Ontario HR Managers: Is anyone actually worried about Bill 149 compliance? [Canada]
HR | Ontario, Canada
Bill 149 has been in force for a few months now and I'm genuinely struggling to find anyone who seems particularly worried about it. The pay transparency requirements seem straightforward enough on paper, but a few things are nagging at me that I don't hear people talking about much.
For the record-keeping requirement, most employers I'm aware of are saving internal drafts of job postings, but not necessarily preserving copies of postings exactly as they appeared publicly at the time they were live. How are people approaching this issue? Do people feel confident that if Ministry of Labour asked you for a complete record of every posting you've published in the last 12 months — exactly as it appeared publicly — that you could produce it for them?
I've also read that ESA complaints about job postings can be filed by anyone who sees the posting — not just people who actually applied. There's been discussion in employment law circles about job seekers systematically reviewing public postings for Bill 149 violations as a deliberate activity, and Reddit alone has quite a few threads of people actively flagging non-compliant postings.
Penalties can range from a $250 NOC for a first offence up to costs that add up quickly if legal representation gets involved. Has anyone else discussed these things as a concern, or does it feel like not a big deal?
Maybe I'm overthinking this and it's easily handled. Genuinely curious what the on-the-ground reality looks like for everyone.