On October 25, 2021, amendments to Ontario's Employment Standards Act, 2000 (ESA) took effect, introducing section 67.2 — a provision that bans most non-compete agreements between employers and employees. This was a significant policy shift aimed at increasing labour mobility, particularly in technology and innovation industries. Ontario became the first Canadian province to legislatively ban non-competes by statute (as opposed to relying solely on the common law reasonableness test). This guide explains what section 67.2 means for Ontario employers and employees in 2026.
What Section 67.2 of the ESA Prohibits
Section 67.2 of the ESA states that an employer shall not enter into an employment contract or other agreement with an employee that is or includes a non-compete agreement. A "non-compete agreement" is defined as an agreement, or a provision in an agreement, that prohibits the employee from engaging in any business, work, occupation, profession, project, or other activity that is in competition with the employer's business after the employment relationship ends.
This provision applies to employment contracts entered into on or after October 25, 2021. Existing agreements signed before that date are not invalidated by section 67.2, though they were already subject to the common law enforceability test (discussed below). A non-compete clause in a post-October 2021 employment agreement is void and unenforceable under the ESA — the employer cannot seek to enforce it.
The Executive Exception
The ESA's ban on non-competes includes one narrow but important exception: it does not apply to a person who is an "executive" — defined in the regulations as a person who holds the position of or exercises the authority of an officer of the corporation or holds one of the following positions: chief executive officer, president, chief administrative officer, chief operating officer, chief financial officer, chief information officer, chief legal officer, chief human resources officer, chief corporate development officer, or any other "C-suite" equivalent. For these executives, a non-compete agreement may still be included in the employment contract.
Importantly, the executive exception does not mean any non-compete against an executive is automatically enforceable — it means the ESA's per se prohibition does not apply. An executive-level non-compete must still satisfy the common law test for enforceability.
The Common Law Test: Still Applies to Executives
For executives (who fall within the exception) and for agreements predating October 2021, the common law enforceability test applies. Canadian courts have historically been reluctant to enforce non-compete agreements unless they are reasonable in the circumstances. The test is whether the restriction is reasonable as between the parties and from the perspective of the public interest. Specifically, a court will consider whether:
- The restriction is reasonable in terms of geographic scope (is the restriction limited to a defined area where the employer actually carries on business?).
- The restriction is reasonable in terms of duration (courts rarely enforce restrictions longer than 12–24 months).
- The restriction is reasonable in terms of activity scope (is it limited to competitive activity that poses a real threat, or does it sweep too broadly?).
- The employer has a legitimate proprietary interest it is seeking to protect (confidential information, trade secrets, client relationships built on the employer's goodwill).
Case law analysis of Globex Systems Inc v Kotler and similar Ontario decisions confirms that courts apply these criteria strictly and will not "blue pencil" (partially rewrite) an overly broad non-compete to make it reasonable — an unreasonable clause is simply void.
Non-Solicitation Clauses: Still Valid
While non-compete agreements are largely prohibited, Ontario employers can still protect their interests using non-solicitation clauses. A non-solicitation clause restricts a former employee from:
- Soliciting the employer's clients or customers to transfer their business away.
- Soliciting the employer's employees to leave and join a competitor.
Non-solicitation clauses are not covered by the ESA ban (section 67.2 is specific to non-compete restrictions). However, they must still be reasonable to be enforceable at common law — overly broad non-solicitation clauses (e.g., covering all clients the employee ever heard of, not just those they personally served) may still be struck down. A well-drafted non-solicitation clause typically restricts direct solicitation of clients the employee had personal contact with, for a period of 12–18 months post-employment.
Client Lists as Trade Secrets
Independent of non-compete and non-solicitation clauses, employers can protect confidential business information — including client lists — through the law of trade secrets and breach of confidence. A departing employee who takes a confidential client list and uses it to solicit the employer's clients may be liable for breach of the implied duty of confidentiality, even without any written agreement, if:
- The information was genuinely confidential (not publicly available).
- The employee knew or ought to have known it was confidential.
- The employee's use of the information caused harm to the employer.
This claim can be pursued even where a non-compete clause is unenforceable. The employer may seek an injunction to prevent continued use of the information and damages for any business lost as a result.
Practical Advice for Employers Post-2021
Given the ESA ban, Ontario employers should review and update their standard employment agreements to:
- Remove any non-compete clauses for non-executive employees (replace with robust non-solicitation and confidentiality clauses).
- Ensure non-solicitation clauses are precisely drafted — specifying which clients, for what period, and with what limitations.
- Include a standalone confidentiality/NDA clause covering all proprietary business information.
- For executives, continue to use non-compete clauses but subject them to legal review for reasonableness.
- Document which client relationships were developed using employer resources (emails, CRM data) to support trade secret claims if needed.