25 employees on January 1, 2027? The Ontario rules that switch on, and the March 1 deadline

Ontario sets several employer rules at 25 employees, and they don’t all count on the same day. The two written policies depend on your headcount on January 1. The job-posting rules depend on the day you post a job. The new-hire information rule depends on the new employee’s first day. Here’s each one, with what it requires.

How to count to 25

• Count individual employees, not full-time equivalents. A part-time or casual employee counts as one.
• Include employees on leave or on layoff.
• Add up all your Ontario locations. Related businesses may be treated as one employer.
• Temporary help agency workers count toward the agency’s total, not the client’s.

1. A written policy on disconnecting from work

Disconnecting from work means not engaging in work-related communications, such as emails, calls and messages, so employees are free from the performance of work. The policy has to cover all of your employees in Ontario. It must state the date it was prepared and the date of any changes.

The law doesn’t set what your policy must say about after-hours contact, so it’s yours to decide: who may be contacted, for what, and how quickly anyone is expected to answer. What matters is that it’s written, dated, given to everyone, and that it matches how your business actually works. The law doesn’t require the policy to give employees a right to disconnect, but if your policy promises more than the law does, that promise can become enforceable, so write only what you’ll stand behind.

2. A written policy on electronic monitoring

This one has required contents. It must say:

• whether you electronically monitor employees;
• if you do, how and in what circumstances you monitor them;
• the purposes for which you may use information obtained through monitoring;
• the date it was prepared, and the date of any changes.

It must cover every employee in Ontario, including managers and executives who are employees. The policy doesn’t give employees a right not to be monitored and doesn’t create new privacy rights. It makes your monitoring transparent. Think wider than cameras: GPS in vehicles or phones, company email and chat logs, key cards, and software that tracks logins or activity can all count.

The deadline, the copies and the records

A printed copy, an email attachment the employee can print, or a link they can reasonably reach and print all work. You don’t have to hand it out again until the policy changes, but you should be able to show that each person got it.

3. Rules for publicly advertised jobs

Since January 1, 2026, employers with 25 or more employees on the day they post a public job ad must:

• include the expected pay or a pay range, with a range no wider than $50,000 a year (not required for jobs paying more than $200,000 a year);
• say whether AI is used to screen, assess or select applicants;
• say whether the posting is for an existing vacancy;
• not require Canadian work experience, including in the application form;
• tell each interviewed applicant whether a hiring decision has been made within 45 days of their last interview;
• keep each posting, its application forms and the notices to interviewed applicants for three years.

General “we’re hiring” ads that don’t name a position, and internal postings open only to current employees, aren’t covered.

4. Written information for new hires

Since July 1, 2025, employers with 25 or more employees on a new employee’s first day must give them, in writing and before they start where practicable: your legal and operating name, contact details, a general description of where they’ll work, their starting wage, the pay period and pay day, and a general description of their initial hours.

A checklist for January 2027

1. Count your Ontario employees on January 1, 2027, the way the law counts them.
2. If you have 25 or more, write or review both policies and date them.
3. Get them in place before March 1, and give every employee a copy within 30 days.
4. Keep proof of who received each version, and keep every version for three years.
5. Check your job-ad template and your offer-letter process against the 25+ rules.

The free compliance audit asks for your headcount today and on January 1 and lists what applies. In Prodigy Suite, both policies are drafted from your answers, sent to every employee to read and sign on their phone, and kept with every version and signature, so the 30-day distribution is on record.

Questions people ask

Sources

1. Ontario: Written policy on electronic monitoring of employees (updated July 8, 2024)
2. Ontario: Written policy on disconnecting from work (updated July 8, 2024)
3. Ontario: Requirements related to publicly advertised job postings (updated February 24, 2026)
4. Ontario: Mandatory information for employees (updated November 18, 2025)
5. Employment Standards Act, 2000 (e-Laws)

This article is general information about Ontario’s rules as of October 15, 2026, not legal advice. Prodigy Suite isn’t a law firm. For a specific situation, speak to an Ontario employment lawyer.