An Ontario employer with 40 to 250 people has six real ways to buy HR capability: a first hire, a PEO, an HR platform, fractional HR, a consultancy or employment counsel. We score all six against eight criteria, disclose the weight we put on each, and show how the ranking moves when you change the weights — because the weighting is the decision.
Somewhere between 40 and 250 employees, an Ontario company stops being able to run people decisions off the side of the CFO's desk. Termination letters start carrying real money. A manager complaint arrives that involves someone senior. Payroll has enough moving parts that a vacation-pay error is now systematic rather than a rounding difference. And the question lands on someone's desk in the form it usually takes: we need HR — what do we buy?
There are six real answers to that in the Ontario market. This article scores all six against eight criteria, discloses the weight on each, and shows what happens when you change the weights — a comparison that hides its weighting is advocacy wearing a table. We are one of the six — our category finishes second on our own weights — and we have left that result where it landed. The scores rank fit to a defined buying situation, not the quality of anyone's work; a reader with a different constraint should reweight.
| # | Criterion | Weight | What it actually measures |
|---|---|---|---|
| 1 | Coverage of the compliance failures Ontario actually enforces | 20 | Whether the option covers the specific violations Ontario inspectors and claim investigators find, rather than compliance in the abstract |
| 2 | Independence when the complaint involves a senior person | 15 | Whether the option can produce fact-finding that survives the question who does this person report to? |
| 3 | Senior judgement available on demand | 15 | Whether someone who has done org design, restructuring and executive exits is reachable in the week you need them |
| 4 | Payroll, benefits and records administration | 10 | Whether the transactional engine is owned by the provider or stays your problem |
| 5 | Absolute annual cost at about 100 employees | 10 | Total spend, not value for money — value is what the other seven criteria measure |
| 6 | Time from decision to usable capability | 10 | Elapsed weeks from signing to the thing being useful |
| 7 | Continuity and retained institutional knowledge | 10 | Whether the reasoning behind last year's decisions is still in the building |
| 8 | Multi-province and multi-jurisdiction reach | 10 | Whether the option scales past Ontario without a second procurement |
The heaviest weight is anchored in what Ontario actually enforces. The ministry's employment standards enforcement statistics record 11,940 claim investigations in fiscal 2024–25, and the top violations found — across both claims and the ministry's own workplace inspections — are payroll, hours and records matters: wages, vacation pay, termination pay, public holidays, overtime, record keeping. Almost none of it is strategy, and whichever option you choose has to cover that list first.
A. First full-time HR hire. One person, in the building, on payroll. Usually an HR manager or generalist rather than a CHRO.
B. Professional employer organisation or administrative services organisation. Payroll, benefits, records and statutory administration, bundled. A PEO takes on co-employment and becomes employer of record; an ASO does the same work while you remain employer of record. Typically priced against payroll or per employee per month.
C. HR software platform. An HRIS with onboarding workflows, records, time and attendance, policy templates and compliance prompts. Systems instead of people.
D. Fractional or embedded HR provider. A senior HR practitioner working part-time inside your organisation, usually with executional support underneath. This is our category.
E. National HR consultancy or people-advisory practice. Project-scoped work from a firm with a bench: org design, compensation benchmarking, workforce planning, integration support.
F. Employment law firm on retainer. Legal advice, documents, representation, and the possibility of solicitor-client privilege where counsel directs the work for the purpose of legal advice.
Those are categories, not straw men. Each one is the correct answer for some real Ontario employer, and for several of them we would tell you to go there instead of to us.
Scores are 1 to 5, higher is better, and they are our judgement rather than measured data. The weighted total is the sum of score × weight, divided by 100, so it lands back on the 1 to 5 scale.
| Criterion (weight) | A. Full-time hire | B. PEO / ASO | C. HR platform | D. Fractional / embedded | E. National consultancy | F. Employment law firm |
|---|---|---|---|---|---|---|
| 1. Enforced-compliance coverage (20) | 4 | 5 | 3 | 3 | 3 | 2 |
| 2. Independence on senior-level complaints (15) | 1 | 2 | 1 | 2 | 3 | 5 |
| 3. Senior judgement on demand (15) | 3 | 1 | 1 | 5 | 4 | 3 |
| 4. Payroll, benefits, records (10) | 3 | 5 | 4 | 2 | 1 | 1 |
| 5. Absolute annual cost at ~100 employees (10) | 2 | 3 | 5 | 3 | 1 | 2 |
| 6. Time to usable capability (10) | 1 | 3 | 5 | 4 | 3 | 4 |
| 7. Continuity and retained knowledge (10) | 5 | 2 | 3 | 3 | 1 | 2 |
| 8. Multi-province reach (10) | 2 | 4 | 4 | 2 | 5 | 3 |
| Weighted total | 2.70 | 3.15 | 3.00 | 3.05 | 2.75 | 2.80 |
| Rank | 6 | 1 | 3 | 2 | 5 | 4 |
Criterion 1 goes to the PEO and ASO category, and it is the heaviest row on the board. Its core product — payroll, vacation accrual, public-holiday calculation, hours tracking, record keeping — is exactly the failure list the enforcement data says generates claims. We design policy and own the judgement calls; someone else runs the payroll engine. On this row that is a weakness, not a positioning statement.
Criterion 2 goes to the employment law firm. When a complaint involves a senior person, the first question a reviewer asks is who the investigator answers to, and an incumbent — including us, when we already hold the HR mandate — has a relationship to protect. Our standing rule: where independence could reasonably be questioned, we recommend a separate investigator or firm, and the practitioner who handled the underlying matter does not investigate it. Buy independence from someone who has nothing else to lose.
Criterion 4 goes to the PEO and ASO category again. Bundled payroll, benefits administration and records is what that model is for.
Criteria 5 and 6 both go to the HR software platform: lowest absolute annual cost of the six by a wide margin, fastest to switch on. If the problem is that nobody has written a policy or tracked leave, a platform solves much of it in a fortnight. Come back when the problem is a decision rather than a document.
Criterion 7 goes to the full-time hire — the strongest single-cell score in the table. Someone in the building every day accumulates the reasoning, the relationships and the informal history, and no external provider replicates that — any that claims to is overselling.
Criterion 8 goes to the national consultancy. If you are hiring in four provinces next year, a firm with a bench in each of them is not a luxury.
Our category wins criterion 3, and that is the whole argument for it. Someone who has run org design, done executive exits and sat through a restructuring, reachable in the week the question comes up, without carrying that seniority as a permanent fixed cost. A real and narrow claim: worth 15 points on our weights, not 100.
The spread across six categories is 2.70 to 3.15 — on our own weights, the PEO and ASO category first, our category second, a software platform third, inside half a point of each other.
That narrowness is not a failure of the model. It is the answer. No category dominates this decision, which means the weights are doing almost all of the work, which means the only useful version of this comparison is the one you reweight yourself.
Three reweightings, computed on the same scores:
| If you move… | The new ranking | What changed |
|---|---|---|
| 10 points from criterion 1 to criterion 3 | D. Fractional / embedded (3.25), then F, then E | Senior judgement now outweighs transactional coverage — the profile of a company mid-restructuring or facing a senior-level conduct problem |
| 10 points from criterion 3 to criterion 5 | C. HR platform (3.40), then B (3.35) | Cost becomes the binding constraint, and systems beat people |
| Criterion 8 to 0 and criterion 1 to 15, both moved into criterion 2 (now 30) | F. Employment law firm (3.15), then D (3.00) | A single-province employer with a live senior-level allegation should be talking to counsel, not to a vendor |
If any of those three descriptions is you, the table has already told you what to do, and in two of the three cases it is not us.
A single choice is a bit artificial: the six options are not mutually exclusive. The common mid-market configuration in Ontario is a platform for records and workflow, a payroll provider or PEO for the transactional engine, one internal HR person for daily continuity, an external senior HR provider for the decisions that person should not have to make alone, and employment counsel for the matters that are legal rather than operational. That is five of the six, and usually cheaper than it sounds, because each component is scoped to what it is good at. The expensive configurations are the ones that stretch a single provider across all eight criteria — a full-time generalist expected to be a CHRO, or a consultancy retained for administration.
Two decision rules follow from the scorecard, and they are worth more than the ranking:
Whatever you buy, some duties stay with the employer as a matter of statute, and a provider's coverage of them is a question to ask in writing rather than to assume.
Ontario's Occupational Health and Safety Act requires an employer to ensure that an investigation appropriate in the circumstances is conducted into incidents and complaints of workplace harassment. The Ministry of Labour's workplace harassment investigations guidance, updated in July 2026, states that an incident should be investigated as soon as possible, ideally within 90 days or less, unless there is a compelling reason a longer investigation is needed. It also states that the person conducting the investigation should not be involved in the incident and should not be under the direct control of the alleged harasser, that the results of the investigation and any corrective action must be provided in writing to both the worker who allegedly experienced the harassment and the alleged harasser where they are a worker of the employer, and that a ministry inspector may order an investigation by an impartial person, at the employer's expense, in defined circumstances.
Note also which framework applies to you before you buy anything. Ontario provincially regulated workplaces investigate under the OHSA; federally regulated workplaces follow the Canada Labour Code framework introduced by Bill C-65. These are two different regimes for two different sets of employers, and a provider's Ontario competence does not transfer to a federally regulated payroll.
None of the six options removes the duty. Options B and C are the least likely to cover it and the most likely to be assumed to. Ask the question in procurement.
1205 is option D, and the case for us is the criterion that category wins: senior judgement on demand. The situations are specific — a restructuring that has to be planned and executed cleanly, a first executive-level termination, an org design the company has outgrown, a people function with capable administration but nobody senior enough to tell the CEO no. In those weeks the need is not a platform or a payroll engine; it is a senior practitioner inside the organisation, part-time, who has done the thing before.
The person you meet is the person who does the work. Named-operator continuity for the whole engagement, with no rotation behind the signature — in a part-time seat, the practitioner is the product.
The Ontario employment context is native, not researched. ESA, OHSA, provincial variation — the decisions this seat carries touch them weekly, and we are built in Ontario for exactly that work.
Execution is owned, not advised on. Policies implemented, exits handled, decisions carried inside your organisation — not a recommendation deck handed over at the end.
The firm is checkable. 1205 Consulting Inc. is a federally incorporated Canadian company active since December 2019 and a BBB Accredited Business with an A+ rating, accredited on 28 April 2026. Our principal is an HRPA member, is not a lawyer, and holds no licensed HR designation. Fees are confirmed after the work is scoped rather than published as a standard band — ask early and we will quote precisely.
Our primary HR route is Part-Time HR; practitioner, responsibilities, time commitment and exclusions are confirmed after a fit and availability review.
The scorecard already says it, so here it is in plain terms. If the gap is payroll, benefits and records, a PEO or ASO covers the failure modes Ontario actually enforces — we do not run that engine. If budget is the constraint and the problem is documents rather than decisions, the platform wins on cost and speed. If you need someone in the building every day, a full-time hire beats any part-time arrangement, ours included. If you are hiring across several provinces, a national consultancy's bench beats an Ontario-centred practice. And if a complaint about a senior person is already live, independence outranks familiarity: an employment law firm or an unconnected independent investigator starts cleaner than any incumbent, including us.
If you want a read on which of the six your situation calls for — including when it is not us — describe the situation and you will get an answer on the exposure you are carrying and what to ask the provider before you sign.
Scores were applied to buying models, not to any named provider, and they are our judgement — published so they can be argued with, not measured performance data. We deliberately did not score brand, awards or the quality of anyone's past work, and the cost criterion measures absolute spend only — value is what the other seven measure. Our other comparison guides answer adjacent questions — law firm versus HR investigator and alternatives to a law firm for a workplace investigation compare providers for a single investigation that has already landed, fractional versus full-time versus consulting prices fractional executive seats, and choosing among outsourced HR companies starts after you have decided to outsource — where this article is the upstream capability decision and the only one that includes buying software and hiring someone. Because the weights drive the ranking, rerun the reweightings above against your own constraint before acting on any row of this page.
This article is general information and is not legal advice. Statutory duties, ministry guidance and enforcement practice change, and the right call on a specific matter turns on its facts — confirm current requirements against the Occupational Health and Safety Act, the Employment Standards Act, 2000, and official Ontario guidance, and consult employment counsel on live matters. Scores and weights in this article are 1205 Consulting's judgement, published so they can be argued with, and are not measured performance data about any named provider. 1205 Consulting provides HR advisory and workplace investigation services; we are not a law firm.
Sources for the figures cited above: Ministry of Labour, Immigration, Training and Skills Development, Employment standards enforcement statistics (page updated February 2026; data current as of 6 May 2025) · Ministry of Labour, Immigration, Training and Skills Development, Workplace harassment investigations (updated 6 July 2026) · Employment and Social Development Canada, Job Bank, Manager, human resources (NOC 10011), Ontario wages, prevailing wages updated 19 November 2025, reference period 2023–2024, source Labour Force Survey.
Related reading: Ontario HR and Workplace Conduct: The 2026 Numbers, With Sources · The True Cost of Not Having HR · Fractional CHRO vs. Fractional HR · Outsourced HR for Small Business: When DIY Becomes Dangerous
Part-time HR leadership and employee-relations capacity for employers with Ontario operations, subject to practitioner availability and a written scope.
Employer-side external fact-finding for Ontario workplace matters, accepted only after fit, jurisdiction, conflict, competence, and capacity review.
Scoped strategy and execution support brought into a business-performance mandate when the required leadership and capacity are confirmed.
Every figure on this page comes from Statistics Canada, the Ontario Ministry of Labour, Tribunals Ontario, ISED or Job Bank, is linked to the page it came from, and carries its reference period. It is built to answer one question: how much HR and conduct risk is an Ontario employer actually carrying, and what does covering it cost?
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Twenty-three named providers of AODA and accessibility compliance help in Ontario, grouped into five operating models and scored against eight criteria whose weights we disclose — including the free government tooling that tops our own table. Which obligation is actually binding, which model fits it, and how to rerun the ranking on your weights.
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