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In force since January 1, 2026

Ontario Bill 190 Washroom Cleaning Records: The Complete Employer Compliance Guide (2026)

Ontario's Working for Workers Five Act (Bill 190) and O. Reg. 480/24 require every employer with washroom facilities to maintain and post cleaning records accessible to workers — with fines up to $100,000 per offence. This guide explains exactly what you need to do.

10 min read
For all Ontario employers with washroom facilities

What is Bill 190 / O. Reg. 480/24?

Bill 190 — the Working for Workers Five Act, 2024 — received Royal Assent in October 2024 and introduced Ontario Regulation 480/24 under the Occupational Health and Safety Act (OHSA). The regulation came into force on January 1, 2026.

Before Bill 190, Ontario's OHSA required employers to maintain clean washroom facilities but did not mandate a specific record-keeping format or posting requirement. O. Reg. 480/24 changed that by creating explicit obligations:

Maintain cleaning records

Employers must keep a record of every washroom cleaning, including the date, time, and identity of the person who performed it.

Post records where workers can see them

Records must be posted in or near the washroom in a location accessible to workers — either physically or electronically (e.g., via QR code).

Keep records current

Records must be kept up to date and reflect actual cleaning activity, not just scheduled times.

The key change from Bill 190: it is no longer enough to keep washrooms clean. You must now document and post evidence that they are being cleaned — and that documentation must be accessible to your workers.

Who Does Bill 190 Apply To?

O. Reg. 480/24 applies to all Ontario employers who provide washroom facilities to their workers — regardless of industry, sector, or workplace size. There is no minimum employee threshold.

Office buildings & commercial properties
Retail stores & shopping malls
Restaurants, cafes & food service
Schools, colleges & universities
Hospitals & long-term care homes
Manufacturing & industrial facilities
Gyms & recreation centres
Hotels & hospitality venues
Janitorial & facility services companies
Property management companies
Warehouses & logistics centres
Construction sites (with permanent washrooms)

If you are an Ontario employer and your workers use washroom facilities, Bill 190 applies to you.

What Must Be Recorded?

O. Reg. 480/24 requires cleaning records to capture sufficient information to demonstrate that washrooms are being cleaned as required. At minimum, each record should include:

Date and time of the cleaning
Name or identifier of the person who performed the cleaning
Tasks completed (toilets, sinks, floors, mirrors, supplies, waste bins)
Confirmation that cleaning was completed (not just scheduled)

A schedule showing when washrooms should be cleaned is not sufficient. Records must document when they were actually cleaned.

The regulation does not prescribe a specific format. Paper logs and digital systems are both acceptable — but digital systems offer significant practical advantages for compliance. Download a free compliant template →

How Must Records Be Posted?

O. Reg. 480/24 requires records to be posted in a location accessible to workers — in or near the washroom. Both physical and electronic posting are acceptable.

Physical posting

A printed cleaning log displayed on the washroom door or inside the facility. Workers can read it directly.

Requires daily printing and replacement
Records can be lost, damaged, or removed
No central record for inspectors

Electronic posting (recommended)

A QR code posted at the washroom links to a live digital record. Workers can access it by scanning the code.

Always current — no reprinting needed
Permanent digital record for inspectors
Exportable for audits in seconds

Fines and Penalties

Failure to comply with O. Reg. 480/24 is a violation of the Occupational Health and Safety Act. OHSA penalties are significant:

Up to $100,000 per offence for corporations

Each washroom without a compliant cleaning record is a separate offence. A portfolio with 10 non-compliant washrooms could face up to $1,000,000 in fines.

Compliance orders published publicly

MLITSD compliance orders are posted on the Ontario government's public inspection database — visible to tenants, clients, and prospective customers.

Stop-work orders possible

In serious or repeated cases, MLITSD inspectors may issue stop-work orders affecting your operations.

The cost of a compliant digital cleaning system — starting at $29/month — is a fraction of a single compliance order.

Paper Logs vs. Digital Records for Bill 190 Compliance

Both paper and digital records are accepted under O. Reg. 480/24. But in practice, paper logs create significant compliance risk:

Requirement
Paper Log
Komplio (Digital)
Record each cleaning with time & identity
Manual — depends on staff discipline
Automatic — captured at QR scan
Post records where workers can see
Requires daily printing and posting
Always live via washroom QR code
Tamper resistance
Low — easy to backfill entries
High — timestamped at submission
Inspector readiness
Manual binder search
CSV export in seconds
Multi-site management
Separate binders per location
Single dashboard, all sites
Record retention (12 months)
Physical storage required
Automatic — 365 days retained

How Komplio Makes Bill 190 Compliance Automatic

Komplio is a Canadian washroom management platform built for exactly this regulatory environment. Here is how it satisfies every O. Reg. 480/24 requirement:

QR scan creates a timestamped record automatically

When a cleaner scans the washroom QR code, Komplio creates a cleaning record with the exact date, time, and cleaner identity — no manual entry. The regulation's core requirement is satisfied with a phone scan.

Records are posted live via the QR code

The same QR code posted at the washroom lets workers see the most recent cleaning record by scanning it. No daily printing. No re-posting. Always current — meeting the 'posted where workers can access' requirement.

Inspector-ready export in seconds

When an MLITSD inspector arrives, export a full cleaning history as CSV — filtered by washroom, date range, or cleaner. No scrambling through binders.

365-day record retention built in

All cleaning logs are stored automatically for 365 days. You don't need to manage physical binders or worry about records being lost or damaged.

Multi-site management from one dashboard

Manage all your buildings and washrooms from a single account. See which washrooms are compliant and which have missed cleanings — across every location.

Get Bill 190 compliant in 30 minutes

Self-serve setup. No sales call. Print QR codes, assign cleaners, and every cleaning is logged automatically from day one.

Essentials plan from $29/month · 14-day free trial · no contracts

Disclaimer

This article is intended for general informational purposes only and does not constitute legal or regulatory advice. Obligations under OHSA and O. Reg. 480/24 may vary by sector and workplace type. Consult a qualified legal or compliance professional for guidance specific to your organization. Komplio is a management and record-keeping tool and does not replace professional compliance assessments.