Ontario’s pay transparency rules took effect January 1, 2026. Compliance, while arduous for some, is straightforward. The conversations it triggers, however, are not. Some of the difficult conversations happening right now aren’t caused by new legislation. They’re caused by years of inconsistent hiring and unchecked compression. Here’s how to get it right.
Prepare Managers & Leaders
THE GOAL: NO SUPRISES
No manager should say something in an interview that HR has to walk back on Monday. Everyone who talks to employees or candidates needs to speak confidently about compensation and it must align with the organization’s overall compensation structure. HR needs to give leaders the tools to do so effectively.
Build the narrative before you train anyone. To start, HR must align internally on three things: where you target on the market (e.g., “we pay at the median of e.g. manufacturing in the GTA, for our size band”), what drives placement within a range (skill, scope, performance, tenure), and what the growth path looks like. Once that’s done, it’s time to bring in the managers.
Train for the Actual Conversations, not just the Policy
Explaining the legislation alone isn’t enough here. Create sessions where leaders can practice difficult conversations about compensation, e.g., a candidate pushing back on salary or an employee asking why a new hire is earning more. Yes, it may feel a little awkward in training, but the preparation will pay off.
Provide a Framework, not a Script
Prepare your managers with a solid framework that covers most compensation conversations, which is built around four basic moves:
- Acknowledge questions about pay openly
- Explain how your ranges are set
- Describe where the employee sits in the range and why
- Pivot to what growth looks like for that employee
Establish a clear escalation path for when it is needed. Managers need to know when to involve HR in a situation and feel comfortable doing so. Define which situations warrant it, who they go to, and how fast.
When Candidates Push Past Your Range
THE CHALLENGE: HOLDING THE LINE ON COMPRESSION
Before any postings go live, test your ranges against credible, peer-reported, regional data. Benchmarking has never been more important. Comparing your ranges against the Ontario market before postings go live is essential.
Audit placements before anything goes public. Walk through where your current employees actually sit in their ranges before those ranges become visible to candidates. Fix what you find before it snowballs. For example, you’re posting for a General Labourer: COIRI’s Ontario median for that role is $22.37 per hour. If your incumbent is at $20.22, you’re paying nearly 10% below the going rate for someone already doing the job. You have an equity problem, and transparency is shining a spotlight on it. It has to be dealt with.
Talk About More than the Number
Candidates fixate on base salary because it’s the only number on the page. Get the rest of the picture into the conversation early — benefits, flexibility, RRSP match, development, vacation, all the pieces that don’t fit on a job ad but actually shape what working for you is like.
Scale Down Exceptions
Mandate that every offer above the range must go through HR, with a written rationale. That’s the entire policy. The minute you start letting quiet workarounds slip through, the rule is gone, and new problems begin.
A small but useful move to help curb the need for some exceptions is to post your range 5–10% below where your budget actually caps out. The top of the posted range then becomes the comfortable landing spot for a strong candidate, and provides the hiring manager with some flexibility if needed.
When Employees See What New Hires Are Making
THE RISK: RETENTION
The employees who notice they’re being paid less than new hires and say nothing are usually your biggest retention risk. They’re probably looking, but doing so quietly. Make sure your managers are doing regular check-ins with top performers, and that HR has eyes on anyone who hasn’t had a meaningful compensation conversation in the last 12 months.
Be Proactive. If your posted ranges are about to reveal compression, go to the affected employees and have the conversation on your terms. Reaching out first is a completely different conversation from the one you’ll be having if they get there first.
Be honest about what’s actually going on. Nobody wants to feel misled. Say what happened, explain how, and be specific about what you’re doing about it and what the timeline is. Being vague will only make it worse.
Know the Number Before Having the Conversation
Before you sit down with a long-tenured employee, know what the market is actually paying for their role right now. Take a Health & Safety Officer in London, Ontario — COIRI data puts the current median in that region at $81,299. If your person is sitting below that, you have a reliable benchmark to build a remediation plan around. A manager who walks into that conversation backed by data is much more effective than one who walks in trying to reassure.
Build a Remediation Plan and Let People See it
Start with anyone sitting below the minimum range. Those are the urgent ones. They need off-cycle adjustments, and they need them quickly. Then map out what the rest of the cleanup will look like, even if it takes a couple of cycles. People aren’t expecting perfection — they want to know there’s a plan. They’re looking for proof that someone is taking this seriously, and that while change won’t happen overnight, it is underway.
Reinforce what Tenure and Performance are Worth
Make your framework explicitly reward both range progression tied to performance and tenure recognition in band placement, as well as long-service benefits that new hires don’t immediately access. Then make sure managers are telling that story.
The Bottom Line
Compliance is not an option, and as many have already discovered, pay transparency rewards organizations that have already done the internal equity work — and punishes those that haven’t. The employers who will fare best will treat this not as a compliance exercise, but as a mandate to finally fix what has long been put off.
The good news is that the initial pain of overhauling your compensation structure is worth it. Done right, it builds a more equitable, efficient, and trusting workplace for everyone.
Best Practice: Benchmark Before You Make Ranges Public
COIRI’s employer-reported compensation data — covering hundreds of positions across the province gives you the benchmarks you need to audit confidently. Please visit https://coiri.com/benchmark-data/ for more information or sign up for a free Clarity membership and see everything our platform has to offer: https://coiri.com/clarity-pricing/.