Ontario’s legislative pipeline shows no sign of slowing. On the heels of the “Working for Workers” series, now seven bills deep, the province has introduced Bill 105, the Protecting Ontario’s Workers and Economic Resilience Act, 2026. Introduced on April 20, 2026, the bill adds another set of changes for employers to absorb, including two that should be on every HR team’s radar: a meaningful expansion of how employment standards complaints are handled, and the first specific employment standards rules in Ontario governing uniform charges.
This post walks through what the bill changes, when those changes take effect, and what HR teams should do to prepare.
The Bill in Context
Bill 105 continues a trend that the Ontario government has been building for several years: tightening the rules around how employees are recruited, monitored, managed, and protected, while also strengthening the Ministry of Labour’s ability to enforce those rules. For multi-province employers, Bill 105 is one more reason that an Ontario-specific compliance lens is required, and that policies built around an earlier version of the Employment Standards Act, 2000 need to be reviewed regularly to keep pace.
Two parts of Bill 105 stand out from an HR standpoint: changes to the complaints and inspection framework, and a new restriction on charging employees for uniforms.
A Bigger Toolkit for the Director of Employment Standards
The first set of changes, which come into force on Royal Assent (meaning there is no grace period), significantly expands what the Director of Employment Standards can do when an employee files a complaint.
Under Bill 105, the Director will be permitted to assign complaints to an inspection rather than treating them strictly as individual disputes. That option will be available for complaints relating to:
- Job postings (including pay disclosure, AI-in-hiring disclosures, vacancy information, and other posting requirements introduced through the “Working for Workers” series).
- Disconnecting from work policies.
- Electronic monitoring policies.
- Temporary help agencies and recruiters.
For HR teams, this is a meaningful shift. A single complaint about a job posting, an electronic monitoring policy, or a disconnecting from work policy could now trigger a broader inspection of the employer’s practices in that area — not just a one-off resolution with the complainant. For organizations with high posting volumes or extensive monitoring programs, the downstream risk associated with even a single complaint is now larger.
The bill also gives the Director new discretion to refuse to investigate complaints that are frivolous, vexatious, or an abuse of process, or where there is insufficient information to substantiate the complaint. That should help focus enforcement resources on more substantive issues, but it does not reduce the underlying compliance obligation.
Uniforms: A New Restriction with a 2027 Effective Date
The second change — coming into force on January 1, 2027 — adds Ontario’s first specific employment standards rules governing uniforms. Under Bill 105:
- Employers will be prohibited from requiring employees to pay for uniforms, or for the repair or laundering of uniforms, except in limited circumstances such as loss, damage beyond normal wear and tear, or failure to return items as agreed.
- Amounts improperly charged will be enforceable as wages owing — meaning improper deductions or charge-backs can be recovered through the same mechanisms as unpaid wages.
- Transitional rules will address conflicts with existing collective agreements.
These rules align Ontario more closely with provinces that have long-standing restrictions on uniform charges (BC and several others). For sectors that rely heavily on branded uniforms — retail, hospitality, security, healthcare, transportation — the operational and financial impact may be significant. The change will require a re-examination of payroll deductions, uniform deposits, replacement policies, and any provisions in collective agreements or individual employment contracts that purport to shift uniform costs onto employees.
Why This Matters for National HR Teams
Even though Bill 105 is an Ontario statute, it illustrates two broader themes that national HR teams are increasingly facing.
First, the rules governing recruiting, monitoring, and managing employees are not just becoming more prescriptive — they are becoming more enforceable. Empowering the Director to convert complaints into inspections is a significant escalation, particularly for areas like job postings and electronic monitoring policies, where many employers have not yet fully built out compliance documentation.
Second, Ontario is continuing to occupy a leading position on workforce-related legislation. Provisions that begin in Ontario often migrate to other provinces — sometimes in modified form, sometimes more aggressively. A national employer that uses Ontario as a leading indicator of compliance pressure will rarely be caught off guard.
What HR Teams Should Do Now
- Audit your job posting practices. Confirm that all current and template job postings comply with Ontario’s expanded posting requirements (pay disclosure, AI-in-hiring disclosures, vacancy information, etc.). Build a repeatable review process so that a complaint about one posting does not cascade into an inspection that turns up problems across many others. See our post Ontario Job Postings – New Requirements Come into Force Jan. 1, 2026.
- Review your disconnecting from work and electronic monitoring policies. Make sure each is current, properly distributed, and consistent with how managers actually operate. Documentation, training, and acknowledgment records should all be in place — the same areas an inspector is likely to focus on. See our post UPDATED – Electronic Monitoring Policy Now Required in Ontario.
- Tighten your temporary help agency and recruiter arrangements. If you use external recruiters or temporary help agencies, confirm that they hold any required licensing, that contracts include compliance representations, and that your own onboarding processes do not inadvertently violate the rules that apply to these arrangements.
- Start the uniform policy review now, even though the rule does not come into force until January 1, 2027. Inventory existing uniform charges, deposit schemes, and laundering charge-backs. Identify which can continue under the limited exceptions and which need to be eliminated or restructured. For unionized workforces, factor the change into upcoming bargaining.
- Update your training and manager guidance. Front-line managers and recruiters need to understand the new enforcement environment — particularly that a single complaint can now trigger a broader inspection. Concise, role-specific updates are more effective than generic training rollouts.
Key Takeaways
- Bill 105 expands the Director of Employment Standards’ ability to convert complaints into inspections for job postings, disconnecting from work policies, electronic monitoring policies, and temporary help agency and recruiter matters.
- It also introduces Ontario’s first specific employment standards rules restricting employer charges for uniforms, repair, and laundering — coming into force January 1, 2027.
- HR teams should treat Bill 105 as a prompt to audit their job posting, monitoring, disconnecting from work, and uniform charge practices, and to update training and documentation accordingly.
- As with much of Ontario’s recent employment legislation, national employers should expect comparable changes to surface in other provinces over time.
Bill 105 is a reminder that the rules are not just expanding — they are becoming more enforceable. The organizations that fare best in this environment will be the ones that treat compliance as an operational discipline, not a one-time policy refresh.
How Compliance Works Helps You Stay Ahead of Changes
Compliance Works can help HR teams stay ahead of Bill 105 and the changes still to come. The platform tracks each amendment from introduction through Royal Assent and into force, allowing you to be proactive. Its Info Hub, Policies, and Checklists translate those legislative changes into the practical tools HR teams need to act on: ready-to-adapt disconnecting from work and electronic monitoring policies, alongside checklists that help confirm your current practices align with the new rules. Combined with jurisdiction-level filtering and reporting, that makes it possible to manage Bill 105 not as a one-time project, but as part of an ongoing Ontario compliance program.
