Most compliance roundups are written for companies that look nothing like a dealership. This one isn't. Here's what's actually landing across Canada and the US between now and January 1, what it means for a store, and what you can safely ignore.

Already in force the three most dealers have missed

OSHA's heat program now names automotive repair by NAICS code. The National Emphasis Program on heat was renewed on April 10, 2026 and runs to 2031. Several early-2026 bulletins reported it lapsing. It didn't. The target list now includes NAICS 8111 (Automotive Repair and Maintenance) and 4412 (Other Motor Vehicle Dealers — RV, powersports, marine). Indoor heat counts, which means service bays, body shops, parts warehouses and detail bays. On any day the heat index hits 80°F, inspectors conducting any inspection are required to ask about your heat prevention program and record the answers.

The I-9 rules changed without a rule change. On March 16, 2026, ICE reissued its Form I-9 Inspection Fact Sheet and moved a large category of errors from “technical” to“substantive.” Technical errors came with a ten-business-day window to fix them. Substantive errors are fineable on the spot. Now substantive: a missing date of birth, a missing first day of employment, incomplete document data inSection 2, missing preparer or translator details. This applies to every I-9 in your filing cabinet, not just new ones.

The CARS Rule is dead — and that made things worse, not better. The Fifth Circuit vacated it. The FTC moved enforcement to Section 5 of the FTC Act, sent warning letters to 97 dealerships in March 2026, and published the recipients' names on May 28. Advertised pricing that omits mandatory fees, pricing contingent on dealer financing, and mandatory add-ons are the practices being targeted.

October 1

Minimum wage rises in five provinces.

‍Ontario $17.60 to $17.95;

Prince Edward Island $17.00 to $17.30;

Nova Scotia $16.75 to $17.00;

Manitoba $16.00 to $16.40;

Saskatchewan $15.35 to $15.70.

Ontario's student rate moves from $16.60 to $16.90 for employees under 18 working 28 hours a week or less during the school term — the rate most stores staff their lots and detail bays on.

Connecticut requires you to publish an explanation of your pay codes. Employers with 100 or more employees must write a guide explaining at least ten of the pay codes appearing on employee pay checks, post it on the company website, and provide it in English, Spanish and any other language common in the workforce. Nobody has more pay codes than a dealership — flag hours, draw, draw recovery, unit commission, gross-profit commission, chargebacks, spiffs, CSI bonus, non-productive time. This law makes you explain all of it publicly.

Connecticut's training repayment ban loses its size threshold. It already applied at 26 or more employees. Now it covers every employer, with no exception for training or credentials.

Connecticut postings must describe benefits, not just pay.

November 1

BC pay transparency reporting drops to 50 employees. If you have 50 or more employees in British Columbia, you publish a report with mean and median hourly pay, overtime pay and bonus pay broken out by gender. The binding constraint isn't the math, it's the gender self-identification data, which you need lead time to collect. Expect the numbers to look unflattering for structural reasons — commissioned sales and flat-rate technician roles skew male and high-earning. Prepare the narrative alongside the report.

November 6

BC drops the blanket “clean shaven” respirator rule. Fit testing and seal checks stay. Anything interfering with the seal is now managed case by case rather than by blanket policy. If your body shop respiratory program still says “must be clean shaven,” it's out of step with the regulation and is also your most likely source of a human rights complaint.

December

December 31 — Ontario AODA compliance report. Private organizations with 20 or more employees in Ontario file the accessibility self-assessment. Note the counting rule: it's 20 employees per legal entity. Most dealer groups are several filers, not one.

Before month end — Maryland employers must notify employees in writing before FAMLI payroll withholding begins January 1. Easy to miss, and it has to land before the first deduction.

January 1

Minimum wage moves again. Thirteen states index to inflation and adjust on January 1. Michigan and Virginia raise by legislated step, Nebraska by a new fixed 1.75% escalator. Rates publish between October and December, so build the budget line now and confirm the figures in December.

Illinois bans the reflexive driver's licence requirement. You can no longer require a driver's licence in a job posting unless driving is an essential function of that job and a business necessity, and the posting must justify it. Dealerships put this on nearly every posting. For a porter or lot attendant it's defensible. For a BDC rep, cashier or parts counter role it won't be. Audit your Illinois templates before January.

Illinois also adds menopause accommodation obligations and paid jury duty leave for employers over 25. For flat-rate and commissioned staff, build a defensible“standard rate” calculation into the policy now.

Ontario is set to ban charging employees for uniforms. Bill 105 would prohibit requiring employees to pay for uniforms or their laundering and repair. Technician uniform rental programs and payroll deductions for branded apparel are exactly what this reaches. It was at third reading at last check — confirm Royal Assent before you change anything.

Connecticut paid sick leave extends to employers with a single employee. Colorado's replacement AI law takes effect with notice and explanation duties on employers using AI in employment decisions. Maryland FAMLI contributions begin at 0.90%of covered wages. And exempt salary thresholds rise in California to $72,384 and in Washington to $82,321 (under 51 employees) or $91,468 (51 and over) — relevant to your GMs, sales managers, service managers and controllers, not to technicians.

Two things you can stop doing

Most dealership rooftops are not required to submit OSHA 300A data electronically. NAICS4411 and 8111 aren't on the lists that trigger it — only 4413 (parts and tire stores) is, along with any establishment over 250 employees. You still keep the log and post the 300A every year. If your team is e-submitting for every store, that's wasted work.

The federal overtime salary threshold fight is over. DOL rescinded the 2024 rule in May 2026. The threshold is back to $684 a week with no automatic indexing. Watch your state thresholds instead.

Where to start

Two dates are close enough to matter this month. BC's pay transparency report is due November 1 and needs gender self-identification data you may not have collected yet. Ontario's AODA filing is due December 31 and needs a separate report for each legal entity, which for most groups means more than one.

Neither is difficult. Both take longer than you'd think if you start in the last week.