In June 2026, 71 per cent of job postings in Ontario carried pay information. Six months earlier, just before the province's new posting rules took effect, the figure was 49 per cent. Across the Atlantic, all 27 EU member states were supposed to have a pay transparency law in place by June 7. Four met the deadline. By late September, five had fully finished the job.
Two jurisdictions, one direction of travel, very different speeds. For employers hiring in more than one market, which describes a growing share of Canadian companies, the result is a patchwork: rules that resemble each other in principle and diverge on the details that matter, such as how wide a salary range can be, who must be told what, and by when. This piece looks at what Ontario's first ten months have shown, where Europe stands, and what the combination means for hiring teams.
What Ontario's job posting rules require
Since January 1, 2026, Ontario employers with 25 or more employees have had to meet a defined set of requirements whenever they advertise a role publicly. The rules sit in the Employment Standards Act, 2000 and Ontario Regulation 476/24, and they reach well beyond pay, according to Osler's summary of the legislation:
Pay
the expected annual compensation, or a range that does not exceed $50,000. A range of $80,000 to $120,000 is permitted; $60,000 to $120,000 is not. Roles expected to pay more than $200,000, including those where the top of the range passes $200,000, are exempt.
Vacancy
a statement on whether the posting is for an existing vacancy.
AI
disclosure if artificial intelligence is used to screen, assess or select applicants.
Canadian experience
no Canadian-experience requirements in postings or application forms.
Follow-up and records
candidates who were interviewed must be told within 45 days of their last interview whether a hiring decision has been made, and employers must keep postings and application forms for three years after a posting comes down.
Pay disclosure draws most of the attention, but the other items matter as much to how hiring actually runs. Together they make parts of the process visible that used to stay inside the company: whether the job is real, whether software is sorting the applicants, and whether anyone will hear back.
Ten months in: disclosure rose, precision did not
Indeed's Pay Transparency Tracker, reported by Canadian HR Reporter in July, gives the clearest read so far. Across Canada, 57 per cent of postings included pay information as of June 2026, up from roughly one in five six years ago. The recent gains came almost entirely from Ontario. Outside Ontario and British Columbia, which introduced its own requirements in November 2023, only 41 per cent of postings included pay, a figure that has barely moved in three years.
That last number carries the main lesson. Voluntary change has been slow, and legislated change has been fast. The occupations that started furthest behind moved most: human resources postings went from 30 per cent to 70 per cent with pay information, mechanical engineering rose 43 percentage points, and civil engineering 46. Higher-paying work moved least. Postings for physicians and surgeons slipped by a point, which fits an exemption that removes roles above $200,000 from the requirement.
More postings now show a number, though not necessarily a precise one. Of Ontario postings that include pay, only 16 per cent quote an exact figure; the rest give a range. The median range has also widened, from about 16 per cent in the first half of 2025 to 18 per cent in the first half of 2026. In dollar terms, that is the difference between a posted band of $100,000 to $116,000 and one of $100,000 to $118,000. Indeed's analysis suggests that employers who were reluctant to disclose before the law tend to be somewhat less precise now that they must.
Canada's overall position has improved as a result. At 57 per cent, it now sits ahead of the United States, where 49 per cent of postings carry pay information, and trails only Japan (97 per cent) and the United Kingdom (58 per cent) among the 11 advanced economies Indeed tracks.
Europe's deadline arrived, and most of Europe did not
The EU Pay Transparency Directive (2023/970) gave member states until June 7, 2026 to write it into national law. For hiring, it requires employers to give candidates the starting pay or pay range before the interview, and it bars questions about a candidate's pay history. It also introduces pay gap reporting, with the first reports from the largest employers, covering 2026 pay data, due in 2027.
Five states fully transposed
The European Commission confirmed in December 2025 that it would not extend the deadline. Even so, according to the status table Lockton published on September 25, only five of the 27 states had fully transposed the Directive as of September 23: Greece, Italy, Lithuania, Malta and Slovakia.
Implementation remains uneven
Greece's law took effect on July 6, though most employer obligations there begin on November 1. Lithuania's pay reporting requirements start on January 1, 2027. Estonia and Poland have transposed parts, mainly the pre-employment provisions. Czechia, Denmark, Finland and the Netherlands are aiming for January 1, 2027. Sweden announced in March that it was seeking to postpone implementation and renegotiate the Directive, and in Germany a draft law has been prepared but not yet published.
Employers should be careful about treating that unevenness as breathing room. Law firms advising multinationals have pointed out that a missed transposition deadline does not mean the Directive is without effect, and that some provisions may be relied on directly in national courts. For a Canadian company hiring in Europe, or with European staff, the sensible assumption is that the direction is fixed even where the dates are not.
The readiness gap
The more telling figures concern preparation rather than legislation. Mercer's Global Pay Transparency Survey, which gathered responses from more than 1,600 multinational organizations across 60 markets in autumn 2025, found that 77 per cent were developing or had developed a pay transparency strategy, but only 14 per cent had fully implemented one. In Europe the figure was 9 per cent. Mercer's respondents expected the share of employers disclosing hiring pay ranges to climb from 60 per cent in 2024 to 94 per cent by the end of 2026, and 63 per cent agreed that candidates expect transparency even more than current employees do.
Posting a number is the easy part of this work. Defending it is harder. A published range invites comparison with the people already on the payroll, and any gap between what a new hire is offered and what a long-serving colleague earns becomes easier to see. With employers planning merit budgets of roughly 3.0 to 3.1 per cent for 2027, according to Mercer Canada and Normandin Beaudry, essentially unchanged from this year, there is little room to close such a gap through raises alone. That puts weight on getting job levels, ranges and starting-pay guidelines right before the posting goes live.
What this changes for hiring teams
A few practical shifts follow from the evidence.
Range design becomes a hiring decision rather than an administrative one.
A band close to the $50,000 Ontario limit will satisfy the law and tell a candidate very little. A narrow band that the business cannot honour creates a different problem. The employers likely to benefit most are those that settle, before the posting goes out, where in the range a given candidate is likely to land and why.
Recruiters need to explain the range.
For recruiters, including those at SRA Group, the posted range now frames the first conversation with a candidate. That raises the value of explaining what sits inside it: which experience moves an offer toward the top, what the role pays in the market, and how the company weighs the two. Recruiters who can add market context to the number are doing something a posting cannot.
Cross-border hiring needs a common standard rather than a local patch.
Ontario's AI disclosure and 45-day follow-up rules, Europe's pre-interview pay requirement and country-specific timelines do not line up neatly. Organizations hiring in several places are generally better served by building one posting and process standard that meets the strictest applicable rule, then adjusting for local differences, than by maintaining a separate template for every jurisdiction.
Finally, the records matter.
Ontario requires three years of retained postings and applications, and the AI disclosure invites scrutiny of how screening tools are actually used. Hiring teams that document their process now will find audits and candidate questions much easier to handle later.
The bigger picture
Pay transparency has moved from a policy debate to a working feature of hiring. Ontario shows how quickly postings change once a law sets a date: twenty-two points in six months. Europe shows how difficult it is to move 27 legal systems together, and the 41 per cent figure outside Ontario and British Columbia suggests that, without a mandate, little shifts on its own.