Our sister firm, Williams HR Law has been a source of information for HR practitioners, managers and business owners as legislative amendments were proposed and revised.  Their Bill 148 Compliance Considerations bulletin provides a list of questions to consider when assessing your organization’s risk of non-compliance and use their special edition In-the-Know newsletter for guidance on your Bill 148 compliance efforts.


In this WHRC blog article, we want to highlight areas of the HR function that may be impacted as you implement the legislative changes in your organization, such as:



  • With changes to minimum wage, how are you going to re-set employee expectations regarding your compensation philosophy and emerging compression issues?
  • What new HR processes will need to be created? (e.g. requests for wage reviews)
  • Are there discretionary benefit offerings that can be adjusted to offset the costs associated with changes to leave and vacation requirements?


  • How will changes to leave, overtime, on-call pay, and vacation requirements be incorporated into your overall employment offering?
  • Have you considered changes to your organizations relationship with talent agencies?

Workforce Planning

  • Will your organization require additional staff or training to improve sales to offset the increased costs from Bill 148?
  • Will you need to evaluate your talent supply to identify skill gaps and talent risks that may exist?
  • Will your organization need to explore outsourcing opportunities or the addition of technology to offset rising labour costs?
  • Do you have succession and retention plans in place?
  • Have you considered the staffing impact from extended ESA leaves, e.g., parental, vacation? How will hours of work and scheduling need to be modified?
  • To optimize your workforce, what departments or critical activities need to be identified and prioritized that drive value for the organization?

HR Infrastructure

  • How will HR documentation be updated? (e.g. onboarding checklists, offer letters)
  • How will HR record-keeping processes be updated?
  • Have you assessed the impact of legislation banning employers from requesting a doctor’s note on how you handle attendance related matters?
  • How will new reporting requirements related to employment terms and conditions, as well as scheduling, be captured in your Human Resources Information System?
  • How will changes to overtime and on-call pay be tracked and administered in your payroll system?

Communication Strategy

  • How will changes be communicated to employees? (e.g., formal letters outlining changes)
  • What rationale will be provided for how your organization has decided to respond to Bill 148?
  • How will managers be supported in communicating and handling employee questions? (e.g., training)


If you have any questions, or would like to discuss the impact of Bill 148 on your organization from an HR best practice perspective, please feel free to contact any of our HR Business Consultants at