Everyone’s hyped about Ontario’s new pay transparency rules.
They think it’s a reset. It’s not.
The Law: New Theatre, Old Problems
Starting January 2026, Ontario’s Working for Workers Four Act, 2024 requires companies with 25+ employees to list pay ranges (max $50K spread for jobs under $200K), disclose AI use in screening, ban “Canadian experience” requirements, clarify if a job is current or future, update all interviewed candidates within 45 days, and keep three years of recruitment records. It sounds major. In reality, most of the market won’t feel a thing.
Reality Check: Who Actually Hires?
Nearly 90% of Ontario businesses have fewer than 25 employees. These firms are not included in the compliance conversation. Yet, medium and large employers (100–499 and 500+ employees) account for about 70% of Ontario’s workforce. They ghost less – not out of virtue, but because they have HR infrastructure and visibility. Compliance and risk matter when you’re big.
Micro and small businesses, the under-25 crowd, are the biggest sources of candidate ghosting. Not from malice, but from chaos: owners juggle everything, hiring is informal, and nobody’s following up. Ghosting stems from lack of process, not intent. When these firms cross the 24-employee mark, they’re suddenly expected to comply, often with no HR infrastructure – a nightmare.
Who Posts Ghost Jobs in Canada?
A 2025 Jobs.ca study shows that micro and small businesses with under 25 employees are responsible for an estimated 40–45% of ghost jobs. Recruitment agencies follow closely, with about 30–40% of their postings being ghost jobs. Recruitment firms must follow the new law only if their client organization must comply, and there’s no obligation to identify the client in their posting.
Medium-sized firms clock in at 25–30% for ghost postings, mainly due to informal practices and limited HR bandwidth. Large companies post ghost jobs least often, at about 15–20%, thanks to formal processes and compliance pressure.
The Working for Workers Four Act does not address the largest offenders, leaving much of the ghost job activity unregulated.
The Unrest Will Grow
Layer on layoffs, technological disruption, inflation, and rising unemployment, and frustrated candidates won’t just call ESA hotlines; they’ll blast non-compliance on LinkedIn, Reddit, and review sites for all to see.
This isn’t just about compliance; it’s about trust. When candidates are left in the dark, they lose faith in the entire hiring ecosystem. The law’s focus on large employers may calm the surface, but it doesn’t fix the root cause: a lack of accountability and process across the board.
What’s Next?
The new laws are a step in the right direction, but it’s not the fix we’re all hoping for. Ontario’s new rules shake up hiring for those who must comply – 2% of Ontario businesses. Pay ranges and anti-ghosting rules serve as the opening act. If all employers and recruiters, regardless of size, don’t meet the same standard, nothing changes. The real fix requires that every job post has the name of the actual employer and that every candidate gets closure. Anything less means the work is not done.
Until then, the hiring landscape will remain a patchwork of compliance and chaos, with the biggest offenders operating in the shadows.