AODA Requirements for Ontario Businesses by Size

What are the AODA requirements?

Every Ontario business with at least one employee must have accessibility policies, train its people, provide accessible customer service and offer accessible formats on request. At 20 employees you add a compliance report. At 50 you add documented policies, a multi-year plan, training records and a website that meets WCAG 2.0 Level AA.

The regulation is written for everyone from a two-person bakery to a hospital, so it reads like it. Here is the version for businesses and non-profits, sorted by the only number that matters: how many people you employ in Ontario.

How to count your employees

Ontario's guidance says to include:

full-time, part-time and seasonal employees
contract workers you pay a wage or salary to and direct

And to leave out:

employees outside Ontario
volunteers
independent contractors

Leaving someone out of the count does not leave them out of the rules. If a volunteer or contractor serves the public on your behalf, you still have to make sure they follow the standards, which usually means training them.

What applies to your business?

How many employees does your business or non-profit have in Ontario?

1 to 19 employees20 to 49 employees50 or more employees

7 things apply to a business or non-profit with 1 to 19 employees:

Have accessibility policies
Policies on how you will meet the accessibility standards. Writing them down is optional under 50 employees, but a good idea.
O. Reg. 191/11, s. 3
Train everyone who works for you
Employees, volunteers, anyone who helps set policy and anyone serving customers on your behalf. On the standards that fit their job and on the Human Rights Code. As soon as practicable, and again when policies change.
s. 7
Provide accessible customer service
Allow assistive devices, welcome service animals and support persons, give notice of temporary disruptions, and take feedback in accessible ways.
Part IV.2
Offer accessible formats on request, and say so publicly
Provide information and communication supports in a format that works for the person, in a timely way, at no extra cost, and let the public know they are available.
s. 12
Make feedback processes accessible
If you take feedback, people with disabilities must be able to give it, and the public must know accessible formats are available.
s. 11
Follow the employment standards
Accessible recruitment, telling staff about supports, accessible formats for employees and individual workplace emergency response information where needed.
Part III
Consider accessibility in kiosks and new public spaces
Have regard to accessibility when buying self-service kiosks. Design of Public Spaces rules apply to new or redeveloped spaces such as service counters and waiting areas.
s. 6, Part IV.1

No employees in Ontario? Ontario says you are exempt. Designated public sector organizations follow different rules. This is a summary, not legal advice.

Duties for every business with one or more employees

Have accessibility policies
Policies on how you will meet the accessibility standards. Writing them down is optional under 50 employees, but a good idea.
O. Reg. 191/11, s. 3
Train everyone who works for you
Employees, volunteers, anyone who helps set policy and anyone serving customers on your behalf. On the standards that fit their job and on the Human Rights Code. As soon as practicable, and again when policies change.
O. Reg. 191/11, s. 7
Provide accessible customer service
Allow assistive devices, welcome service animals and support persons, give notice of temporary disruptions, and take feedback in accessible ways.
O. Reg. 191/11, Part IV.2
Offer accessible formats on request, and say so publicly
Provide information and communication supports in a format that works for the person, in a timely way, at no extra cost, and let the public know they are available.
O. Reg. 191/11, s. 12
Make feedback processes accessible
If you take feedback, people with disabilities must be able to give it, and the public must know accessible formats are available.
O. Reg. 191/11, s. 11
Follow the employment standards
Accessible recruitment, telling staff about supports, accessible formats for employees and individual workplace emergency response information where needed.
O. Reg. 191/11, Part III
Consider accessibility in kiosks and new public spaces
Have regard to accessibility when buying self-service kiosks. Design of Public Spaces rules apply to new or redeveloped spaces such as service counters and waiting areas.
O. Reg. 191/11, s. 6, Part IV.1

What changes at 20 employees

File an accessibility compliance report every three years
Through Ontario's Accessibility Compliance Reporting Portal, certified by a senior officer. The current deadline is December 31, 2026.
AODA s. 14; Ontario.ca

AODA compliance reports are due December 31, 2026.

Applies to Ontario businesses and non-profits with 20 or more employees.

How to file

What changes at 50 employees

At 50 you become a "large organization" in the regulation's terms. Most of the extra work is writing things down and publishing them, plus one technical job: the website.

Document your policies and make them public
Include a statement of organizational commitment, publish the documents and provide them in an accessible format on request.
O. Reg. 191/11, s. 3 (2), (3)
Keep a multi-year accessibility plan
Document it, post it on your website and review it at least once every five years.
O. Reg. 191/11, s. 4
Make your public website meet WCAG 2.0 Level AA
All internet websites and web content published after January 1, 2012, except live captions and pre-recorded audio description.
O. Reg. 191/11, s. 14
Keep training records
Dates training was given and how many people took it.
O. Reg. 191/11, s. 7 (5)
Document individual accommodation and return-to-work processes
A written process for individual accommodation plans and a documented return-to-work process for employees absent due to a disability.
O. Reg. 191/11, s. 28, 29
Document customer service policies and processes
Written policies, the temporary disruption steps and the feedback process, available to anyone on request.
O. Reg. 191/11, s. 80.46 to 80.50

The website rule is the one most businesses cannot do in-house. The AODA website requirements page explains it, and the compliance examples show what it looks like in practice.

A one-page AODA compliance checklist

Work down the list. Stop at your size.

Count Ontario employees and write the number down with the date.
Write your accessibility policies, even if you are not required to publish them.
Train staff, volunteers and contractors. The free Ontario modules are fine for most roles.
Add an accessible formats and communication supports notice to your website and contact page.
Check that your feedback form, phone line or email works for people with disabilities.
Brief staff on service animals, support persons and assistive devices.
Plan how you will post notice of temporary disruptions, like a closed accessible entrance.
20+: file the compliance report by December 31, 2026.
50+: publish documented policies and a multi-year plan.
50+: keep training records.
50+: test the website against WCAG 2.0 Level AA and fix what fails.

Ontario also publishes an interactive Accessibility Standards Checklist (opens in a new tab) (a PDF you download and open in Adobe Reader). It is worth running before you file.

Questions about AODA requirements

How do I count employees for the AODA?

Count full-time, part-time, seasonal and contract workers in Ontario. Do not count employees outside Ontario, volunteers or independent contractors. You are still responsible for making sure volunteers and contractors who serve people on your behalf follow the standards.

What does a business with fewer than 20 employees have to do?

Create accessibility policies, train employees and volunteers, provide accessible customer service, offer accessible formats and communication supports on request and tell the public you do, make feedback processes accessible, and follow the employment rules. You do not file a compliance report.

Do I need a multi-year accessibility plan?

Large organizations (50 or more employees in Ontario) must create, document and follow a multi-year accessibility plan, post it on their website and review it at least once every five years. Smaller businesses do not have to, though it is a sensible way to organize the work.

Do my accessibility policies have to be written down?

If you have 50 or more employees, yes. You must document them, include a statement of commitment, make them public and provide them in an accessible format on request. With fewer than 50 employees you must still have policies, but Ontario does not require you to document them.

Does the AODA website rule apply to small businesses?

The WCAG 2.0 Level AA website requirement applies to businesses and non-profits with 50 or more employees and to the designated public sector. Smaller businesses still have to provide information in an accessible format on request, and an inaccessible site still turns customers away.

Official sources

Checked on November 5, 2026.

Government of Ontario

Ontario laws (e-Laws)

Got 50 or more employees and a website nobody has tested?

We check it against WCAG 2.0 Level AA by hand, fix the issues and document the work for your records.

See AODA website compliance

Continue the AODA Guide

AODA Compliance Report 2026: Who Files by December 31 and How

Ontario businesses with 20+ employees file by December 31, 2026. What you need, the portal steps and what your senior officer certifies.

AODA Compliance Examples: What It Looks Like in Practice

Before-and-after website code mapped to WCAG 2.0 AA, plus sample accessible formats, feedback and disruption notices to adapt.

AODA Website Accessibility Requirements for Ontario Businesses

Does AODA apply to your website? The 50-employee threshold, WCAG 2.0 AA, what smaller businesses should know, and a starting-point tool.