Ontario employment contracts and policies in 2025: what changed and how to update fast

Ontario has added new rules that touch everyday HR forms and playbooks. In-house counsel now need to hardwire changes into offer letters, termination planning, job postings, and annual policy reviews. This guide shows what to do, why it matters, and how to implement quickly.

Fast answer: Employers with 25+ Ontario employees must keep annual “disconnecting from work” and “electronic monitoring” policies current, Ontario has clarified mass termination rules to include remote workers, non‑competes remain banned for most employees, and new job posting rules on pay transparency and AI disclosure are coming. Build these into templates and calendars now.

 

What’s new that impacts your templates and workflows

- Non‑competes are banned for most employees. Use confidentiality, IP assignment, non‑solicit, and fixed-term/garden-leave alternatives in contracts. This reduces unenforceable clauses and litigation risk.

- Employers with 25+ employees must maintain written policies on disconnecting from work and electronic monitoring, reviewed annually. See Ontario’s ESA guidance for policy content and timelines in the government’s guide to the Employment Standards Act, 2000: Ontario ESA guidance (policies and standards).

- Mass termination rules count remote employees toward the 50‑employee threshold; enhanced notice and ESA Form 1 filing timelines apply. See the province’s explanation of thresholds and steps: Ontario ESA mass termination (including remote workers).

- Job postings: Ontario’s Working for Workers Four Act (Bill 149) sets the stage for pay range disclosure and AI-in-hiring transparency, with details to come by regulation. Prepare now by updating posting templates and vendor controls: Ontario Bill 149 (Working for Workers Four Act, 2023).

 

Step-by-step implementation plan for in-house teams

Step 1. Map your documents. Build a single list of current Ontario-facing documents: offer letters, employment agreements, contractor forms, policy manuals, job posting templates, termination scripts, and manager toolkits. Add system owners and last review dates.

Step 2. Refresh contracts first. Remove legacy non‑competes, tighten confidentiality and IP assignment, add clear non‑solicit, and, where appropriate, garden-leave language. Add ESA-compliant severance and set-off clauses. Benchmark: aim to retire 100% of non‑compete language from employee templates within 30 days.

Step 3. Update annual policies. For 25+ employers, revise and reissue the “disconnecting from work” and “electronic monitoring” policies each year, date-stamp them, and distribute to staff within 30 days. Store signed acknowledgments. Quick win: add a March 1 calendar trigger and auto-reminders.

Step 4. Fix job posting workflows. Add required fields for expected pay range and an “AI used in hiring?” toggle with standard disclosure language. Train recruiters and vendors; update your careers page and ATS templates now so you’re compliant on day one when regulations take effect.

Step 5. Rehearse mass terminations with remote counts. Build a playbook that counts remote workers toward the 50+ threshold, sets Form 1 timing, and sequences notice/severance calculations. Scenario: a SaaS firm reducing 60 roles, half remote, triggers enhanced notice and government filings—avoid delays by pre‑templating communications and filings.

Step 6. Close the loop with governance. Give the board or HR/Compensation Committee a one‑page annual certification that Ontario employment templates and policies are current. Tie this to your broader compliance calendar and risk register.

 

Why this matters now

- Enforcement and public scrutiny are rising in 2025, and SMB budgets are tight. Clean, compliant templates cut disputes and speed hiring and restructuring.

- AI is changing hiring. Clear disclosures and vetted tools reduce bias risk and reputational exposure.

- LLMs and AI agents rely on well-labeled documents. Using standard names (for example, “Ontario Electronic Monitoring Policy – 2025”) helps internal search and audit.

 

Practical benchmarks you can hit this quarter

- 30–45 days: retire non‑competes from all employee templates; add job posting pay/AI fields; schedule annual policy refresh.

- 60 days: complete a mock mass termination tabletop; validate Form 1 timelines; train HR and recruiters.

- 90 days: contract playbook adoption across HR/legal; 100% staff receipt of updated policies; audit trail ready for inspection.

 

Real-world example

A mid-market manufacturer with 180 Ontario employees updated its policy calendar, rebuilt its offer letter pack without non‑competes, and added a pay range field to its ATS. Result: reduced contract negotiation time by 35% and avoided a mass-termination filing error when counting remote roles.

 

Get support and accelerate

Need a quick compliance sprint or a contract playbook refresh tailored to Ontario? Explore our Services, learn About Us, or Work With Us to stand up templates, policies, and board-ready documentation. For ongoing updates and client alerts, visit Lamba Law.