Ontario's January 2026 OHSA Changes: An Employer Compliance Guide

An inspector can now impose a penalty directly. No charge, no court date, and the Ministry can publish your name.

What actually changed on January 1, 2026?

The changes flow from the Working for Workers Seven Act, 2025, which received Royal Assent on November 27, 2025. Several regulations under the Occupational Health and Safety Act then came into force on January 1, 2026.

If you only remember the headlines, remember these five:

• Administrative monetary penalties (O. Reg. 365/25): inspectors can issue fines outside the court system.
• Procurement equivalency (O. Reg. 364/25): public buyers must treat accredited safety management systems as equal.
• On-site AEDs (O. Reg. 157/25): defibrillators are now mandatory on larger construction projects.
• WSIB AED reimbursement (O. Reg. 360/25): up to $2,500 back per unit.
• Washroom-cleaning records (O. Reg. 480/24): construction projects must log cleanings.

The first two are the ones with teeth for every employer, not just construction. Start there.

Inspectors can now fine you without going to court

Administrative monetary penalties are the single biggest shift. Under Ontario Regulation 365/25, an inspector who finds a contravention can impose a financial penalty directly, instead of routing the matter through a Provincial Offences Act prosecution. The notice has to be issued within one year of the day the inspector learned of the contravention.

Two details change the calculus for employers. First, paying an AMP closes the door on a prosecution for that same contravention, so the government gets a faster, cheaper enforcement tool and you lose the long runway a court process used to give you. Second, the Ministry can publish the name of anyone penalized, the nature of the contravention, and the amount, including online. For a contractor who lives on its reputation in tender rooms, that publicity can sting more than the cheque.

Here is the nuance the headlines miss. Right now there is only one penalty amount actually prescribed in the regulation, and it attaches to breaches of O. Reg. 364/25 (the procurement rule below), set at the lesser of $100,000 or 10% of the contract value. The framework, though, is built to grow. The infrastructure for province-wide AMPs is in place, and the list of prescribed contraventions can expand without new legislation.

Your COR or ISO 45001 now has to be accepted on public bids

Ontario Regulation 364/25 settles a fight that has frustrated contractors for two years. Government and broader public-sector organizations now have to treat all accredited occupational health and safety management systems as equivalent when they buy. A public buyer cannot insist on one specific system and shut out a bidder who holds another.

The backstory matters, because the rumour mill got this one wrong. In 2024, IHSA announced it would stop recognizing ISO 45001 as equivalent to COR 2020. After a loud industry response, the provincial government reversed course and directed that the equivalency continue. The new regulation goes further and writes that equivalency into law for public procurement.

So if you hold COR 2020 or ISO 45001, a public-sector client can no longer demand the other certificate as a condition of bidding. One accredited system is enough. We have already seen clients drop plans to chase a second, duplicate certification they were only pursuing to satisfy a single prequalification form.

Do you need an AED on your site?

For construction, the answer is a flat yes once you cross two thresholds. Ontario Regulation 157/25 requires an automated external defibrillator on any project expected to run three or more months with 20 or more workers regularly employed. The AED has to be stored with a small kit (scissors, gloves, absorbent towels, a razor, and spare pads), and a worker trained in CPR and AED use must be on site whenever work is in progress.

There is money on the table to offset it. Under O. Reg. 360/25, WSIB will reimburse up to $2,500 per defibrillator bought between July 1, 2025 and June 30, 2027, with claims due by July 31, 2027 and one reimbursed unit per qualifying project. Keep the receipt and proof the project met the thresholds.

We covered the equipment, training, and reimbursement mechanics in depth in our guide to Ontario's AED requirements for construction sites. If a project of yours is near the 20-worker line, read that next.

The smaller changes that still trip employers up

A few quieter items round out the package. None is dramatic on its own, but each is an easy AMP target once the penalty list grows.

Washroom-cleaning records. Under O. Reg. 480/24, construction employers have to keep a cleaning record for each washroom showing the date and time of the two most recent cleanings. It is a paperwork item, and paperwork items are exactly what inspectors check first.

WSIB premiums dropped. The average 2026 premium rate fell to $1.23 per $100 of insurable payroll, down from $1.25. Small, but a reminder that a clean claims record pays for itself.

Naloxone is not new, and it is still missed. Since June 1, 2023, employers who are aware, or ought reasonably to be aware, of a risk that one of their workers could overdose on opioids at work must provide a naloxone kit and train staff to use it. Plenty of Ontario workplaces still have not done the risk assessment. If you have not, do it, and write down your conclusion either way.

What's coming next in 2026 and 2027

January was not the end of it. A second wave of changes is already scheduled, and the smart move is to budget for it now.

From July 1, 2026, Ontario will accept CSA-compliant respirators and particulate filters alongside the NIOSH-certified devices its regulations have required until now. This widens your purchasing options rather than narrowing them. It does not touch the fit-testing rules, which still require a fit test before first use and at least every two years. Further changes to head protection (moving toward CSA-standard hard hats) and elevated work platform training are working their way through the system for 2026 and 2027.

If you buy PPE in bulk, review your specifications before the next purchase order rather than after.

What's not the law yet (so you don't overreact)

Two topics get talked about as if they are already binding. They are not, and reacting as though they are wastes money.

A proposed heat stress bill has been introduced at Queen's Park, but it has not passed and is not in force. Ontario still has no standalone maximum-temperature regulation. That does not mean heat is unregulated; you must control it as a hazard under the OHSA's general duty clause, with water, rest, shade, and acclimatization. It just means there is no specific number to comply with yet.

The CSA Z1003 psychological health and safety standard is likewise voluntary. It is a strong framework, and we recommend it, but it is not a legal requirement in Ontario. Build toward it because it works, not because an inspector will cite you for skipping it.

The risk is not the rules you know about. It is the paperwork item you assumed didn't apply to you.

Where to start this week

You do not need to overhaul your program. You need to know which of these obligations apply to your workplace and confirm you can prove each one. Most of our clients find a couple of gaps in an afternoon: a washroom log nobody is keeping, a naloxone assessment never written down, a COR certificate that lapsed last quarter.

Walk your own site against the checklist below. If you finish and you are not certain where you stand on the AMP exposure or the procurement rule, that is the conversation worth having before an inspector has it for you.