Since 1 July 2025 an Ontario courier dispatching through an app has statutory disclosure and record-keeping duties. Your software either produces those records or you produce them by hand.
Key takeaways
Look past routing and optimisation. For a Canadian courier the features that decide whether the software is fit are: whether it produces the worker records the law now requires, whether it captures a proof of delivery that holds up, whether its customer messaging complies with Canadian telecommunications and anti-spam rules, and whether the personal information it collects is defensible.
Routing engines are broadly comparable. Compliance records are not, and they are the ones that cost money when they are missing.
Ontario’s Digital Platform Workers’ Rights Act, 2022 came into force on 1 July 2025 and sets out rights for workers performing digital platform work — defined to include ride share, delivery or courier services offered through an online platform — and it applies regardless of whether they are employees or independent contractors.
The disclosure duties are specific and are things a dispatch system either emits or does not. A worker has the right to receive, in writing, within 24 hours of getting access to the platform, the factors used in deciding whether work is offered and how they are applied, how pay is calculated, the regular pay period and pay day, whether tips are collected and how, and whether a performance rating system is used and what its consequences are. When a work assignment is offered, the worker must be told the estimated pay and how it was calculated. Within 24 hours of completing an assignment, the worker must be told the actual amount payable, tips collected and payable, how pay was calculated including any distance or mileage used, when payment will be made, expenses, any premium, and the start and end times.
There is also a records obligation that reads like a database schema. Operators must record each worker’s name and address, amounts paid for each assignment with a description of each payment including tips, and the dates access was given and each assignment was performed including the times each assignment started and finished; those records may be kept by someone else on the operator’s behalf but must be kept for three years after the worker’s access to the platform is terminated and be available for inspection.
Two further points shape the software. Removal from a platform requires a written explanation and two weeks’ written notice for any removal lasting 24 hours or more, subject to defined exceptions. And a claim must generally be filed within two years of the alleged violation — so a three-year retention rule is the floor, not a nicety.
Courier POD is usually a signature scrawl and a photograph. That is fine until somebody disputes it. The useful benchmark is what a bill of lading is required to show for freight in British Columbia: consignor name and address, date of shipment, originating point, carrier names, consignee name and address, destination, and particulars of the goods including weight and description, plus a statement of whether the goods were received in apparent good order and condition.
Courier work rarely falls under those provisions, but the list is the right specification for a POD record: who, what, when, where, and condition on receipt. Add the geolocation and timestamp of capture. Canadian courts have an established route for admitting electronic records such as messages and emails, so the question is not whether a digital POD counts — it is whether yours records enough to be worth producing.
Delivery notifications are the most-used feature in any courier system and the least examined. If a message is a commercial electronic message, Canada’s anti-spam legislation applies and the CRTC is among the bodies enforcing it; whether you rely on implied or express consent changes what you have to be able to show.
If the system places calls with a pre-recorded or synthesised voice, it is an automatic dialing-announcing device. The CRTC defines an ADAD as equipment capable of storing or producing telephone numbers used to convey a pre-recorded or synthesized voice message. Even where there is no attempt to solicit, such calls are restricted to 9:00 a.m. to 9:30 p.m. on weekdays and 10:00 a.m. to 6:00 p.m. at weekends in the recipient’s local time, must begin with a message identifying the caller and the purpose with a valid email or postal address and a local or toll-free number, must display an originating number, may not use sequential dialling, and must disconnect within ten seconds of the recipient hanging up. Those contact details must remain valid for at least sixty days after the call.
An AI voice agent confirming a delivery window sits inside all of that. It is permitted; it is not unregulated.
A courier system collects three streams of personal information: the recipient’s name and address, the driver’s location and behaviour, and photographs that frequently include somebody’s home. PIPEDA’s requirements in brief set the baseline for commercial activity, and whether it applies to your business is worth settling before you configure retention.
On the driver side, the Office of the Privacy Commissioner’s guidance on privacy in the workplace is the reference point for GPS and in-cab video. In Ontario, employers of a certain size also have obligations around a written electronic monitoring policy. Configure the software to collect the minimum that does the job, and set photograph retention deliberately rather than leaving it at “forever”.
Courier businesses run on a mix of employees, contractors and platform workers, and the Ontario statute above deliberately applies regardless of status. That does not make the status question go away for everything else — payroll, notice and workers’ compensation all still turn on it, and the classification test is a legal analysis, not a setting in a dispatch tool.
One scope note worth checking against your fleet: federal hours-of-service rules and the move from paper daily logs to certified electronic logging devices apply to commercial motor vehicle drivers, and Transport Canada published the amendments to the Commercial Vehicle Drivers Hours of Service Regulations in June 2019. Most courier vans sit outside that world; a five-tonne straight truck added to the fleet may not. Confirm where your vehicles fall before assuming the dispatch tool is the only record you need.
Worked example: a nine-van courier in Ottawa
Nine vans, four employee drivers, five drivers engaged through the company’s own app. Same-day and scheduled work for law firms, clinics and a parts distributor.
The evaluation started with routing and ended somewhere else. Two of the three shortlisted systems could not produce, per assignment, the start and end time, the amount payable, tips collected, the distance used in the calculation and the expense component — which is close to the list Ontario requires an operator to record and keep for three years.
The chosen system exports that record on a schedule, retains delivery photographs for a defined period rather than indefinitely, and sends customer notifications by SMS with a documented consent trail. The planned AI callback feature was deferred until the ADAD conditions — hours, identification message, number display, ten-second disconnect — could be configured rather than assumed.
The saving was not in routing. It was that the payroll and disclosure records stopped being reconstructed by hand from three systems at month end.
Yes, for digital platform work. Ontario states the rights apply to workers who provide ride share, delivery or courier services through an online platform regardless of whether they are employees or independent contractors.
It is one element. Pair it with the timestamp, the geolocation, the recipient name where taken, and a condition note. A photograph alone tells you a parcel existed somewhere, not that it reached the right person.
A message about a delivery the customer has already arranged is different in character from marketing. The line is whether it is a commercial electronic message, which is why the CRTC’s anti-spam material is worth reading before the flow is built, not after.
Transparency is the practical answer, and in Ontario there are specific obligations around a written electronic monitoring policy. The OPC’s workplace guidance is the better starting point than a vendor’s feature list.
It becomes the diligence list. Worker classification, retained records and messaging consent are all standard enquiries — the sister-firm overview of buying or selling a courier or last-mile delivery business covers the ground.
A 30-minute call is enough to tell you whether AI pays for itself in your back office.
