Ontario's 2026-2027 Healthcare Compliance Campaign: What the IRS Focus Means for Your Workplace Violence and Harassment Program

On April 1, 2026, Ontario's Ministry of Labour, Immigration, Training and Skills Development (MLITSD) opened a new compliance year — and the headline campaign for health and community care is squarely targeted at the Internal Responsibility System (IRS). The campaign runs through March 31, 2027 and combines education, awareness, and enforcement, as confirmed in WSPS's 2025-26 MLITSD initiatives bulletin.

For HR leaders in hospitals, long-term care, retirement homes, group homes, home care, and community-care providers, that single sentence is more consequential than it sounds. An IRS-focused inspection is not a checklist audit. It is a stress test of whether your harassment and violence-prevention program actually works — top to bottom — when an inspector starts asking workers what they would do if they witnessed something and what they have seen happen when someone has spoken up.

This is the second consecutive year MLITSD has put healthcare in the campaign window. The 2025-2026 wave focused explicitly on workplace violence prevention — inspectors checking that workers were "protected from the hazard of workplace violence" in hospitals, long-term care homes, retirement homes, group homes, treatment clinics, specialized services, and home healthcare. The 2026-2027 wave broadens the lens: not just whether the program exists, but whether the IRS is functioning around it.

Key Takeaways

• MLITSD is back in healthcare for a second straight year — this time testing the IRS, not just the program documents.
• Inspectors will probe whether workers, supervisors, JHSCs, and leadership all know their OHSA roles for harassment and violence — and whether information is actually moving up and down the chain.
• "We have a policy" is not a defence. Inspectors are looking for evidence of training, risk assessment, documented investigations, and follow-through.
• Healthcare's existing duty under section 32.0.7 of the OHSA — to investigate every incident and complaint of workplace harassment — sits at the centre of this campaign. The post-Metrolinx expansion of that duty makes the standard higher than it was a year ago.
• Penalties under the OHSA Administrative Monetary Penalty regime, in force since O. Reg. 364/25, now apply without prosecution. Non-compliance is faster and cheaper for the Ministry to punish.

What the IRS Actually Is — and Why Inspectors Care

The Internal Responsibility System is the philosophical spine of Ontario's Occupational Health and Safety Act. It assigns every person in the workplace a defined set of responsibilities for health and safety: workers report hazards, supervisors act on them, employers ensure systems and training are in place, and the Joint Health and Safety Committee holds the whole thing accountable.

For workplace harassment and violence, the IRS expectations are concrete:

• Workers are expected to recognize harassment and violence hazards, report incidents and concerns, and participate in the program.
• Supervisors are expected to know the program, enforce it, take complaints seriously, and document what they do with them.
• Employers are expected to maintain a written program under section 32.0.6 of the OHSA, conduct risk assessments under section 32.0.3, train all workers, and investigate every incident and complaint under section 32.0.7.
• JHSCs / Health and Safety Representatives are expected to be consulted on the program, review the assessment, and have line of sight into how complaints are being handled at an aggregate level.

An IRS inspection is a deliberate cross-check of whether each of those layers is working. Inspectors interview frontline workers without management present. They ask: "Have you been trained? Do you know who to report to? Have you ever reported something? What happened?" They then talk to the supervisor and the JHSC and look for the same story to come back. When the answers diverge, the inspector knows the program is documentary — not operational.

The Ontario Nurses' Association's guide to workplace violence and harassment describes what worker-side participation in a functioning IRS looks like in the healthcare context — and it is a useful mirror for employers preparing for inspection.

Why This Year Is Different from Last Year

Three things have changed since the 2025-2026 campaign closed.

First, the post-Metrolinx duty to investigate is now settled law. As we analyzed in detail, the Ontario Divisional Court confirmed that section 32.0.7 of the OHSA requires investigation of incidents and complaints, not just formal written complaints. A worker telling a charge nurse that a patient's family member made a sexual comment is an incident. The duty to investigate triggers regardless of whether anyone files paperwork. In a sector where most harassment incidents are reported informally — patient-on-worker, family-on-worker, peer-on-peer — this expansion fundamentally changes the inspection conversation.

Second, Bokhari v. Top Medical Transportation Services, 2026 ONSC 1073 raised the litigation cost of a poor investigation. As we covered last week, the Divisional Court has constrained the HRTO's ability to dismiss applications at the door. More applications will now reach merits hearings. Healthcare employers — heavy users of the HRTO as a defence forum — will spend more time and money defending claims regardless of whether the underlying incident was investigated. The cheap exit is gone.

Third, OHSA Administrative Monetary Penalties are operational. As of O. Reg. 364/25, the Ministry can issue monetary penalties for prescribed violations without going through the courts. That changes the speed of enforcement: an inspector can now leave a workplace with a penalty in hand, not just an order. McCarthy Tétrault's analysis of the AMP regime lays out the practical effect.

The combination matters. Healthcare employers heading into this campaign year face higher substantive expectations, faster enforcement on non-compliance, and a more expensive litigation backdrop if a complaint reaches the HRTO. The campaign is the trigger; Metrolinx, Bokhari, and the AMP regime are the amplifier.

What Inspectors Will Look For

Based on the pattern of recent campaigns, the Ontario government's published inspection results from prior workplace violence prevention initiatives, and Hicks Morley's healthcare-sector commentary, expect inspectors to test the following:

Program documents — A current, dated workplace violence policy and a current, dated workplace harassment policy. A written program for each. Evidence of annual review. Evidence the JHSC has been consulted.

Risk assessments — A documented workplace violence risk assessment under section 32.0.3. Specific to the workplace, not a head-office template. Updated when circumstances changed materially (e.g., a new patient population, a new shift pattern, a recent incident).

Training records — Worker training records under section 32.0.6(1), with dates, attendance, and content. Supervisors should be able to articulate, from memory, the steps they take when a worker reports an incident.

Complaint and investigation records — Logs of every reported incident, formal or informal. Investigation files for each. Documented outcomes, including how the complainant and respondent were informed. A pattern of "no incidents reported" in a busy hospital unit is a red flag, not a clean record.

Reprisal protections — Evidence that workers know they cannot be punished for reporting. The OLRB's recent reprisal awards, including the auto shop reprisal decision covered by HR Law Canada, are a reminder that reprisal exposure is independent of the underlying complaint.

Communication up and down the IRS — Worker interviews that match supervisor interviews that match the JHSC's understanding of what is happening on the floor.

What to Do This Quarter

1. Run an internal mock IRS inspection. Ideally external. Walk a unit. Interview five frontline workers without management present. Ask the same questions an inspector would ask. Compare what you hear to your program documents. The gap is your work order. WSPS's healthcare resources include sector-specific tools that mirror inspector lines of inquiry.

2. Refresh your harassment and violence risk assessment. If the document is more than a year old, it is stale. If it does not name specific patient populations, specific shifts, specific physical locations, or specific roles as elevated-risk, it is a template. Update it with current incident data and JHSC input.

3. Audit your investigation records against the post-Metrolinx standard. Pull the last 12 months of harassment and violence incident reports. For each one, confirm: Was an investigation conducted? Was it documented? Were the parties informed of the outcome in writing? If the answer to any is no, you have a section 32.0.7 exposure. The post-Metrolinx standard is described in Sherrard Kuzz's commentary on the duty to investigate.

4. Verify the IRS chain. Ensure each layer can describe its responsibilities — workers, supervisors, JHSC, senior leadership — without reading from a card. If they cannot, training has failed and the IRS is decorative.

5. Confirm reprisal protections are explicit and known. Section 50 of the OHSA prohibits reprisals against workers who exercise their rights. Workers should know this and be able to point to where it is communicated. If your reprisal language is buried on page 14 of an HR handbook, fix it.

Where 1205 Consulting Fits

1205 Consulting designs and audits OHSA harassment and violence prevention programs for Ontario healthcare and community-care employers — and serves as external investigator on incidents that carry reputational, regulatory, or litigation risk. The IRS-focused inspection model rewards employers who can prove their program is operational, not just documented. Most program failures we see are not policy failures. They are training, intake, and follow-through failures that an inspector finds in a 20-minute worker interview.

If your healthcare or community-care organization has not stress-tested its program against the new 2026-2027 inspection framework, book a call or learn more about our workplace investigations and HR services practices.

For broader context on the recent Ontario rulings shaping how investigations are run and judged, see our coverage of the post-Metrolinx duty to investigate, the post-Bokhari HRTO screening change, and the OHSA Administrative Monetary Penalty regime.

This article provides general information and is not legal advice. Healthcare and community-care employers should consult employment counsel for advice specific to their circumstances.