Ontario’s Bill 190: Working for Workers Five Act, 2024, introduces new requirements that will reshape how property operators manage washroom maintenance in commercial and industrial buildings.

By 2026, it will no longer be sufficient to rely on unrecorded practices or informal routines. Operators must be able to demonstrate compliance through visible and documented cleaning logs, along with meeting new frequency and inspection standards.

At Mero, we see this as an opportunity for the industry to drive greater consistency, transparency, and operational excellence in washroom maintenance.

This post will explain what the law requires, what compliance options are available, and how operators can take a strategic approach to this transition.

Key Requirements Under Bill 190

July 1, 2025: Phase 1

• Washroom Access: Employers must provide safe, clean, and well-stocked washrooms to all workers, including contract and off-site staff.
• Maintenance Logs: Records must be created documenting each cleaning, restocking, and inspection, including the date, time, and responsible personnel.
• Recordkeeping: These records must be retained for at least one year and provided to Ministry of Labour inspectors upon request.

January 1, 2026: Phase 2

• Cleaning Frequency: Washrooms must be cleaned and maintained at least once per shift, with adjustments based on usage patterns.
• Visible Cleaning Logs: Cleaning logs must be visible and accessible near each washroom, in either digital or physical format. Providing access via QR code or web link to an electronic cleaning log is also acceptable.
• Preventative Maintenance: Operators must implement proactive inspections to identify and resolve functional issues such as leaks, broken fixtures, or ventilation problems.

Why This Matters for Building Operators

The core message is simple: creating, maintaining, and visibly displaying washroom cleaning logs is now a compliance requirement, not an operational best practice.

Failure to meet these requirements could result in additional audits, financial penalties, reputational risk, and heightened scrutiny from Ministry of Labour inspectors.

At the same time, operators have the opportunity to treat this transition as a way to:

• Improve tenant experience through more transparent service
• Strengthen vendor accountability
• Build a more data-driven approach to washroom maintenance

Options for Compliance: What Operators Should Consider

Choosing the Right Approach

For many operators, a hybrid approach may make sense:

• Physical logs for smaller, lower-traffic sites or as an interim solution
• Digital logs for high-traffic buildings, Class A assets, multi-tenant sites, or portfolios where consistency and scalability matter

Next Steps for Operators

Conduct a Readiness Audit

• Review current washroom maintenance practices
• Identify gaps in logging, visibility, record retention, and inspection routines

Evaluate Compliance Solutions

• Determine where physical logs may suffice vs. where digital logging provides greater value
• Align vendors and cleaning teams to new compliance expectations

Build a Transition Plan

• Prioritize high-visibility or high-traffic sites for early digital log implementation
• Establish processes for record monitoring and preventative maintenance documentation

Final Thoughts

Bill 190 represents a major shift in how building operators must manage washroom maintenance and compliance in Ontario.

Taking action by auditing your current state and evaluating available logging solutions will help you stay compliant and enhance service delivery and operational transparency.

As the compliance deadlines approach, Mero will continue providing insights and tools to support operators at every transition stage.