Canadian Provincial 2026 Pay Transparency and Artificial Intelligence (AI) Disclosure Requirements

Pay transparency can be a divisive and confusing topic. Employers are reluctant to share. Employees want to know more. The Canadian federal government can’t make a broad decision that applies to all. Provincial governments are left to make different decisions for their jurisdictions. More recently, AI usage disclosure has been discussed as it relates to the hiring process. This article covers what a Canadian employer needs to know and what a job candidate should expect.

1. Pay transparency - Prince Edward Island (PEI)

PEI was ahead of the Canadian curve, with legislation introduced in 2022. PEI requires employers to disclose pay or pay ranges in publicly listed job postings. PEI also makes this expectation easily accessible, which is appreciated by all.

As an added piece of legislation, employers in PEI are not allowed to ask candidates about their pay history. Candidates may provide such information voluntarily, if they choose.

2. Pay transparency - British Columbia (BC)

BC introduced legislation covering multiple aspects in 2023. The first piece implemented was a requirement for employers to disclose an expected salary or salary range in late 2023. Also in 2023, employers were no longer allowed to ask candidates about their pay history.

BC also decided to enforce pay gap reporting, with a phased approach, after seeing an 18% gender pay gap in 2022. Organizations with 1,000+ employees were required to start reporting in November 2024, while employers with 300+ and 50+ employees had their reporting requirements start in November 2025 and November 2026.

3. Pay transparency - Ontario (ON)

Canada’s largest province by population introduced legislation in 2024, with an effective date of January 2026. Starting in 2026, employers are required to post a salary or pay range in job postings. The salary is supposed to be an all-in amount, inclusive of all compensation, including base salary, variable compensation, or other forms of compensation. The range cannot be more than $50,000 and the requirement only applies to employers with 25+ employees. The legislation also does not apply for roles where the top end of the compensation range is above $200,000.

4. Pay transparency - other provinces

Some other provinces are still working on legislation but no requirements are currently in place.

5. Pay transparency - template disclosure for Ontario (ON)

We provide practical guidance but you should consult an HR professional or employment lawyer if you have questions about your specific circumstances. Here’s an example disclosure:

“The expected total compensation for this role is $50,000-$75,000. This is inclusive of base salary, a discretionary bonus, and the insurance benefits available for this role.”

6. AI disclosure - Ontario (ON)

Starting in January 2026, Ontario employers who are using AI must disclose how they are doing so. They must include such disclosure in the job posting. This requirement applies to the process of reviewing or assessing candidates.

Ontario introduced additional requirements as part of this legislation, including the prohibiting of Canadian experience criteria, a need to disclose whether the posting is for an existing job vacancy, communication to interviewed candidates within 45 days of the last interview, and the retention of advertised jobs as well as application forms for three years after posting. 

7. AI disclosure - Quebec (QC)

As part of Law 25, Quebec has introduced regulation that requires employers to disclose when decisions are made exclusively through automated process.

8. AI disclosure - other provinces

Other provinces do not currently have AI disclosure requirements in place.

9. AI disclosure - template for Ontario

Organizations that do not use AI in their hiring process do not have a disclosure requirement. We are seeing more and more employers using AI in hiring. For employers using AI in the resume screening process, the most common use case we are seeing today, below is a template for Ontario employers:

“We use artificial intelligence (AI) to review resumes of candidates and assess their fit based on the criteria outlined in the job posting. We do not use AI to make any final hiring or interview decisions.”

10. AI usage in Collage

Collage introduced AI in its applicant tracking system with an AI resume screener, to allow employers to enter a prompt and see a candidate summary and a percentage fit on a scale of 0-100%, based on the prompt.

Collage’s AI resume screener is completely optional, requires a prompt to activate, and is included with our applicant tracking system.

We’ve seen incredible adoption of our AI resume screener, saving employers many hours in the hiring process.

11. Overall guidance

You should know your requirements based on your jurisdiction. You may want to consult an HR or legal professional if you need additional support. Johanna Hildebrand, an HR expert and a leader at People First HR Services, has seen an influx of questions from clients on pay transparency and AI disclosure.

Johanna provides additional guidance to employers: “Current legislation sets a minimum bar of disclosure, where any employer may decide to do more. With Ontario and British Columbia being two of our three most populous Canadian provinces, there may be an expectation from Canadian applicants to see salary ranges. We advise clients to share more, rather than less, to attract the best candidates.”

At Collage, we have also seen a significant increase in questions on these topics with our HR On Call service. The service has been built to help Canadian organizations with employment legislation and HR best practices.