For years, going silent on someone you interviewed carried no consequence beyond a bad review on Glassdoor. In Ontario that changed. Ghosting job applicants in Ontario is now regulated under the Employment Standards Act, and the rule has been in force since 1 January 2026.
If you run hiring for a business with 25 or more employees in the province, this is not a future obligation to plan for. It applies to every publicly advertised job posting you have run this year.
What the 45 day rule actually requires
The core obligation is short. When you interview someone for a publicly advertised job posting, you have to tell them whether a hiring decision has been made for that posting. You have 45 days from the date of their last interview.
A few details matter more than the headline. According to the Ontario government’s guide to the requirements, you can deliver that information in person, in writing, or using technology. Where a candidate sits through several interviews less than 45 days apart, you only have to inform them once, counting from the last one. Where the interviews are more than 45 days apart, each one starts its own clock.
You also have to keep a copy of what you sent, for 3 years after the day you sent it. That applies no matter how you delivered it, including a phone call.
Note what the rule does not cover. It says nothing about applicants you never interviewed, and it does not require you to explain your decision. Telling 40 rejected candidates that the role has been filled satisfies it.
The other 5 obligations in the same package
The notification rule arrived alongside 5 others, and they all apply to the same postings. Missing any one of them is a separate exposure on every live ad.
Pay transparency
Every publicly advertised posting has to state the expected compensation or a range. The range cannot span more than $50,000. The requirement does not apply where the pay, or the top of the range, is above $200,000 a year.
Disclosing use of AI
If you use artificial intelligence to screen, assess or select applicants, the posting has to say so. The definition in the Act is broad. It covers systems that generate predictions, recommendations or decisions influencing an outcome. That reaches a lot of resume screening tools nobody internally describes as AI.
Stating whether the vacancy is real
Each posting has to say whether it is for an existing vacancy. Pipeline building ads are not banned, but they can no longer look identical to a live opening.
No Canadian experience requirement
You cannot require Canadian experience, or any equivalent, in a posting or on an application form. Asking about relevant skills and experience in general is still fine.
Keeping records for 3 years
You have to retain a copy of every publicly advertised posting and any associated application form for 3 years after the posting comes down, alongside the notifications described above.
Who this applies to
The rule on ghosting job applicants in Ontario does not reach every employer. The threshold is 25 or more employees in the province on the day the posting is made. That is measured per posting, not annually, so a business sitting near the line can be covered for some ads and not others.
The scope is external postings advertised to the general public, with certain prescribed exceptions. Internal postings and some other categories fall outside it.
What failing to comply costs
Ghosting job applicants in Ontario is not a standalone offence with its own penalty. These requirements sit inside the ESA, so they are enforced like any other employment standard, through complaints and inspections.
The penalty ceiling also moved recently. The maximum fine for an individual convicted of contravening the ESA doubled from $50,000 to $100,000. Separately, a third or subsequent contravention within a 3 year period can draw a penalty of up to $5,000, multiplied by the number of affected people.
The practical risk for a high volume employer is not one large fine. It is that each non compliant posting counts on its own, so a chain running 30 open roles across locations is carrying 30 instances of the same mistake.
Why ghosting job applicants in Ontario happens at volume
Almost nobody ghosts a candidate on purpose. It happens because the notification step has no owner and no deadline that anyone feels.
Picture a regional manager filling 12 front line roles. They interview 60 people, hire 12, and move on to next month’s target. The 48 who did not get an offer are not a task in anyone’s queue. There is no ticket, no reminder, and no consequence until now. Meanwhile the same manager is already short on interview capacity, so the administrative tail of hiring is the first thing that slides.
That is why the 45 day rule is harder for high volume employers than the pay transparency one. Publishing a salary range is a change you make once to a template. Notifying every interviewed applicant is a task that recurs dozens of times a month and scales with your hiring, forever.
It also explains why the exposure grows quietly. A team hiring 3 people a quarter will remember. A team hiring 40 a month will not, and the gap widens exactly when hiring volume outgrows the team.
How to close the gap
Three things get most employers compliant without new headcount.
Make the notification part of closing a role, not a separate task. A req is not finished when the offer is accepted. It is finished when everyone interviewed has been told. Moving that into the definition of done is the single highest leverage change, because it removes the need for anyone to remember.
Write the message once. The rule asks you to state whether a decision has been made. It does not ask for feedback or reasons. A short standard template, sent from one place, covers it and removes the hesitation that makes people delay.
Log it as you send it. The 3 year retention requirement is the part most teams discover late. Storing the notification at the moment you send it costs nothing. Reconstructing 8 months of them during an inspection is a different exercise.
How Workwolf® handles this stage
Workwolf® runs the hiring process on your behalf, which means candidate communication sits with us rather than with your managers. Every applicant who reaches an interview is tracked through to an outcome, and the notification goes out as part of closing the role.
That matters for compliance because the failure mode here is never a policy decision. It is a busy month. When the step belongs to a process that runs outside your team, a short staffed location does not change whether it happens.
The same discipline is worth having even if you operate outside Ontario. The legal obligation stops at the provincial border, but the reasons ghosting damages hiring do not.
What to do this week
Start with a count. Pull every publicly advertised posting you have run in Ontario since January. Check 3 things on each: does it show a compensation range, does it state whether the vacancy is real, and does it disclose AI screening if you use it.
Then pick your busiest role and ask who told the last 20 interviewed candidates that a decision had been made. If the answer is nobody in particular, that is where ghosting job applicants in Ontario turns from a habit into a compliance gap. It also repeats every month.
If the volume is the reason the step keeps slipping, that is worth a conversation. Book a call with our team and we will look at where your process stands today.
This article describes the requirements in general terms and is not legal advice. Confirm how they apply to your business with an employment lawyer.
