Ontario Bill 190 Washroom Compliance Checklist — What Every Employer Needs to Know
A plain-language guide to O. Reg. 480/24, what's required, who it applies to, and how to stay compliant without the paperwork headache.
If you're an Ontario employer, Bill 190 has changed how you're legally required to manage your workplace washrooms. As of January 1, 2026, it's no longer enough to keep washrooms clean — you must document every cleaning and make those records accessible to your workers.
Inspectors from the Ministry of Labour can walk into your facility today and ask to see your washroom cleaning records. If you can't produce them, you run the risk of fines, likely a warning if its the first offence.
This guide breaks down exactly what the law requires, who it applies to, and the fastest way to get compliant.
What Is Bill 190?
Bill 190, formally called the Working for Workers Five Act, 2024, was passed by the Ontario government on October 28, 2024. It amended the Occupational Health and Safety Act (OHSA) with a clear goal: make workplaces more accountable, transparent, and fair for Ontario workers.
The washroom-specific requirements are set out in Ontario Regulation 480/24, which came into full force on January 1, 2026.
The core idea is straightforward. Ontario employers have always been expected to keep washrooms clean. Bill 190 takes that expectation and makes it visible — requiring documented, accessible proof that cleaning is actually happening consistently.
Who Does Bill 190 Apply To?
Bill 190's washroom requirements apply to most Ontario workplaces under the OHSA, including:
Office buildings and corporate facilities
Retail stores and shopping centres
Warehouses and distribution centres
Manufacturing plants and industrial facilities
Schools, colleges, and universities
Hospitals and long-term care facilities
Hotels and hospitality venues
Construction projects (with additional requirements under O. Reg. 213/91)
If you have employees and you have washrooms, this law almost certainly applies to you.
What About Federally Regulated Workplaces?
If your organization operates in a federally regulated industry — including banking, airlines, telecommunications, and interprovincial transportation — your workplace falls under the Canada Labour Code rather than Ontario's OHSA, meaning Bill 190 and O. Reg. 480/24 do not directly apply to you.
The federal Canada Occupational Health and Safety Regulations already require employers to maintain washrooms in a clean and sanitary condition, but stop short of the specific timestamped record-keeping and worker-accessible posting requirements that Ontario has introduced.
That said, the federal government registered new amendments to the Canada Labour Code regulations in February 2026, signalling that Ottawa is actively closing gaps in its OHS framework. Whether washroom record-keeping requirements similar to Ontario's are coming federally is a question of when, not if.
If you operate in a federally regulated industry, now is a smart time to get ahead of it — because the employers who build compliant systems today won't be scrambling when Ottawa catches up.
What Exactly Does Bill 190 Require?
Here is the complete compliance checklist broken down into plain language:
✅ 1. Keep Washrooms Clean and Sanitary
This requirement came into force on July 1, 2025. Employers and constructors must maintain all washroom facilities provided to workers in a clean and sanitary condition at all times. This isn't new in spirit — but it's now a legally enforceable obligation with teeth.
✅ 2. Document the Date and Time of Every Cleaning
As of January 1, 2026, every washroom cleaning must be logged with:
The date of the cleaning
The time of the cleaning
The record must show the two most recent cleanings for each washroom facility at all times.
✅ 3. Make Records Accessible to Workers
This is the part that catches most employers off guard. Workers must be able to access cleaning records on their own — without needing to ask a supervisor, track down a manager, or dig through a filing cabinet.
Acceptable methods of making records accessible include:
Posting a physical log in a visible location in or near the washroom
Posting a QR code near the washroom that links directly to the digital cleaning record
Providing electronic access with clear instructions on how and where workers can find the records
The key word is readily accessible. If your worker has to ask someone to pull up the records, you are not compliant.
✅ 4. Provide Workers with Instructions for Digital Access
If you're using a digital system, you must actively inform workers where and how to access the cleaning records. A QR code posted near the washroom that links directly to the log is the most practical solution for most workplaces.
✅ 5. Construction Sites Have Additional Requirements
Under Ontario Regulation 213/91, constructors on construction projects must maintain a cleaning record that covers the previous six months of washroom servicing, or the full duration of the project — whichever is shorter. This is a more extensive record-keeping obligation than standard employers face.
What Are the Penalties for Non-Compliance?
Ontario's OHSA enforcement has real consequences. Fines for non-compliance can reach $100,000 per offence for individuals. For corporations, penalties are significantly higher — and as of January 1, 2026, inspectors now have the authority to issue Administrative Monetary Penalties (AMPs) on the spot for OHSA contraventions, without needing to go through a full prosecution process.
In plain terms: an inspector can walk in, find that your washroom records aren't posted or accessible, and issue a financial penalty before they leave your building.
Paper Logs vs. Digital Logs — Which Is Better?
Both paper and digital logs can meet the legal requirements of Bill 190. But they are not equal in practice.
Paper logs are simple and inexpensive to start. But they get lost. They're easy to falsify. They require someone to physically check them to verify compliance. And as months of records accumulate, storing and organizing them becomes a real administrative burden.
Digital logs are accessible from anywhere. They create automatic timestamps that can't be altered after the fact. Managers can monitor compliance in real time across multiple locations. And when an inspector arrives, you can pull up a complete audit trail in seconds.
For most Ontario employers — especially those managing multiple washrooms, multiple locations, or large workforces — a digital solution isn't just more convenient. It's more defensible.
The Fastest Way to Get Compliant
Here is the step-by-step checklist to get your organization compliant with Bill 190 as quickly as possible:
Step 1 — Inventory every washroom List every washroom facility your workers use, including portable units, temporary facilities on job sites, and washrooms in leased spaces where you have responsibility for maintenance.
Step 2 — Choose your record-keeping method Decide whether you're going paper or digital, and apply that approach consistently across all locations and shifts.
Step 3 — Assign accountability Define exactly who is responsible for logging each cleaning on every shift — including evenings, weekends, and periods of staff absence. Gaps in records are a compliance risk.
Step 4 — Post records where workers can see them Whether paper or QR code, records must be displayed in or near each washroom in a location where workers are likely to notice them.
Step 5 — Train your cleaning staff Every person responsible for cleaning a washroom needs to understand how to log the clean immediately after completing it. A cleaning that isn't logged doesn't count.
Step 6 — Communicate to workers Tell your employees where and how they can access washroom cleaning records. For digital systems, this means posting instructions or a QR code near the washroom entrance.
Step 7 — Review regularly Set a monthly review process to check that records are being kept consistently and that no washrooms have been missed.
How VeriClean Makes Bill 190 Compliance Effortless
VeriClean was built specifically for Ontario employers navigating Bill 190. Here's how it works:
Cleaners scan a QR code posted in the washroom and log their clean in seconds using a unique PIN — no app download required
Workers scan the same QR code to instantly view the two most recent cleaning records — fully accessible, fully compliant
Managers get a real-time dashboard showing cleaning status across every washroom and every location
Every record is automatically timestamped, stored, and audit-ready. If an inspector walks in tomorrow, you can pull up a complete cleaning history for every washroom in your facility in under 30 seconds.
Setup takes less than 10 minutes per location. Pricing starts at $29/month.
Start your free trial at vericlean.ai →
Frequently Asked Questions
Does Bill 190 apply to small businesses? Yes — most Ontario employers who provide washroom facilities to workers are covered, regardless of business size. The exemptions are narrow and primarily apply to federally regulated industries.
Can I use paper logs to comply with Bill 190? Yes, paper logs are legally acceptable. However, they must be posted in a visible location near each washroom and kept current with the two most recent cleanings. Digital systems offer a more reliable and audit-friendly alternative.
How long do I need to keep washroom cleaning records? The regulation requires the two most recent cleaning records to be posted at all times. For construction sites, records covering six months or the duration of the project must be maintained. Consult your legal advisor regarding longer-term record retention best practices.
What happens if an inspector finds I'm not compliant? As of January 1, 2026, Ministry of Labour inspectors can issue Administrative Monetary Penalties on the spot for OHSA contraventions. Fines for individuals can reach $100,000 per offence.
Is a QR code an acceptable way to post cleaning records? Yes. Posting a QR code near the washroom that links directly to the cleaning record is explicitly recognized as a compliant method under O. Reg. 480/24, provided workers can access the record without needing to ask for help.
This article is for informational purposes only and does not constitute legal advice. For compliance guidance specific to your workplace, consult a qualified legal advisor or visit ontario.ca for the full text of Ontario Regulation 480/24.