Ontario’s new AI Disclosure Rules in Hiring
Ontario is taking a clear step toward transparency in hiring. Effective January 1, 2026, employers with 25 or more employees will be required to disclose the use of artificial intelligence (AI) in the recruitment process for publicly advertised job postings. For employers, this is not just a “check-the-box” update to job ads. It requires understanding where AI is actually being used in your hiring process and putting practical controls in place to support compliance. Who the requirement applies to The disclosure obligation applies if all three of the following are true: If you have fewer than 25 employees, the disclosure requirement does not apply — though best practices around transparency and fairness still do. What counts as “AI use” in recruitment? This is where many employers underestimate their exposure. You do not need to be using cutting-edge or custom-built AI for the requirement to apply. If a tool uses automation, machine learning, or algorithmic decision-making to evaluate candidates, it likely counts. Common examples of AI use include: If an AI tool influences who advances and who doesn’t, assume disclosure is required. What the law actually requires Employers must include a clear, plain-language statement in the publicly advertised job posting (and any associated application form) that AI is used in the hiring process. What this actually means:
AI in HR: Balancing Efficiency with Ethics
Artificial intelligence (AI) has become the defining workplace disruptor of our time. In human resources, the adoption of AI tools is accelerating—whether in recruitment, onboarding, performance management, or even employee sentiment tracking. For employers, the opportunity is clear: AI promises efficiency, cost savings, and better decision-making. But it also raises questions of ethics, fairness, and trust that HR leaders cannot afford to ignore. As an HR consulting firm based in Canada, we’ve seen firsthand how organizations are approaching AI. While many are excited by the potential, others are hesitant—worried about reputational risk, compliance, and the unknowns. The reality is that both perspectives are valid. The challenge for HR is to embrace AI responsibly. Where AI is Transforming HR AI applications are already embedded in the employee lifecycle: In each case, the efficiency gains are significant. AI reduces administrative burden and allows HR professionals to focus on more strategic, human-centered tasks. The Ethical Tension With innovation comes risk. AI in HR intersects with sensitive employee data, personal histories, and career opportunities. The ethical questions are pressing: Ignoring these risks could erode employee trust and even expose organizations to legal liability. Building a Responsible AI Strategy in HR For employers, the path forward requires balance. Here are some principles we recommend: Why This Matters Now In a competitive labour market, organizations that adopt AI responsibly can differentiate themselves. They gain the benefits of efficiency and innovation, while also building trust and protecting their employer brand. Conversely, those who rush in without considering the ethical implications risk reputational damage, employee disengagement, and legal exposure. At the heart of HR is people. AI can enhance our ability to support them—but it must never replace the human judgment, empathy, and fairness that define strong workplaces. Final Thoughts AI in HR is not a question of if, but how. The challenge for employers is to harness AI’s power while upholding values of equity, transparency, and respect. That balance will define the future of work—and the organizations that get it right will be the ones who thrive. By: Carly Howard, Human Resources Manager