Don’t Lose Your Enforceable Termination Clause to the Substratum Doctrine

If you’re an employer or HR representative well-acquainted with the realm of employment law blogs, you’ve undoubtedly encountered a myriad of cautionary tales about the perils of contracting errors.  The blogs about this topic are countless – and for good reason! The significance of getting contracts right cannot be overstated, as a single mistake could potentially lead to substantial liabilities for your organization. An omitted phrase or a misused word within a termination clause could be the deciding factor between an 8-week statutory notice obligation and a hefty 24-month damages award.

However, let’s assume that you’ve taken every precaution. You’ve carefully reviewed your contracts, consulted legal experts, and you’re confident that your termination clauses are impeccably drafted. Is there still a risk that a court would refuse to enforce that termination clause?  The answer, perhaps unsurprisingly, is yes.  Even with meticulous drafting, there’s a legal principle that could potentially invalidate your termination clause – the Substratum Doctrine.

The substratum doctrine can be applied when a court finds that an employment relationship has changed so substantially since the contract was executed that the terms of the agreement should no longer be allowed to apply.  This can happen when an employee’s responsibilities increase over time.  Take, for example, an employee who was originally hired as a junior sales associate.  That employee executes an employment contract at the time of hiring that includes an enforceable termination provision.  If, over time, they prove valuable to the company then they might be promoted into a sales manager position in which their primary responsibility is managing other salespeople. If they have not been provided with a new employment contract, then it is possible that the basis of the original contract has changed so substantially (from making sales to managing employees) that a court could refuse to enforce the termination clause of the original contract. This can result in a significant unexpected liability if the employer eventually needs to terminate the employee.

Factors that have tended to support the application of the substratum doctrine include:

  • Major changes to the employee’s regular duties
  • A change in position title
  • Substantial increases in compensation and/or changes in the type of compensation provided
  • Changes in reporting structure
  • A long-term of service

Employers should ensure that their contracts expressly provide that termination provisions will survive substantial changes to their position, responsibilities, and pay, as this can prevent the application of the substratum doctrine.1 Employers should also regularly assess and update contracts when substantial changes occur within an employee’s role. While it’s natural for businesses to evolve and adapt, these changes can inadvertently introduce legal vulnerabilities.  As roles transform, so should the contractual agreements that underpin them.  A short consultation with your employment lawyer to assess the relevant facts and prepare a fresh contract (if required) could result in massive savings in the long run.  

If you need help in preparing or updating your Canadian employment contracts, get in touch with our incredible team today!

1Celestini v. Shoplogix Inc., 2023 ONCA 131, para 35

Share the Post:

Related Posts

Blue alarm clock representing timing and Ontario employment termination clauses after Baker

“At Any Time” Gets Its Time: Is There Any Certainty for Ontario Employers After Baker? 

Ontario employers finally have more guidance on employment termination clauses. In Baker v Van Dolder’s Home Team Inc.; Li v Wayfair Canada ULC, the Ontario Court of Appeal upheld clauses using “at any time” and “for any reason.”

But Baker doesn’t give every employment contract a free pass. We unpack what the decision means for employers reviewing termination language today.

Read More »
Hands typing on a keyboard in front of illuminated computer screens, representing virtual workplace communication and online workplace misconduct.

Virtual Harassment: When Workplace Misconduct Happens Online 

Virtual harassment is becoming a growing workplace issue as employee interactions increasingly happen through digital platforms. From group chats and messaging apps to social media activity, online conduct can create real workplace consequences. Learn why employers should update workplace policies, extend conduct expectations beyond the office, and take a proactive approach to investigating and addressing virtual misconduct.

Read More »
December 31, 2026 AODA filing deadline for Ontario employers, displayed beside champagne glasses and gold New Year decorations

The Accessibility Deadline Many Ontario Businesses Don’t Know About: December 31, 2026

Ontario businesses and non-profits with 20 or more employees must file an AODA accessibility compliance report by December 31, 2026. Before certifying compliance, employers should confirm their headcount, complete required training, review accessibility policies and plans, address gaps, and file early. SpringLaw explains the deadline, key requirements, and practical steps Ontario employers should take now, before they file.

Read More »

Contact Us

Thank You For Your Interest. Kindly Complete The Form Below. Our Client Services team will be in touch with further information about our fees and intake process.
[grow-contact-form]