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Electronic CommunicationsCanadaEN

Ontario Workplace Safety: Regulating Electronic Communications and Digital Notice

Ontario's Bill 190 sets explicit standards for electronic communications in workplace safety, governing virtual harassment and establishing rules for electronic posting of safety policies.

October 29, 2026 · 681 words
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Editorial hold — human review pending.

Country: Canada. Research snapshot: 2026-10-20. Source / development date: 2024-10-28.

Unresolved verification flags

Ontario-specific amendments. Verify commencement and the current OHSA; do not turn the express inclusion of virtual harassment into an unsupported duty to assess all harassment risks.

Resolve these limitations and the article-specific legal checklist before approval. This draft is educational information, not legal advice.

In Canada, the Working for Workers Five Act, 2024 received Royal Assent on October 28, 2024. As of the research snapshot date of October 20, 2026, organizations under Ontario jurisdiction must align their communications infrastructure with provincial occupational health and safety legislation.

The Dual Role of Electronic Communications under Bill 190

The Working for Workers Five Act, 2024 (Bill 190) addresses electronic communications across two distinct fronts under Schedule 4: the prohibition of digital harassment and the authorization of electronic compliance notices [source: launch-source-21].

First, the legislation recognizes that electronic communications can serve as a conduit for harm. Section 1(2) and section 1(3) of Schedule 4 expand the statutory definitions of "workplace harassment" and "workplace sexual harassment" under subsection 1(1) of the Occupational Health and Safety Act (OHSA) to include conduct occurring "virtually through the use of information and communications technology" [source: launch-source-21]. This statutory phrasing directly links workplace digital communications—such as enterprise messaging, internal email, and collaborative software—to statutory safety enforcement.

Second, the statute establishes a formal legal mechanism for employers to deliver mandatory information electronically. Under section 1(5) of Schedule 4, the OHSA is amended by adding subsection 1(5), defining "Electronic posting" [source: launch-source-21]. Information qualifies as posted in a readily accessible electronic format only if:

  1. The employer provides workers with direction on where and how to access the information [source: launch-source-21].
  2. The information is posted in an electronic format that can be readily accessed by workers in the workplace [source: launch-source-21].

Sections 3, 4, 6, 8, and 9 of Schedule 4 permit the posting of Joint Health and Safety Committee names, annual summaries, the OHSA text, occupational health and safety policies, and harassment policies in this electronic format [source: launch-source-21].

Modernizing Information Dissemination and Prevention

Prior to these amendments, organizations often maintained physical bulletin boards that were inaccessible to teleworkers and mobile field staff. The new statutory framework allows digital dissemination while imposing clear standards for accessibility [source: launch-source-21].

By establishing that employers must actively direct workers to electronic resources, the legislature prevented passive storage in obscure network directories. Concurrently, recognizing virtual harassment under the same legislative enactment highlights the responsibility of organizations to maintain digital communication channels that are free from intimidating, offensive, or discriminatory conduct [source: launch-source-21].

Governance Recommendations for Executive Leadership

To align organizational communications with statutory intent, corporate leadership should adopt structured administrative practices.

Executive teams are recommended to conduct an audit of corporate communication tools. In a hypothetical scenario, a company implements an internal chat tool where team channels feature derogatory comments directed at an employee's professional competence. Leadership should ensure that organizational acceptable-use policies explicitly identify such digital behavior as workplace harassment under company policy and statutory definitions.

Furthermore, leadership should standardize digital bulletin boards. Creating a single, centralized intranet portal containing the OHSA, health and safety policies, and committee directories helps meet the requirements of subsection 1(5). Management should issue written, step-by-step instructions to all onboarding staff explaining how to navigate to these resources, maintaining electronic acknowledgment receipts as a governance best practice.

Legal review required

Corporate executives and human resources teams must execute a comprehensive legal review before adopting new electronic notice mechanisms:

  • Verify that digital delivery platforms meet both prongs of section 1(5) of the OHSA (direction to workers and accessibility in the workplace).
  • Confirm that policies addressing "information and communications technology" mirror the amended statutory definitions in subsection 1(1) of the OHSA.
  • Validate that language requirements under section 25(2)(i) (English and the majority language of the workplace) are preserved within the electronic format.
  • Ensure that all uncertain or unverified statutory duties are confirmed by legal counsel before organizational deployment.

Educational information, not legal advice.