Compliance8 min readBy Mazin Kulom, Founder & President

Ontario Now Requires Washroom Cleaning Records. Here's What Your Building Has to Post.

Since January 1, 2026, virtually every Ontario workplace must post a record of each staff washroom's two most recent cleanings. No size exemption, no phase-in. Here's what the rule actually says, who it covers, and how to fold compliance into a cleaning contract instead of a new chore.

Since January 1, if your business has staff and a washroom in Ontario, the law expects two things of you: keep that washroom clean and sanitary, and keep a posted record proving when it was last cleaned. The rule arrived with remarkably little noise — the pages explaining it are mostly law firms writing for HR departments — but it has no company-size exemption and no phase-in for small workplaces. A Ministry of Labour inspector can now walk into a school, a store, a warehouse, or a six-person office and ask to see the record. Here's the rule, plainly.

Key takeaways
Since January 1, 2026, Ontario employers must keep a record of washroom cleanings — the date and time of the two most recent — and make it available to workers. The underlying duty to keep washrooms clean and sanitary has been in force since July 1, 2025.
There is no size threshold. The rule applies to employers and constructors alike — a two-person shop and a warehouse running three shifts carry the same duty.
The record is posted in a conspicuous spot in or near the washroom, or kept electronically — as long as workers are told where and how to find it.
The law doesn't dictate how often you clean. But a posted record of the last two cleanings makes your actual frequency visible to staff and to Ministry of Labour inspectors.
Compliance is a line in your cleaning contract, not a new hire: the crew that cleans logs each visit, and the record maintains itself.

What the new rule actually requires.

Since January 1, 2026, every provincially regulated employer in Ontario that provides a washroom for its workers must keep a cleaning record for it — the date and time of the two most recent cleanings — and make that record available: posted in or near the washroom, or accessible electronically. That’s the whole requirement. It comes from section 25.3 of the Occupational Health and Safety Act and Ontario Regulation 480/24.

The rule arrived in two stages, which is part of why it slipped past so many owners. The Working for Workers Five Act, 2024 added section 25.3 to the OHSA: washroom facilities provided for workers must be maintained in a clean and sanitary condition. That duty took effect July 1, 2025. The record-keeping half — the part an inspector can ask you to produce — came into force January 1, 2026, with the details set out in O. Reg. 480/24.

Who has to comply? Almost every workplace.

Employers and constructors — all of them. Unlike many workplace rules, there is no worker-count threshold: the duty isn’t reserved for large facilities. If you’re a principal with staff washrooms in a school, a general manager with a back-of-store washroom, an agency owner on one floor of an office building, or a plant manager with washrooms serving three shifts, the duty reads the same. On construction projects, employers and the constructor share it.

The carve-outs are narrow. The duty attaches to washrooms provided for workers — so in a mall or food court, a public washroom outside your leased unit isn’t yours to record. Eye-wash stations and emergency showers aren’t washroom facilities at all. But note the practical catch: in most small businesses, staff and customers use the same room, which puts that room squarely in scope.

The ruleWhat it saysWhat it means for you
Clean and sanitary (since July 1, 2025)Washrooms provided for workers must be maintained clean and sanitaryWashroom cleaning is now an OHSA duty, not a housekeeping preference
The record (since Jan 1, 2026)Date and time of the two most recent cleanings, kept and made availableEvery cleaning gets logged as it happens — not reconstructed later
PostingA conspicuous place in or near the washroom, or electronic with directionsA laminated card by the door is the simplest version that stays compliant
CoverageEmployers and constructors, no size thresholdOffices, schools, stores, gyms, clinics, warehouses, job sites
EnforcementMinistry of Labour (MLITSD) inspectors can ask and issue ordersTreat it like any other posted OHSA requirement

The record makes your cleaning frequency public.

Here’s the part the legal bulletins mostly skip. The regulation never says how often a washroom must be cleaned — no interval, no minimum. But two timestamps do arithmetic in anyone’s head. A card showing Tuesday 9:05 p.m. and Monday 9:12 p.m. says one thing about a building; a card showing entries nine days apart says another, and it says it to every employee, every visitor who glances at it, and any inspector who walks in. Cleaning frequency used to be an internal budget decision. As of this year, it’s self-documenting.

That cuts both ways, and it should. A washroom serviced nightly now has a posted card proving it — which is worth something to the businesses already paying for that standard. And a “cleaning” that’s really a thirty-second restock is now a logged claim with a date and time on it. What a real washroom cleaning involves — the top-to-bottom order, disinfectant dwell times, the drain traps — is its own discipline; our commercial restroom cleaning guide walks through the method. The record rule doesn’t raise the cleaning standard directly. It just makes whatever your standard is visible.

"Keep, maintain and make available" is three duties

Logging the clean isn’t enough if the posting goes stale, and a tidy binder in the office doesn’t help a worker standing at the washroom door. The habit that satisfies all three at once: whoever cleans writes the date and time on the posted card before leaving the room, every visit. If you go electronic instead, workers must be told exactly where and how to find the record — a QR code on the washroom door pointing at the live log is the cleanest version.

Compliance is a scope line, not a project.

If a cleaning company services your building, this rule should cost you nothing but a conversation. The people doing the cleaning are the right people to log it — so the requirement belongs in the written scope of work: what counts as a cleaning (a full clean to a stated method, not a paper restock), that every visit is logged with date and time, and who keeps the posted card or digital log current between visits. A proper janitorial program already runs on task lists and sign-offs; the washroom record is one more line, maintained by the crew that’s already in the room.

If you clean in-house, the mechanics are the same: the washroom line slots into the daily tier of a complete office cleaning checklist, logged by whoever does it, with the record living at the door. Either way, the rule is one more reason to get your cleaning scope in writing if it isn’t already. A scope that names tasks and frequencies is also, conveniently, the document that makes cleaning quotes comparable when you next go to market.

  1. 01

    List every washroom your workers use. Staff-only rooms, shared staff-and-customer rooms, one per floor if that’s your layout. Each one needs its own record.

  2. 02

    Pick the posting method per washroom. A laminated card in a conspicuous spot in or near the room, or an electronic record with clear directions for workers on where and how to reach it. Pick whichever one will actually stay current in your building.

  3. 03

    Define what counts as a cleaning. The record is only as honest as the work behind it. Set the standard in writing — fixtures, surfaces, floor, restock, in the right order — so a logged entry means the room was actually cleaned, not glanced at.

  4. 04

    Make logging part of the cleaning itself. Whoever cleans — your staff or your contractor’s crew — records the date and time before leaving the room, every time. If a contractor cleans your building, write the logging and the posting upkeep into the scope of work explicitly.

  5. 05

    Audit it the way an inspector would. Once a month, walk to the washroom and read the card. Two entries, recent, plausible, matching the service schedule you’re paying for. If the card and the contract disagree, you’ve learned something more important than a compliance gap.

The rule doesn't ask whether your washroom was cleaned. It asks whether you can prove when.

Frequently asked questions.

Yes. There is no worker-count threshold — the duty applies to employers and constructors regardless of size, so a six-person office carries the same obligation as a large facility. The rule lives in Ontario's Occupational Health and Safety Act, so the main workplaces outside it are federally regulated ones — banks, telecoms, interprovincial transport — which follow federal workplace rules instead.

Under Ontario Regulation 480/24, the record must show the date and time of the two most recent cleanings of that washroom facility. The employer must keep the record, maintain it, and make it available to workers — either posted in a conspicuous place in or near the washroom where workers will see it, or electronically, in which case workers must be given directions on where and how to access it.

Yes. The regulation allows the record to be kept electronically as long as workers can access it and are told where and how — a QR code on the washroom door linking to a live cleaning log is a common approach. For a single washroom, a laminated card by the door is often the more reliable option simply because it can't fall out of date without being visibly blank.

The law sets no fixed frequency. The standard is that washrooms provided for workers are maintained in a clean and sanitary condition, and the posted record then shows your actual cadence to anyone who reads it. In practice, commercial cleaning scopes treat washrooms as a daily task in any occupied building — and with the record posted, a frequency that's too thin is now visible rather than theoretical.

The requirement sits in the Occupational Health and Safety Act, so it's enforced the way other OHSA duties are: inspectors from the Ministry of Labour, Immigration, Training and Skills Development can ask to see the record during a workplace visit and can issue compliance orders — and, as with any OHSA duty, failing to comply with an order can escalate to prosecution and fines under the Act. The cost of avoiding all of that is a logging habit.

The duty covers washrooms provided for workers. A washroom used only by customers isn't the target of section 25.3 — but in most smaller businesses, staff and customers share the same room, and a shared room is one your workers use, which brings it into scope. The clean exemption is the multi-tenant scenario: a public washroom in a mall or food court outside the unit you lease is the landlord's, not yours.