during mass terminations give employees stronger stability while asking employers to be more structured during mass terminations 

Ontario’s new extended temporary layoff rules give employers more time, but only with the right paperwork. A layoff can now stretch beyond the old 35-week limit as long as it stays under 52 weeks in a 78-week period. However, the employee must agree in writing, must be given a firm recall date, and must understand the agreement cannot be withdrawn. The Director of Employment Standards must also approve it. And employers must keep documentation for three years. 

For small employers, this is not administrative noise; missing a step can turn a layoff into a termination, triggering notice, severance and other obligations that can surprise a lean team. 

Another major update is the new three days of job seeking leave during mass terminations, which apply when 50 or more employees are let go within four weeks. Employees can use this time for interviews, appointments, or preparing applications, and employers can ask for reasonable evidence. 

Meanwhile, the long-term illness leave enhancement brings a meaningful change for workers facing serious health conditions. Employees who have passed 13 weeks of service now have access to up to 27 weeks of unpaid protected leave. This amendment aligns Ontario closer to federal sickness benefit timelines, and it creates ripple effects for staffing, coverage planning, and return-to-work conversations. 

These updates echo the values behind SpringLaw’s work: transparency, humane processes, and collaborative problem solving, even during difficult workforce transitions. 

The new rules may extend your processes, but they also reduce risks when handled thoughtfully. With clear documentation and early planning, employers can navigate these changes while maintaining empathy and compliance. 

If your team is preparing for restructurings or needs help updating leave and layoff workflows, our SpringLaw lawyers can help you build a smooth, defensible process. Contact us to support your compliance and workplace planning needs. 

If your team plans to hire in 2026, you will be working under a new set of Ontario rules that reshape requirements for public job postings. With a bit of preparation, employers can implement processes that ensure their compliance going forward. These changes can feel like one more thing to juggle. With some planning, you can turn this into a moment of clarity, fairness, and smoother hiring.

These updates may actually simplify your day to day once you build them into your routine, bringing more predictability to a hiring process that often feels rushed or unclear.

Pay Transparency Requirements

Starting January 1, 2026, any employer with 25 or more employees on the date the job is posted must disclose real pay information in every public posting. That means either:

  • a clear salary number
  • or a salary range with no more than a $50,000 spread
  • These rules do not apply if compensation is over $200,000.00 annually. 

Clear pay upfront reduces unnecessary applications and repetitive questions. This gives your team more time to focus on work that actually moves your business forward.

Vacancy vs. Pipeline Disclosure

Every public posting must also explain whether the job is:

  • tied to an actual vacancy 
  • or part of a pipeline, giving applicants a sense of urgency and timing.  

This small detail sets expectations early and improves the overall candidate experience.

No More “Canadian Experience” Requirement

Ontario employers are no longer allowed to require “Canadian experience” in job postings.

This expands your talent pool and shifts the focus toward real skills, potential, and fair access.

AI Transparency in Hiring

If any automated or AI‑supported tools screen, rank, or assist with hiring decisions, employers must disclose this clearly in the posting. This includes tools built into your ATS that may be working quietly in the background.

A simple one-line disclosure helps you stay compliant and signals a hiring process that values transparency and trust.

Timely Applicant Communication

Employers must inform interviewed candidates of the hiring decision within 45 days.

Clear timelines reduce candidate follow-ups and protect your team from the stress that comes when process gaps create avoidable misunderstandings.

Why These Rules Matter

These rules reflect a broader shift toward thoughtful, transparent hiring processes that support fairness and reduce workplace stress.

Clarity and transparency often do more than meet legal standards. They create a calmer internal workflow and a stronger impression of your organization.

A Smoother Path Forward

While this may feel like a lot to take in, these changes create a cleaner and more respectful hiring experience for everyone involved. With a consistent template and a few workflow updates, your team can meet these requirements without scrambling.

A simple checklist or shared hiring template helps keep your process steady, even when hiring feels hectic.

Need Support?

If you want help updating your job posting templates or tightening your hiring workflow, our SpringLaw team can support your employment and compliance needs. Reach out and we will help you stay ahead calmly, clearly, and confidently.

We are here to help you build hiring systems that feel clear and manageable, so compliance becomes one less thing to worry about.

Hiring is one of the most time-consuming parts of running a business. It is also one of the riskiest. 

So it is no surprise that employers are turning to AI to speed things up. Resume screening tools. Automated shortlists. Chatbots that pre-screen candidates. Applicant tracking systems that rank people before a human ever looks at an application. 

While it can streamline workflows, it might also create legal exposure for many employers. 

If you use AI in hiring, or plan to, there are new rules you need to understand, especially in Ontario. And even if you outsource hiring to software or recruiters, the risk still lands on you. 

How AI Helps with Hiring Decisions 

Many common hiring platforms now use AI or algorithmic decision-making behind the scenes. That includes tools that: 

  • Screen resumes 
  • Rank candidates 
  • Filter applicants based on keywords 
  • Assess video interviews 
  • Predict “job fit” 

In many cases, employers do not control how these systems are trained or what data they rely on. They just see the output. 

That is how legal problems can result. 

Using AI Does Not Help You Avoid Your Human Rights Obligations 

Canadian employment law does not care whether discrimination was intentional, unintentional, or based on a machine’s output. 

If a hiring process screens out candidates in a way that disproportionately impacts protected groups, that can still lead to a human rights complaint. 

AI tools often rely on historical data. If past hiring decisions reflected bias, the AI may simply repeat it. Faster and at scale. 

However, one thing is clear: employers cannot hide behind technology. If your hiring process discriminates, you are ultimately responsible. 

The Ontario Disclosure Rule 

Under the Working for Workers Four Act, 2024, employers now have a new, explicit obligation when using AI in hiring. 

Effective January 1, 2026, employers must disclose the use of artificial intelligence in job postings if AI is used to screen, assess, or select applicants, though there are some specific exceptions (consult your lawyer for details!). 

The law requires employers to include a statement in publicly advertised job postings disclosing the use of AI. It applies even if: 

  • The AI is provided by a third party 
  • The AI only assists part of the process 
  • A human still makes the final decision (which should always be the case anyways) 

What Employers Get Wrong About Disclosure 

Disclosure does not remove liability. It does not fix bias. It does not protect you if the tool itself is flawed. 

What disclosure does is provide transparency.  

Once applicants know AI is involved, they may ask: 

  • How does the tool work? 
  • What data does it rely on? 
  • Does it disadvantage certain groups? 

If you cannot answer those questions, that is a problem. 

Bias Claims Are No Longer Hypothetical 

We are already seeing lawsuits in the U.S. tied to algorithmic hiring tools. Canadian lawyers are watching closely. 

The risk is not limited to obvious discrimination. AI tools can unintentionally screen out candidates based on: 

  • Race 
  • Gender 
  • Other protected human rights grounds 
  • Proxies for human rights grounds, such as languages spoken 

An employer may have never intended to discriminate, but that does not stop a claim, nor can it be a defence against one. 

Outsourcing Hiring Does Not Outsource Liability 

A common mistake employers make is assuming liability shifts to the software provider. It does not. 

If you use an AI-powered hiring platform, you are still responsible for ensuring your hiring process complies with: 

  • Human rights legislation 
  • Employment standards 
  • Privacy obligations 

Before using any AI hiring tool, employers should be asking: 

  • What data trained this system? 
  • Has it been audited for bias? 
  • Can decisions be explained? 
  • Can humans override outcomes? 
  • Does it promote equity and diversity? 

If the answers are vague, that is a red flag. 

Human Oversight Is Not Optional 

One of the most important safeguards employers can implement is meaningful human review. 

That means: 

  • Humans understand how the tool works 
  • Humans review outputs critically 
  • Humans can intervene 
  • Humans make the final decision 
  • Humans remain accountable 

Blind reliance on rankings or scores is risky and ill-advised. Courts expect employers to exercise judgment, not defer to technology. 

The Bottom Line for Employers 

AI can make hiring faster. It can also make mistakes faster. 

Ontario employers now face a clear regulatory obligation to disclose AI use in hiring. Beyond that, human rights exposure remains ever present. 

If you are using AI in hiring and you are not sure whether you are compliant, be sure to consult your lawyer. 

Employers should review their hiring tools, update job posting practices, and put guardrails in place. 

If you want help reviewing AI hiring practices, drafting compliant disclosures, or building policies that actually work in real workplaces, contact us, call us, or schedule an appointment with us. Fixing this after a complaint is far more expensive than getting it right now. 

A new year brings fresh plans, renewed energy, and big goals for growing your business. But January is also when many Ontario employment law changes quietly take effect. If your HR documents have not been reviewed recently, you could be starting 2026 with more risk than you realize.

For small and mid-sized employers, outdated contracts, policies, or job postings are one of the most common sources of workplace disputes. The good news is that a proactive review now can save you stress, time, and legal costs later.

Why January Is the Right Time to Review Your HR Documents

The start of the year is more than a symbolic reset. It is a practical checkpoint for your workplace compliance.

Here is why reviewing your HR framework now matters:

  • Employment laws change on January 1
    Many legislative updates in Ontario come into force at the start of the year. Waiting months to review your documents can leave you exposed.
  • Fresh eyes catch old problems
    January creates space to look honestly at what is working and what is outdated, unclear, or no longer enforceable.
  • Growth exposes weak systems
    Hiring, restructuring, or expanding without solid HR documents often leads to costly mistakes.
  • Clear rules reduce friction
    Strong, updated policies give managers confidence and employees clarity, which reduces conflict before it starts.

Ontario Employment Laws Employers Should Know for 2026

Ontario workplace laws continue to change in response to labour shortages, evolving hiring practices, and increased focus on transparency and safety. If your HR documents do not reflect these updates, your business may already be behind.

Key Ontario legislative changes in force as of January 1, 2026 include:

Easier Labour Mobility for Certified Professionals

Ontario’s Labour Mobility Act introduced an “as of right” framework that allows many non-health regulated professionals from other provinces to work in Ontario more easily. This affects over 50 regulatory bodies and hundreds of certifications. Health professionals are covered under similar legislation.

Why this matters for employers:
Recruitment policies, credential checks, and onboarding practices may need updating to reflect these changes.

New Job Posting Rules Under the Employment Standards Act

Ontario employers now face stricter rules around job postings, including requirements related to compensation disclosure, vacancy status, use of artificial intelligence in hiring, and barriers to immigrant workers.

Why this matters for employers:
Non-compliant job postings can attract scrutiny and complaints before a candidate is even hired.

Defibrillators Required on Certain Construction Sites

Under Ontario health and safety legislation, construction projects lasting three months or longer with 20 or more workers must now have a defibrillator on site and a trained worker available.

Why this matters for employers:
Health and safety policies and site procedures must reflect these obligations to avoid serious compliance issues.

Where HR Documents Commonly Fall Out of Date

Many employers assume compliance means reacting when something goes wrong. In reality, most issues start quietly with documents that no longer reflect the law or how the workplace actually operates.

A smart review looks at the entire employee lifecycle, including:

  • Recruitment
    Job postings, interview practices, timelines, and candidate communications
  • Hiring and onboarding
    Employment contracts, offer letters, probation terms
  • Active employment
    Workplace policies, procedures, employee handbooks, remote work rules
  • Health and safety
    Training records, reporting procedures, site-specific requirements

Why Updated HR Documents Protect Your Business

Your HR documents do more than sit in a folder. They shape how decisions are made every day and how disputes are resolved when things get difficult.

Keeping them current helps you:

  • Stay legally compliant
    Reduce the risk of penalties, investigations, or unexpected liability
  • Lower dispute risk
    Clear, enforceable documents prevent small issues from becoming legal problems
  • Support consistent management decisions
    Managers rely on policies when handling performance, discipline, and terminations
  • Build trust and clarity
    Employees are more confident when expectations are clearly set and consistently applied

Strong HR documents also signal professionalism. That matters when you are hiring, scaling, or dealing with a workplace issue under pressure.

A Proactive Approach Beats Damage Control

Waiting until a complaint, investigation, or termination forces a review is expensive and stressful. A proactive HR compliance review helps you identify gaps early and fix them before they create real problems.

At Spring Law, we work collaboratively with employers to review and update HR frameworks in a way that fits how your business actually operates. No legal jargon. No over-lawyering. Just clear, practical guidance that reduces risk and helps you get back to business.

As you plan for the year ahead, ask yourself one question:
Do your HR documents protect your business as it exists today, or the one you had years ago?

If you are not sure, that is usually your answer. Schedule time with us, it will be worth it. 

Source: Ontario regulations and statutes in force as of January 1, 2026.

Remote work settled into Canadian workplaces long ago, yet many employers still operate as though the shift was temporary. The result? Quiet risks, unclear expectations, and legal obligations hiding beneath everyday workflows. 

Remote work isn’t dangerous on its own; unstructured remote work is. 

The most common misstep happens before employers even realize it: allowing an arrangement to drift. When an employee works remotely for months or years without written terms or reminders that the arrangement may change, they may begin to view their home office as a permanent right. That’s how a reasonable recall to the office can quickly morph into a constructive dismissal claim. 

Employers often overlook a second critical point: Jurisdiction follows the worker.

If your Ontario-based employee moves to Alberta, Alberta’s employment standards may apply. That influences overtime, vacation, leaves, holiday pay, and hours-of-work rules, even if the employer never intended the shift. Remote work isn’t borderless…at least, not legally. 

And then there’s the pressure of constant connectivity for remote workers. Employees who check messages late at night rarely see themselves as still “working.” Employers with 25 or more workers must maintain a written Right to Disconnect policy, yet many treat it as paperwork rather than practice. A policy that sits in a handbook doesn’t stop the quiet build-up of unpaid hours, fatigue, and burnout. 

Remote monitoring has grown alongside remote work. Software now tracks logins, timestamps, keystrokes, and device activity, but transparency remains essential. Employees need to know if they’re being monitored, how, and why. This isn’t optional; it’s part of building a compliant and fair digital workplace. 

Finally, remote exits demand as much structure as remote onboarding. Revoking access, collecting equipment, and securing data can’t happen casually. A forgotten laptop or saved file on a personal device may expose confidential information that would never have left a traditional office. 

To help bring structure to this new reality, employers should keep a few essentials in mind: 

  • Remote work arrangements need written terms to avoid creating unintended rights. 
  • Employment standards usually follow the province where the work is performed. 
  • Ontario employers with 25+ employees need a Right to Disconnect policy. 
  • Any electronic monitoring must be disclosed to employees. 
  • Remote offboarding needs structure: equipment return, access removal, data security. 

Remote work can absolutely be a strategic advantage. But it works best when the flexibility employees love meets the clarity the law requires. 

If your workplace policies feel outdated or improvised, SpringLaw can help you build a remote-work system that protects your business and supports your team. Schedule a call today

The reality HR is facing 

More candidates are turning to AI for resumes, cover letters, and interview prep. Surveys in 2024–2025 show hiring teams are seeing a flood of applications and mixed quality, with many managers wary of AI-generated content. 

  • 38% of job seekers send 20 or more applications per week, and 54% of hiring managers say the surge slows hiring. 
  • 53% of hiring managers dislike AI-generated resumes. It’s the top red flag in one recent survey. 

Use AI to help, not to decide 

Keep humans in the loop. Use AI to sort large volumes, then have trained people review the outputs. This aligns with the spirit of Ontario’s 2026 disclosure rule and with what candidates say they want: transparency and human judgment. 

Five practical bias safeguards 

  1. Ask vendors about fairness tests. Request summaries of how the tool checks for biased outcomes. Avoid opaque “black box” scoring. Periodically audit a sample by hand. 
  2. Limit AI to admin steps. Use it for deduping, screening for must-have credentials, and scheduling. Keep human review for shortlists. 
  3. Standardize evaluations. Use consistent rubrics and document reasons for advancement. 
  4. Invite candidate feedback on forms and interviews to catch barriers early. 
  5. Train your team. People tend to over-trust automation. Training reduces that risk. 

Write job ads that welcome more talent 

AI can also improve inclusion at the top of the funnel. Use tools and prompts to cut jargon, reduce gender-coded wording, and clarify must-haves versus nice-to-haves. You’ll reach a larger, stronger pool and reduce the spray-and-pray effect that adds noise to your pipeline. 

Quick ad checklist 

  • Plain job title 
  • Three to five core duties 
  • Measurable outcomes for the first year 
  • Real pay range 
  • Clear “must-have” skills only 
  • Your AI disclosure line if screening uses AI 

Ontario compliance snapshot for 2026 

  • Disclose AI use in publicly advertised postings and associated application forms 
  • Pay range in postings and no “Canadian experience” requirement 
  • Applies to employers with 25+ employees 
  • Effective January 1, 2026 

What success looks like in 90 days 

If you run your hiring like any other key business process, set a simple 90-day plan with 3 to 7 priorities, assign owners, and review progress weekly. That’s how teams create traction and avoid stall-outs. 

  • Pick your disclosure line and add it to all templates this quarter. 
  • Audit one high-volume role and map where AI appears. 
  • Rewrite two key job ads with clear pay and simpler language. 
  • Train recruiters to answer AI questions from candidates. 
  • Schedule a monthly audit of AI-screened rejections to catch false negatives. 

Want help turning this into a one-page hiring playbook for your team, plus training and updated templates? 

 SpringLaw can build it with you. 

AI use in workplaces is growing quickly. A 2025 global study of more than 32,000 workers across 47 countries found 58 percent of employees report using AI at work, with roughly a third using it weekly or daily. Tech Xplore+1

Many employees say AI improves efficiency, idea generation, and work quality. McKinsey & Company+1

But this increased adoption comes with risks. Independent surveys of workers show many admit to inappropriate AI use, including uploading sensitive company data to public AI tools, using AI when it is not allowed, or failing to check the accuracy of AI-generated work. Fast Company+1

Why Banning AI Use Is a Bad Idea

With so many employees already using AI on their phones or home computers, a blanket ban is unlikely to work. Banning AI tends to drive use underground. That hiding can erode trust, lead to undisclosed mistakes, and harm company culture.

Even with a ban, the risks remain: Privacy breaches, improper use, and unrecorded AI-assisted work. Banning only reduces transparency.

A Better Approach: Train Your Workforce

Many of the problems associated with AI use stem from lack of understanding. The better path is to treat AI as a workplace tool and teach employees how to use it responsibly:

  • Train them on how AI works, including its limitations.
  • Emphasize verification: AI-generated content must be checked before use.
  • Teach confidentiality and data-handling best practices.
  • Provide examples of acceptable vs prohibited use.

Several workforce-AI studies highlight that adoption of AI tools tends to be far safer and more effective when paired with training, guidance, and human oversight. McKinsey & Company+1

If internal resources are limited, employers can rely on external training programs or vendor-provided onboarding.

Why You Need a Clear AI Policy

A thoughtful AI policy should cover:

  • Confidentiality and data protection.
  • Disclosure requirements for AI-generated work.
  • Verification of AI outputs.
  • Human accountability (final decisions remain with people.)
  • Intellectual property and attribution guidelines.
  • Prohibitions against certain risky AI uses (e.g. replicating someone else’s likeness or voice).
  • Clear consequences and reporting mechanisms.

There is no universal AI policy template. What works for one organisation may not suit another.

Encourage Ongoing Learning and Upskilling

Technology evolves quickly. Many experts find that a worker’s “skills half-life” is shrinking; what they know today may need a refresh in just a few years.

Employers should consider offering regular AI training sessions, time for self-directed learning, or even modest budgets for continuous education. Investing in people ensures that AI remains a tool, not a risk.

Final Takeaway

AI is already transforming workplaces. A ban may seem like an easy fix, but it rarely works in practice. A better strategy is to build trust, offer training, set clear policies, and encourage responsible use.

With the right approach, AI can boost productivity, support innovation, and help employees do better work, without compromising compliance or trust.

If your organisation needs help developing an AI use policy or staff training, feel free to reach out to our team for support.

Ontario’s Working for Workers Four Act, 2024 changes the Employment Standards Act. 

From January 1, 2026, employers with 25 or more employees must say in any publicly advertised job posting if AI is used to screen, assess, or select applicants. You must also include the same note in any associated application form. 

This sits beside other new posting rules, such as pay range disclosure and the prohibition on requiring “Canadian experience” in job postings. 

Who is covered 

  • Employers in Ontario with 25 or more employees. 
  • Publicly advertised job postings and related application forms. 

What must be disclosed 

A clear statement that your hiring process uses AI at any stage to screen, assess, or select candidates. Ontario has adopted a broad definition of AI, and the obligation is disclosure, not a full technical report. Expect further guidance as the effective date nears. 

Sample disclosure statements you can copy 

Pick one and tailor it to the tools you actually use. 

  1. “We use AI-enabled tools to sort applications based on job-related criteria. A human decides who moves forward.” 
  2. “Our hiring process includes AI screening for keywords and minimum qualifications. Recruiters review all results.” 
  3. “Video interviews may be scored with AI. Trained staff review the scores before any decision is made.” 

Tip: Keep it short, accurate, and visible on both the job ad and the application page. HR teams should be ready to answer candidate questions about AI use. 

Your 6-step compliance checklist 

  1. Inventory your tools. Note any software that ranks, filters, or scores candidates. 
  2. Decide what the tool does. Screening, assessing, selecting—or all three. Write it down in plain English. 
  3. Add disclosure lines to every posting and application form in advance of the deadline, ideally by December 2025. 
  4. Post pay ranges and remove “Canadian experience” requirements to prepare for the full 2026 posting rules package. 
  5. Train your team on how to answer candidate questions about AI. 
  6. Keep a human in the loop. Use AI to assist, not replace, decision makers. 

FAQs 

  • Do we need to name the vendor or publish model details?
    • No. The Act requires disclosure of AI use, not technical specs. Keep it clear and accurate. 
  • Does this apply to generic “Help Wanted” signs?
    • No. The duty targets publicly advertised postings, not generic notices. 
  • Is there guidance on exact wording?
    • Not yet. Legal commentators expect more direction before 2026, so monitor updates. 

Need a quick policy refresh before year-end planning? SpringLaw can review your hiring tools, draft compliant disclosure language, and train your team.