Who Is Exempt from Ontario’s Pay Transparency Rules? The Exceptions Explained.
Not every employer and not every posting is covered by Ontario’s 2026 job posting requirements. Understanding the exemptions is important — but so is understanding how narrow they are.
“If your workforce fluctuates around 25, do not guess. Count carefully on the day each posting goes live.”
The 25-employee threshold
The rules apply to employers with 25 or more employees on the day the publicly advertised job posting is posted. The count includes full-time, part-time, casual, probationary, and temporary employees. It includes employees on leave, on layoff, or on strike. It includes homeworkers and officers of a corporation who perform work for wages.
It is the individual number of employees that counts, not full-time equivalents. An employer with 20 part-time employees and 5 full-time employees has 25 employees and is covered.
For employers with multiple locations, all employees at all Ontario locations are counted together. If your three locations each have 12 employees, you employ 36 employees and the rules apply — even though no single location reaches 25.
The compensation exemption
The salary range requirement does not apply if the expected compensation for the position exceeds $200,000 per year, or if the top of the compensation range exceeds $200,000 per year. For example, a posting for a role with expected compensation of $210,000, or a range of $170,000 to $210,000, is exempt from the pay disclosure requirement.
What is always exempt
- Internal job postings restricted to existing employees only
- General recruitment campaigns that do not advertise a specific position
- Postings for roles to be performed entirely outside Ontario
- The Crown, Crown agencies, and their employees
The bottom line for employers near the threshold
If your workforce fluctuates around 25, do not guess. Count carefully on the day each posting goes live. If you are below the threshold, document it. If you are above, comply.
BeazAtWork checks compliance for every covered employer. Run your posting before it goes live.
