2026 Executive Outlook | Abraham Baboujian, KRGinsure

Next year promises new challenges and complications for staffing within the property and casualty (P&C) insurance industry.

Under 2024’s Working for Workers Four Act (Bill 149), Ontario is in the process of implementing its Pay Transparency Act, which takes effect Jan. 1, 2026. The immediate impact of these new rules will be the need for updated processes and procedures, transparency, audits and internal dialogues about compensation structures. It’s a necessary and welcome exercise to combat complacency in the human resources (HR) world.

The new rules apply to companies with 25 or more employees. They reflect the inherent societal expectations around diversity and fair compensation practices. As such, they’re a beneficial consequence of our evolving corporate responsibility mandates.

At their core, the new rules involve mandatory disclosures under all public job postings, including but not limited to:

• Specific pay rates or pay ranges no wider than $50,000 for job postings (except for postings where top-end pay exceeds $200,000). Employers must disclose the full scope of compensation
• Clear indications about whether a posting is for a new position or to fill a vacancy
• Disclosure about whether artificial intelligence will be used during the hiring process (i.e., for screening, assessing or selecting applicants)
• Removal of Canadian experience requirements in postings
• A 45-day limit for follow-up after the last interview
• Requirements that employers keep records of postings, application forms used, and communications related to interviews and follow-ups for three years.

Insurance providers and others in the P&C industry will need to adopt more focused and purpose-driven hiring and compensation models to comply with the new rules. And they will need to take more uniform and consistent approaches to hiring practices.

Job posting templates will need to be updated to avoid negative consequences regarding compensation structures that firms currently use. For example, current employees will be able to review parameters of a ‘new’ job postings and compare them to the particulars of their own positions.

The newly articulated obligations under the Ontario Employment Standards Act will be significant, and non-compliance could lead to reputational harm and legal ramifications.

HR departments will also need to implement and undergo compliance training, update employee handbooks, and raise awareness about the rule changes with front-line managers and across the ranks.

The new law’s immediate impact will be on HR departments, but it will also affect front-line managers, company leaders and executives. Training and awareness will be crucial, and so will amendments