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:
Competing for Emerging Talent in 2025: Hiring Trends Every Employer Should Know

As we move through 2025, the hiring landscape for recent graduates is rapidly evolving. With economic uncertainty, the acceleration of AI, and shifting workplace expectations, a new reality has emerged for candidates and employers. While hiring has not come to a halt, it has certainly become more selective. In light of economic uncertainty, many businesses are limiting job openings or slowing down recruitment processes. As a result, recent graduates are applying to more openings and are exploring other fields that they otherwise wouldn’t have considered. For businesses looking to attract top early-career talent, understanding these changes are essential to understand.
1. Skills-Based Hiring Is More Prevalent.
2. Smaller Companies Are Gaining Appeal.
3. Hybrid Work Continues to be a Big Selling Point.
4. Diversity, Equity, and Inclusion (DEI) Continues to Matter.
5. Employer Branding Is Under the Microscope.
Hiring recent graduates in 2025 requires more than just posting a job ad. It demands a strategic approach that aligns with the evolving expectations of the next generation of professionals. By embracing flexibility, investing in skills-based assessments, and prioritizing transparency and inclusion, companies can not only attract great talent but also set the stage for long-term engagement and growth.
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Candidates Using AI in the Screening Process

The rise of AI tools is transforming various aspects of HR. Still, it poses new challenges, particularly when candidates rely heavily on AI to enhance their applications during the screening process. AI-generated cover letters, résumés, and interview responses are becoming more common, leaving HR professionals, recruiters and hiring managers to navigate between legitimate candidate efforts and AI-generated content. Some of these unique challenges include: 1. Assessing Authenticity How much of a candidate’s application is their work? With AI tools like ChatGPT or resume generators, candidates can create well-structured, polished applications with minimal effort and thought. While AI-generated content often looks impressive, it doesn’t always reflect the applicant’s true skills or qualifications. This creates a challenge in distinguishing between a candidate’s genuine experience and AI-enhanced embellishments. For example, a candidate might submit a highly tailored cover letter that seems perfect on paper, however during interviews, it becomes clear that they lack the depth of knowledge suggested in the application. This disconnect can lead to frustration and disappointment. 2. Evaluating Communication Skills Traditionally, a candidate’s writing — whether in a resume, cover letter, or email — offers insights into their communication skills, attention to detail, and professionalism. With AI tools capable of generating error-free, articulate responses, it becomes increasingly difficult to reliably gauge these attributes. Candidates who may not have strong writing skills can now submit AI-enhanced documents that hide their weaknesses. In roles where communication and thinking on your feet are critical, this could lead to misaligned hires. HR professionals and hiring managers must find new ways to evaluate a candidate’s abilities, relying less on initial written materials and more on real-time communication during the screening process. 3. Interview Preparedness and Genuine Responses AI tools are sophisticated enough to help candidates prepare for interviews by generating answers to common interview questions or simulating mock interviews. Some candidates are capable of discretely using an AI tool in virtual interviews that listen to questions asked in real time and generate a response in seconds. While preparation is important, over-reliance on AI can result in candidates delivering overly rehearsed or generic answers. Interviewers may find it difficult to assess a candidate’s problem-solving abilities, adaptability, or creative thinking if their responses are unoriginal and scripted, or worse yet – identical to other candidates, who are also using AI tools. 4. Ethics and Fairness As candidates increasingly use AI tools to gain an advantage, there’s a growing concern about fairness. Not all candidates have access to or choose to use AI tools, creating a potential disparity in the recruitment process. While some may leverage AI to craft impeccable applications, others who rely solely on their efforts might be at a disadvantage, even if they are equally or more qualified for the role. Conclusion AI is becoming more integrated into a candidate’s application process. While it serves as a valuable tool, it muddies the waters between genuine candidate effort and AI-generated content. To navigate this evolving landscape, HR professionals, recruiters, and hiring managers may need to adjust their testing and evaluation methods to ensure a fair process for all. Written by: Tiffany Leung, Partner, Consultant