On April 20, 2026, Ontario introduced its latest omnibus legislation amending various employment related legislation: Bill 105, Protecting Ontario’s Workers and Economic Resilience Act, 2026.1 As of May 4, 2026, Bill 105 is in the Second Reading stage and has been referred to the Standing Committee on Finance and Economic Affairs. If passed, Bill 105 will implement a number of changes including to the Employment Standards Act, 2000 (the “ESA“)2 and the Occupational Health and Safety Act (the “OHSA“)3, and enact new legislation applicable to talent agencies and entertainment industry workers.
Proposed Changes to the ESA
Bill 105 would introduce a new section to the ESA which would prohibit employers from requiring employees to pay for uniforms or other prescribed items, or for the repair or laundering of such items, except in limited circumstances. It would also allow employees to pursue recovery of uniform related charges as wages owing under the ESA. If passed, these proposed changes would come into force on January 1, 2027.
Bill 105 would also introduce some changes to complaints under the ESA, allowing the Director to assign certain complaints for inspection and to refuse to assign complaints for investigation or inspection in specified circumstances, including where it is clear the complaint is frivolous, vexatious or an abuse of process, or where there is insufficient information to substantiate the complaint. This would be a substantial change to the current system, where all complaints under the ESA must be investigated by the Ministry of Labour.
Finally, Bill 105 introduces changes to the rules for apportioning money collected in enforcement matters, ensuring that employees are paid first, with any remaining amounts divided among the collector, the Director and the Minister of Finance.
Proposed Changes to the OHSA
There are a number of proposed changes to the OHSA, including allowing the Chief Prevention Officer to collect personal information about workers’ exposure to a physical, chemical or biological agent for the purpose of maintaining a worker occupational exposure registry. It would also authorize the Ministry of Labour to reimburse prescribed employers and constructors for the cost of purchasing protective headwear.
One of the key proposed amendments would allow the Ministry of Labour to recognize standards for training, personal protective equipment or other equipment that comply with requirements in another Canadian jurisdiction or the requirements under an agreement between Ontario and another Canadian jurisdiction as satisfying the OHSA requirements. This is intended to improve worker training portability and reduce duplicative training costs for businesses with employees across multiple jurisdictions in Canada.
New Legislation: the Strengthening Talent Agency Regulation Act, 2026 (the “STAR Act”)
Bill 105 introduces the Star Act, a new employment standards statute that would apply to talent agencies and workers in the entertainment industry. The STAR Act would introduce standards that talent agencies would be required to comply with in order to ensure greater protection for workers, including:
- establishing maximum commission rates that can be charged by talent agencies;
- prohibiting talent agencies from charging fees other than commissions and certain fees permitted by regulation;
- requiring payments to entertainment workers within set timelines;
- requiring that talent agencies maintain separate accounts for money belonging to entertainment workers; and
- requiring talent agencies to provide entertainment workers with written statements regarding commission fees owing and retain records in regards to same.
If the STAR Act comes into force, it will also provide entertainment workers with access to complaint and enforcement mechanisms, including allowing them to seek repayment of fees improperly charged by talent agencies.
Changes to other legislation
Bill 105 proposes changes to a number of other pieces of legislation, including the Environmental Assessment Act, the Labour Relations Act, 1995, the Ministry of Health and Long-term Care Act, the Ombudsman Act, the Retirement Homes Act, 2010, and the Workplace Safety and Insurance Act, 1997.
Key Takeaways
Bill 105 has not yet been passed into law, and may be amended as it moves through the Legislative Assembly. We will continue to monitor this legislation and provide further updates as things develop.
Endnotes
- Ontario. Legislative Assembly. Protecting Ontario’s Workers and Economic Resilience Act, 2026. Bill 105, 1st Session, 44th Parliament. First Reading: April 20, 2026. https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-105#BK10.
- Employment Standards Code, RSA 2000, c E-9, <https://canlii.ca/t/56mck> retrieved on 2026-05-12
- Occupational Health and Safety Act, RSO 1990, c O.1, <https://canlii.ca/t/56mbn> retrieved on 2026-05-12
