Late-2025 Changes and 2026 Legislative Watchlist for HR Directors and OHS Managers 

The start of 2026 is an ideal time for Canadian organizations to step back and review whether their workplace policies still reflect current legal, regulatory, and enforcement expectations. Several important legislative changes took effect at the end of 2025, while others are coming into force or being phased in throughout 2026. Together, they signal continued emphasis on pay transparency, psychological safety, and stronger occupational health and safety systems. 

Rather than reacting to individual changes as they arise, HR directors and OHS managers can use this structured policy refresh to reduce compliance risk, improve clarity for workers, and ensure managers are applying rules consistently across jurisdictions. 

Begin with a legislative applicability check 

Before updating policies, confirm which laws apply to which parts of your workforce. This is especially important for organizations with remote workers, mobile roles, or a mix of provincially and federally regulated employees. 

Checklist: applicability and scope 

• Identify whether any employees are federally regulated (transportation, telecommunications, banking, etc.). 
• Confirm all provinces, territories, or outside of Canada where employees physically work or are based. 
• Review whether policies apply differently to office staff, field staff, drivers, lone workers, or remote workers. 
• Flag high-change areas for 2026: recruitment practices, leaves, workplace violence/harassment, and environmental or psychosocial hazards. 
• A clear scope map helps prevent policies that unintentionally conflict with local employment standards or OHS requirements. 

Recruitment, job postings, and pay transparency 

Late 2025 and early 2026 bring significant changes to how employers advertise roles and manage hiring processes, particularly in Ontario and British Columbia. These changes affect not just HR procedures, but written policies and manager guidance. 

Checklist: recruitment and hiring policies 

• Update the Recruitment and Selection Policy to reflect new job posting requirements where applicable (e.g., pay transparency obligations in Ontario as of January 1, 2026). 
• Ensure job posting templates include: 
  • Required salary or wage ranges. 
  • Any mandatory disclosure about the use of artificial intelligence in screening. 
  • Language that avoids prohibited requirements (such as “Canadian work experience” where restricted). 
• Review your Records Retention Policy to ensure hiring records (postings, screening criteria, interview notes) are retained for required periods. 
• Align your Compensation Policy with published pay ranges and internal equity practices. 

Pay transparency requirements are intended to address wage gaps and improve fairness, but they also increase scrutiny of how employers set and justify pay. Clear internal governance around pay ranges and exceptions is essential in 2026. 

Leaves, benefits, and accommodation 

Several changes affecting federally regulated employers came into force in December 2025, and provinces continue to refine leave and accommodation expectations. Even where entitlements have not changed, outdated policy language is a common compliance risk. 

Checklist: leave and accommodation 

• Review Leave of Absence Policies for federally regulated employees to ensure they reflect post-December 2025 requirements. 
• Confirm that provincially regulated leave policies are current for each province of operation. 
• Update manager guidance on: 
  • When medical documentation can be requested. 
  • How accommodation requests are assessed and documented. 
• Ensure attendance management programs explicitly recognize duty to accommodate. 

Workplace harassment and workplace violence 

Across North America, regulators continue to emphasize prevention of workplace harassment and violence, including psychological harm. Several jurisdictions have strengthened statutory requirements or enforcement practices, making this a key area for a 2026 refresh. 

Checklist: harassment and violence programs 

• Re-issue a current Workplace Harassment Policy that: 
  • Defines harassment clearly, including sexual harassment. 
  • Applies to in-person, virtual, and electronic conduct. 
  • Explains reporting options and investigation steps. 
• Review and update the Workplace Violence Policy to ensure it includes: 
  • Risk assessments for role-specific hazards. 
  • Procedures for threats, domestic violence spillover, and emergency response. 
• Confirm investigation procedures include timelines, confidentiality language, and outcome communication. 
• Schedule refresher training for workers and enhanced training for supervisors. 

Policies alone are no longer sufficient. Regulators increasingly expect evidence of implementation: risk assessments, training records, and corrective actions following incidents. 

Core OHS system updates: physical and psychological hazards 

Enforcement trends across Canada point to increasing attention on comprehensive hazard identification, including psychosocial risks and environmental conditions such as heat. 

Checklist: OHS management systems 

• Revisit workplace hazard assessments, including: 
  • Psychosocial hazards (workload, harassment, lone work). 
  • Environmental hazards (heat, cold, air quality). 
• Update Incident Reporting and Investigation Procedures to ensure: 
  • Clear reporting thresholds. 
  • Timely investigations. 
  • Documented corrective actions. 
• Review emergency response plans and first aid coverage for current work arrangements. 

Driving and mobile work 

Driving remains one of the most common and overlooked workplace hazards. A New Year refresh is an opportunity to strengthen controls before incidents occur. 

Checklist: safe driving and mobile work 

• Update your Safe Driving for Work Policy to address: 
  • Licensing and driver abstract checks. 
  • Impairment and fitness for duty. 
  • Distracted driving and mobile device use. 
  • Fatigue and severe weather. 
• Review worksite traffic management procedures where vehicles and pedestrians interact. 
• Confirm collision reporting and investigation requirements are clear. 

Province-specific legislative watch checklist  

Use this checklist to ensure local compliance beyond national or organization-wide policies. 

• Ontario 
  • January 1, 2026 job posting and pay transparency requirements reflected in recruitment policies. 
  • Workplace violence and harassment programs reviewed annually.

• British Columbia 
  • Pay Transparency Act reporting obligations planned for 2026 (for employers with 50+ employees in British Columbia). 
  • Bullying and harassment policy aligned with WorkSafeBC requirements.

• Alberta 

• • Violence and harassment policies reflect OHS Code requirements and investigation expectations. 

• Québec 

• • Policies updated to reflect psychological harassment obligations and CNESST guidance. 

• Atlantic provinces 

• • Confirm statutory harassment policy obligations (e.g., Nova Scotia) are met. 

• All provinces 
  • Employment standards references are current. 
  • Joint Health and Safety Committee or worker representative roles are clearly documented. 

U.S. legislative watchlist  

Keep as a monitoring item rather than a full policy rewrite unless you employ or recruit in the U.S. 

• Ongoing development of OSHA heat illness prevention requirements. 
• Annual January 1 state-level employment law changes affecting pay transparency, paid leave, and postings. 
• Continued state-specific regulation of AI use in hiring.