Ontario Bill 190 Washroom Compliance — Everything You Need to Know
Ontario's Working for Workers Five Act is in force. Employers who fail to keep and post washroom cleaning records can now face significant fines under the OHSA — and inspectors are actively visiting workplaces to check.
What Is Ontario Bill 190?
Bill 190 — formally the Working for Workers Five Act, 2024 — received Royal Assent on October 28, 2024. It is the fifth in Ontario's series of "Working for Workers" bills, each designed to strengthen protections for employees across the province.
For facility managers and employers, the most operationally significant change is a new set of obligations under the Occupational Health and Safety Act (OHSA): every Ontario employer who provides washroom facilities to workers must now keep those facilities clean, maintain a log of cleaning activity, and make that log visible to workers at all times.
The specific posting and record-keeping requirements were clarified in O. Reg. 480/24, which came into force on January 1, 2026.
In plain language
Every washroom you provide for employees needs a cleaning record posted in or near it — showing the date and time of the two most recent cleanings. Workers must be able to see this without asking.
Who Must Comply?
The regulation applies broadly across Ontario industries. If your workplace has washrooms that workers use, you are covered — regardless of sector or company size. This includes:
Construction projects: Constructors on active construction projects have additional obligations under O. Reg. 482/24, which requires a longer cleaning history to be maintained.
Implementation Timeline
⚠️ Enforcement is active
Both phases of the regulation are now in force. Ministry of Labour inspectors are actively conducting workplace visits, and non-compliance can lead to orders and, in serious cases, prosecution under the OHSA.
Bill 190 Receives Royal Assent
The Working for Workers Five Act, 2024 is signed into law. OHSA amendments are enacted, establishing the framework for washroom cleanliness and record-keeping obligations.
O. Reg. 480/24 Filed
The clarifying regulation is filed, defining exactly what records must be kept and how they must be posted — either physically near the washroom or electronically with clear access instructions for workers.
Core Obligations Take Effect
Employers must ensure all worker washrooms are maintained in a clean and sanitary condition, and must begin keeping records of cleaning activity. Inspectors can act on complaints from this date.
O. Reg. 480/24 Fully Enforced
Full posting requirements are enforceable. Records showing the date and time of the two most recent cleanings must be posted and accessible. Non-compliance is enforced through inspector orders and, for serious or repeated violations, prosecution under the OHSA.
Core Employer Duties Under O. Reg. 480/24
The regulation establishes three distinct categories of obligation. All three must be met simultaneously.
Maintain Cleanliness
Every washroom provided to workers must be kept in a clean and sanitary condition at all times. This is an ongoing operational duty, not a one-time setup.
Keep Records
A cleaning log must be maintained for each washroom, recording the date and time of every cleaning. For construction sites, records must span the past 6 months or the project duration (whichever is shorter).
Post & Provide Access
The date and time of the two most recent cleanings must be posted in a conspicuous location in or near the washroom, OR made available electronically — with clear instructions for workers on how to access it.
Respond to Inspectors
Records must be available on demand for Ministry inspectors. Missing or incomplete logs are one of the first things inspectors check when responding to a worker complaint.
What counts as "electronic" posting?
A QR code posted near the washroom that workers can scan to view the cleaning log satisfies the electronic posting requirement — provided workers are informed how to use it. This is exactly how VeriClean works.
Penalties for Non-Compliance
O. Reg. 480/24 itself does not set its own penalty schedule — enforcement runs through the OHSA's existing penalty framework under Section 66, which was significantly strengthened by Bill 190.
Enforced through inspector orders and prosecution
Ontario's Administrative Monetary Penalty (AMP) system, introduced via O. Reg. 365/25, currently applies to exactly one contravention — an unrelated public-sector procurement matter — and does not apply to washroom record violations. Non-compliance here is enforced the traditional way: Ministry of Labour inspector orders, and prosecution under the OHSA for serious or repeated violations.
| Who | Offence Type | Maximum Penalty |
|---|---|---|
| Corporation | Any OHSA / Reg. 480/24 violation Per Offence | $2,000,000 |
| Directors & Officers | Any OHSA / Reg. 480/24 violation Per Offence | $1,500,000 + up to 12 months imprisonment |
| Other Individuals | Any OHSA / Reg. 480/24 violation Per Offence | $500,000 + up to 12 months imprisonment |
A corporation convicted of a second or subsequent offence that causes death or serious injury to a worker within a two-year period faces a minimum fine of $500,000, in addition to the maximums above. Prior convictions and a documented history of non-compliance are also treated as aggravating factors under the amended OHSA. Ontario's Administrative Monetary Penalty (AMP) system does not currently apply to washroom record violations — as of today it covers exactly one contravention, an unrelated public-sector procurement matter.
Why Bill 190 Compliance Matters
The financial penalties are serious — but the operational and reputational fallout from non-compliance can be equally damaging.
Triggers Deeper Inspections
Missing cleaning records are the first thing inspectors check. A gap in your washroom log opens the door to a full audit of your health and safety program.
Worker Trust & Retention
Employees notice. Dirty facilities or missing logs send a clear signal about how a workplace values the people in it — directly affecting morale and turnover.
Client & Contract Risk
Enterprise clients, public sector contracts, and procurement processes increasingly scrutinize compliance programs. Non-compliance can cost you business.
Reputational Exposure
Ministry orders and fines are public records. Public-facing businesses face heightened scrutiny from customers and media when OHSA violations surface.
No Warning Period
There's no statutory grace period under O. Reg. 480/24 — it's enforceable now. An inspector doesn't need a complaint to visit, and non-compliance can lead to an order or prosecution without delay.
Likely to Expand
Similar washroom compliance legislation is expected to extend to other Canadian provinces. Building a compliant system now positions your organization ahead of the curve.
Bill 190 Compliance Checklist
Use this checklist to assess your current compliance posture. Click each item to mark it complete.
Operations
Record-Keeping
Posting & Visibility
Governance
Free · Print-ready · 13-point checklist for Ontario employers
The VeriClean Solution
Paper logs get lost, altered, or forgotten. Spreadsheets don't scale across multiple locations. VeriClean is purpose-built for O. Reg. 480/24 — so compliance happens automatically, every single clean.
How It Works
Compliant in under 60 seconds per washroom
Generate & Post QR Codes
Create unique QR codes for each washroom from your dashboard. Print and post them in each facility.
Staff Log Cleans
Cleaning staff scan the QR code and enter their PIN to instantly record a timestamped, verified cleaning event.
Workers View Records
Workers scan the same QR code to view the two most recent cleans — meeting Reg 480/24 display requirements instantly.
Everything Included
QR-Based Clean Logging
Cleaners scan a QR code to instantly log each cleaning event with a verified timestamp.
Worker-Accessible Records
Workers view the two most recent cleans by scanning the same QR code — no app download needed.
Timestamped Digital Logs
Every clean is recorded with precise date, time, and cleaner identification.
Multi-Site Dashboard
Monitor compliance status across all locations from a single centralized dashboard.
Instant Report Downloads
Export compliance records anytime for inspections, audits, or internal reviews.
Automated Alerts
Get notified when washrooms haven't been cleaned within required timeframes.
Restroom Feedback
Allow workers and visitors to submit anonymous feedback about washroom conditions. Identify recurring issues before they become complaints.
Frequently Asked Questions
What exactly is Bill 190 and why does it affect my workplace?
Bill 190 — the Working for Workers Five Act, 2024 — amends the Occupational Health and Safety Act to require every Ontario employer who provides washroom facilities for workers to keep those facilities clean, maintain a cleaning log, and make that log visible to workers at all times. It received Royal Assent on October 28, 2024.
When did the washroom compliance requirements come into effect?
The core obligations (maintaining cleanliness and keeping records) took effect July 1, 2025. The specific posting requirements under O. Reg. 480/24 came into full force on January 1, 2026. Both phases are now active and enforceable.
What records must be posted, and where?
At minimum, the date and time of the two most recent cleanings for each washroom must be posted in a conspicuous location in or near the washroom, or made available electronically with clear instructions for workers on how to access it.
What are the fines for non-compliance?
Corporations face fines up to $2,000,000 per offence. Directors and officers can face fines up to $1,500,000 and/or up to 12 months imprisonment, and other individuals (including supervisors and workers) up to $500,000 and/or up to 12 months imprisonment. Enforcement is through Ministry of Labour inspector orders and, for serious or repeated violations, prosecution under the OHSA — not Administrative Monetary Penalties, which currently apply to one unrelated procurement contravention and not to washroom compliance.
Does Bill 190 apply to small businesses?
Yes. The regulation applies to every Ontario employer who provides a washroom facility for workers, regardless of business size. There are no exemptions for small businesses.
Is a paper log sufficient to comply?
Technically yes — a paper log posted in or near the washroom can satisfy the requirement. However, paper logs are easily lost, damaged, or forged. They also make it difficult to prove compliance during an inspection. Digital solutions like VeriClean provide tamper-proof, always-current records that are far more reliable.
How does VeriClean satisfy the O. Reg. 480/24 posting requirement?
VeriClean generates a unique QR code for each washroom. Workers scan the code to view the two most recent cleans — satisfying the electronic posting requirement. Cleaners scan the same code and enter their PIN to log each cleaning event with a verified timestamp. No app download is required.
What does VeriClean cost?
Plans start at $9/month. Visit our pricing page for full details, or book a free demo and we'll walk you through setup for your locations.
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Friendly note: This page is informational, not legal advice. If you're unsure how the rules apply to your specific workplace (e.g., multi-tenant buildings, union environments, or unique schedules), consult counsel.
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