If you’re an employer in Ontario with 25 or more employees, your onboarding process just got an upgrade — courtesy of O. Reg. 477/24, which came into force on July 1, 2025. Think of it as the province’s way of making sure new hires don’t show up on day one wondering who you are, where they are, or when they’re getting paid.
Here’s what you need to know to stay compliant (and keep HR from pulling their hair out).
New Pre-Employment Disclosure Requirement
Under the new regulation, employers must provide written notice to all new employees — except for those hired through a temporary help agency — before their first day of work, or as soon as reasonably possible afterward.
This written notice must include:
- The employer’s legal name and any operating/business names,
- Your address, telephone number, and a contact person,
- A short description of where the employee will be working (physical, remote, or somewhere in between),
- The employee’s starting wage or commission rate,
- The applicable pay period and payday, and
- Their anticipated hours of work to start.
In short: no more vague “we’ll sort it out later” offers. Employees need to know what they’re walking into — literally and financially.
ESA Poster Still Mandatory
The ESA poster isn’t going anywhere — and yes, you still need to give it to every employee. The most recent version published by the Ministry of Labour must be provided to new hires within 30 days of their start date.
If the employee requests a version in a language other than English and it’s available, you’re required to provide that too. Google Translate doesn’t count.
Disconnecting from Work and Electronic Monitoring Policies
Employers with 25 or more employees as of January 1 of any year must also provide:
- A Disconnecting from Work Policy, and
- An Electronic Monitoring Policy (if applicable — i.e., if you’re tracking mouse clicks, keystrokes, or anything else digital).
You must give employees a copy of each policy within 30 days of preparing or updating them. New hires must also receive these policies within 30 days of their start date.
If you’ve drafted the policy but it’s been sitting in your inbox for a month, now’s the time to hit “send.”
What You Should Do Now
We recommend reviewing your onboarding documents and processes to ensure you’re meeting all ESA disclosure and policy obligations. That includes updating offer packages, scheduling poster delivery (yes, really), and tracking who’s received what.
Pro tip: a checklist or onboarding tracker goes a long way – so does letting your HR team know about this before the next hiring spree.
If you’d like help drafting a compliant pre-employment disclosure template, updating policies, or figuring out whether your onboarding system is ESA-proof, we’re here to assist.
Robin K. Mann, Associate Lawyer