Ontario’s Working for Workers Acts

 

A January HR Checklist for Automotive Employers

Ontario’s Working for Workers Acts were never designed as a single moment of change. They are a series of layered updates that, over time, have significantly expanded employer obligations around hiring practices, harassment prevention, documentation, and transparency.

By January 2026, many of these requirements are no longer “new.” That’s exactly why they pose risk.

When rules settle into the background, organizations assume they’re already compliant. In reality, gaps tend to appear in job postings, recruitment follow-up, policy language, and record retention. For automotive employers operating in a fast-moving, decentralized environment, those gaps add up quickly.

This article breaks down what matters now and offers a practical checklist to start the year on solid footing.



The Scope Has Expanded, Even If the Work Feels the Same

Ontario’s legislative changes under the Working for Workers framework have touched multiple areas of HR, but three themes continue to surface in enforcement and advisory conversations:

  1. How harassment is defined and addressed

  2. How hiring and job postings are handled

  3. How well employers can document and prove compliance

The intent behind these changes is consistent: reduce ambiguity and increase accountability. For employers, that means less reliance on informal practices and more emphasis on systems, training, and records.



Harassment Definitions Now Explicitly Include Virtual Conduct

One of the most important shifts is the expanded definition of workplace harassment.

Harassment is no longer limited to in-person interactions. Virtual and online conduct, including emails, text messages, messaging platforms, and video calls, are explicitly in scope.

For automotive employers, this matters because:

  • A significant amount of communication now happens digitally

  • Multi-location teams rely on messaging tools

  • Conflicts and complaints increasingly originate online, not on the shop floor

What this means in practice

  • Harassment and respectful workplace policies must explicitly reference virtual conduct

  • Reporting procedures must apply equally to digital interactions

  • Managers need guidance on how to handle issues that occur outside traditional physical workplaces

Policies that rely on vague language or assume in-person interactions only are no longer sufficient.



Job Posting Rules: Transparency, Retention, and Follow-Up

Ontario’s rules around publicly advertised job postings continue to require careful attention.

Employers must ensure:

  • Salary or salary range transparency where required

  • Retention of job postings for three years, even after roles are filled

  • Clear documentation of recruitment processes

An often-missed requirement is the obligation to inform unsuccessful candidates within 45 days after a hiring decision is made for a publicly advertised position.

This requirement affects:

  • Dealerships with high-volume hiring

  • Groups using multiple posting platforms

  • Teams relying on recruiters or external job boards

If there is no clear process for tracking applicants and communicating outcomes, this obligation is easy to miss.

January reality check:
If someone asked your team to show when and how unsuccessful candidates were notified, could you do it quickly?



Recordkeeping Is No Longer Passive

A consistent theme across the Working for Workers changes is record retention.

Employers are expected to keep:

  • Job postings

  • Application records

  • Training completion logs

  • Policy acknowledgements

  • Harassment complaint documentation

The issue is rarely that records don’t exist. It’s that they are fragmented across inboxes, shared drives, and paper files.

When documentation can’t be produced efficiently, employers are exposed, regardless of intent.



A Note on Broader Legislative Awareness

While this article focuses on Ontario, automotive employers operating across provinces need to be mindful of differences elsewhere.

For example, Prince Edward Island has proposed changes to vacation entitlement milestones, reducing the threshold for three weeks’ vacation from eight years of service to five. While not yet in force, organizations should already be considering how accrual systems and payroll configurations would adapt if implemented.

The takeaway is not to overreact, but to plan. Employment standards continue to evolve, and systems that cannot accommodate change quickly create unnecessary risk.



January Compliance Checklist for Automotive HR

Use this as a practical starting point for Q1.

Policy Updates

  • Confirm harassment policies include virtual and online conduct

  • Ensure reporting and investigation procedures are clearly defined

  • Review respectful workplace language for consistency with current definitions

Hiring & Recruitment

  • Audit publicly advertised job postings for transparency compliance

  • Confirm postings are retained for at least three years

  • Implement or validate a process to notify unsuccessful candidates within 45 days

Training

  • Refresh manager training on harassment prevention and response

  • Ensure training completion is documented and easily retrievable

  • Reinforce expectations around digital communication conduct

Documentation & Systems

  • Centralize hiring, training, and policy records where possible

  • Reduce reliance on email-only documentation

  • Validate that records can be produced quickly if requested



Why This Matters Now

Ontario’s expectations are no longer theoretical. They are operational.

For automotive employers, strong compliance creates:

  • Clearer decision-making for managers

  • Greater consistency across locations

  • Reduced exposure during audits or complaints

  • Stronger trust with employees

The goal is not perfection. It’s defensibility.


 

The Working for Workers Acts have reshaped how employment standards are applied in Ontario. By January 2026, the question is no longer whether these rules apply, but whether your systems reflect them.

A short, focused compliance review now can prevent much larger issues later in the year.

Have Questions About 2026 Compliance?

Employment standards and health & safety expectations are continuing to evolve, and staying compliant isn’t always straightforward, especially across provinces.

If you have questions about how these changes apply to your dealership or dealer group, or want to better understand where your current processes may be exposed, our advisory team is here to help.

Connect with our advisory team to talk through your questions, review your current approach, and learn how to stay compliant without adding unnecessary complexity.

Picture of Mandy Deveau
Mandy Deveau

Dealer Communication & Engagement

Keywords: Ontario Working for Workers Act, Ontario employment law automotive, dealership HR compliance Ontario, automotive HR compliance Ontario, Ontario workplace harassment requirements

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