Bill 11 explained: what Ontario's Health Care Staffing Agency Reporting Act means for your agency

Is Bill 11 in force right now?

No. Bill 11 received Royal Assent on June 28, 2025 (Chapter 7 of Statutes of Ontario, 2025), but the Health Care Staffing Agency Reporting Act, 2025 is not yet in force as of July 11, 2026. The Act awaits a proclamation order from the Lieutenant Governor in Council before its requirements apply.

Check the Ontario Gazette and the Ontario Ministry of Health website regularly for a proclamation order. When you see it, the Act will come into force on the date specified, typically 30 to 90 days after proclamation.

Who does Bill 11 apply to?

Bill 11 applies to temporary help agencies that assign prescribed workers to prescribed health care facilities. Prescribed workers and facilities are not yet defined, but they are expected to include:

• Agencies assigning workers to public hospitals (e.g., RNs, LPNs, personal support assistants, housekeeping, food services).
• Agencies assigning workers to long-term care homes (e.g., PSAs, nurses, food service workers).
• Agencies assigning workers to other prescribed health care facilities (e.g., clinics, urgent care, dialysis centres) once prescribed by regulation.

If your agency assigns temp workers to health care facilities, you will be in scope when the Act is proclaimed. If you only assign industrial, warehouse, hospitality, or office workers, you are not affected.

What reporting will you have to do when Bill 11 comes into force?

When proclaimed, your agency must submit reports to Ontario's Ministry of Health at least every six months (or another interval set by regulation). Each report must contain aggregate information, meaning totals and summaries, not individual worker details. The report must cover:

• Administrative information (e.g., number of workers assigned, hours, facilities served).
• Billing information (e.g., invoice amounts, billing rates, client charges).
• Pay rate information (e.g., what you paid workers, how rates were calculated, whether any premiums applied).

The exact reporting form and data fields will be prescribed by regulation when the Act is proclaimed. You will not have to submit raw invoices or contracts, only aggregated summaries.

What records must you keep?

What should you do now to prepare?

• Monitor the Ontario Gazette for a proclamation order. When it is published, the Act will have a specific coming-into-force date, usually 30 to 90 days later.
• Review your current health care facility contracts. When the Act comes into force, you must keep any new or amended contracts for three years after expiry. Set a reminder to do this.
• Ensure your per-worker assignment records are clear and auditable. You will need to aggregate hours, rates, and billing amounts by facility to construct your six-monthly reports.
• Track invoices. When the Act comes into force, invoices show the billing and pay rate information the ministry will ask for in aggregate form.
• Consider whether your current invoicing and hour-tracking process will let you extract the aggregate data the reports will require. If not, work with your payroll provider or a staffing software to set up the needed data structure.

What happens if you do not comply?

Bill 11 does not yet specify penalties for non-compliance. Once the Act is proclaimed and regulations are finalized, the Ministry of Health will likely enforce record-keeping and reporting requirements through compliance orders and fines, similar to other health care staffing regulations. Non-compliance could also affect your ability to win or renew health care facility contracts.