Cross-border
HR guidance for both sides of the border
Employment rules differ between provinces, between states and between the two countries. We help you keep practices consistent where you can and adapt them where local rules require.
CHRLCPHRSHRM-SCP
Our team holds the CHRL and CPHR designations in Canada and the SHRM-SCP in the United States, so the same advisers can work on both sides of the border.
Topic
🇨🇦 Canada
🇺🇸 United States
Ending employment
CanadaReasonable notice or pay in lieu, on top of statutory minimums
United StatesAt-will employment in most states, with contract and discrimination exceptions
Employment standards
CanadaSet by each province, plus federal rules for some industries
United StatesFederal law, such as the FLSA, plus state and local rules
Human rights and discrimination
CanadaProvincial human rights codes, plus the Canadian Human Rights Act for federally regulated employers
United StatesFederal laws such as Title VII, the ADA and the ADEA, plus state and local laws
Pay transparency
CanadaGrowing requirements in several provinces
United StatesRequirements in a growing number of states and cities
Leaves and benefits
CanadaProvincial leaves alongside federal EI benefits
United StatesFMLA plus state paid leave programs, which vary widely
Health coverage
CanadaPublic health insurance, with employer plans adding extended health and dental
United StatesEmployer health insurance is central, and larger employers face federal coverage rules
Employee privacy
CanadaFederal and provincial privacy laws, which vary by province and sector
United StatesNo single federal privacy law for employees; some states, such as California, cover employee data
AI in hiring
CanadaOntario employers with 25 or more employees must disclose AI screening in public job postings
United StatesRules vary by place, such as bias audits for automated hiring tools in New York City
This is a general overview, not legal advice. Rules vary by jurisdiction and change often. For legal questions, we recommend speaking with an employment lawyer.
