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Ontario’s 2026 AODA Reporting Deadline: What Employers Need to Check Before Filing

Writer: Shilo Burt
Shilo Burt
Oct 8
9 min read

If your business or nonprofit has 20 or more employees in Ontario, December 31, 2026 should be on your compliance calendar.


That is the deadline for your next accessibility compliance report under the Accessibility for Ontarians with Disabilities Act, commonly called the AODA.


The report itself is only one part of the work. Before someone certifies your answers, you need to know whether your hiring practices, training, policies, customer service, and other applicable requirements are actually in place.


If accessibility has been sitting on your “we’ll get to it” list, start now. Here is a practical way to prepare without turning the review into an overwhelming project.

In this article


Who needs to file in 2026?

Businesses and nonprofit organizations with 20 or more employees in Ontario must file an accessibility compliance report by December 31, 2026. These organizations report every three years.


This deadline applies to the business and nonprofit reporting category. Designated public-sector organizations follow a different reporting cycle. If you are unsure which category applies, confirm it before preparing your submission.

Being a nonprofit does not automatically make you a designated public-sector organization.

Here is the basic distinction for businesses and nonprofits:

Ontario employee count

Reporting obligation

Other accessibility requirements

1–19

Generally exempt from filing the accessibility compliance report.

Applicable accessibility standards still apply.

20–49

File by December 31, 2026.

Meet applicable standards for smaller organizations.

50 or more

File by December 31, 2026.

Additional requirements apply, including documented policies, a multi-year accessibility plan, and applicable website requirements.

The reporting exemption for employers with fewer than 20 employees is not a general exemption from accessibility obligations.


Similarly, having no storefront does not automatically remove your obligations. Businesses that provide services to other businesses can still be covered.

How to count your employees

Use your Ontario employee headcount, rather than your number of full-time equivalent positions.


Ontario’s guidance uses the highest employee count at any one time during the previous 12 months. Include full-time, part-time, seasonal, and fixed-term employees.

Do not include employees working outside Ontario, volunteers, or genuine independent contractors.


For example, a business with 15 full-time employees and eight part-time employees in Ontario has 23 employees for this purpose, even if its payroll budget describes the team as fewer than 20 full-time equivalents.


Watch the distinction between a contract employee and an independent contractor. Someone employed on a six-month contract is not automatically an independent contractor.

Also, excluding volunteers or contractors from your headcount does not mean you can ignore accessibility in the services they deliver on your behalf. Relevant training and service obligations can still apply.


If your organization operates across provinces, has grown or downsized, or uses staffing arrangements that make the count unclear, resolve that question early.

What does the accessibility report confirm?

The report asks you to confirm compliance with applicable accessibility requirements.


It is not a substitute for implementing those requirements. Submitting a form does not resolve missing training, an outdated accessibility plan, or a hiring process that does not accommodate applicants.


A useful preparation question is:

If we answer “yes,” what would we use to support that answer?

That might be a policy, training record, recruitment template, documented process, or evidence that a website issue was corrected.


You do not need to attach every internal document to your report. However, organizing your supporting information makes the review more reliable and helps if your organization is asked to demonstrate compliance later.


Assign one person to coordinate preparation and identify the senior officer who will certify the submission.

What to check before filing

The following review focuses on common requirements for businesses and nonprofits. Your activities may create additional obligations, so use Ontario’s accessibility checklist alongside your review.


1. Accessibility policies and ownership

Check whether your accessibility policies describe what your organization actually does.


Can employees identify who handles accommodation requests? Does that person still work there? Are the contact details current? Do managers understand their responsibilities?

Businesses and nonprofits with fewer than 50 employees must have accessibility policies, although the AODA does not generally require these policies to be documented. Writing them down is still a practical way to communicate expectations.


At 50 or more employees, documented policies and a publicly available statement of commitment are required.


Practical step: Review the policy with someone who uses it. Ask them to walk through how they would respond to an accessibility request. If the process only works because one person remembers what to do, clarify it.


2. Staff training

Check who has been trained, what was covered, and whether anyone was missed.


Training must cover accessible customer service, applicable accessibility standards, and the Ontario Human Rights Code as it relates to people with disabilities. It should be appropriate to the person’s duties.


An HR manager needs to understand accessible recruitment and employment practices. Someone serving clients needs to know how to respond to accessibility needs during service delivery.


Relevant employees, volunteers, policy developers, and people providing goods or services on your behalf fall within the training requirements. Provide training as soon as practicable and address relevant policy changes through ongoing training.


For businesses and nonprofits with 50 or more employees, required records include training dates and the number of people trained. Keeping a completion log is useful for smaller organizations, too.


Practical step: Compare your current team list with your training records. Check recent hires, casual employees, and managers. Do not assume a course completed years ago covers every role or policy change.


3. Recruitment and onboarding

Review the recruitment process from advertisement to offer.


Do applicants know accommodation is available? Are candidates selected for an interview or assessment told they can request accommodation? Does someone know how to consult with the candidate and arrange suitable support?


Successful applicants must also be notified of your employee accommodation policies when receiving an offer.


For example, an interview invitation could include:

“Accommodation is available on request for the interview and assessment process. Please contact [name/contact details] so we can discuss what you need.”

That sentence needs a working process behind it.


Practical step: Update your job-posting, interview-invitation, offer, and onboarding templates. Give hiring managers a clear contact for requests rather than expecting each manager to improvise.


4. Employee supports and emergency information

Employees need to know about your policies for supporting people with disabilities. New employees must receive this information, and employees need updates when relevant policies change.


When an employee with a disability requests accessible workplace information, consult with them about a suitable format or communication support.


Individualized emergency response information is also required where an employee’s disability makes it necessary and you are aware of the need. Where someone is designated to assist, share the relevant information with the employee’s consent.


Practical step: Check whether employees know how to request support. Review individualized emergency arrangements when locations or accommodation needs change. Keep personal information restricted to those who need it.


5. Performance management and career development

Accessibility matters after hiring, too.


If you use performance management, career development, advancement, or redeployment processes, take employees’ disability-related accessibility needs and individual accommodation plans into account.


For example, before assessing someone against a new reporting process, consider whether the reporting tool and instructions are accessible to them.


Practical step: Add a prompt to your manager guidance to consider applicable accommodation needs before assessing performance or making development decisions.


6. Customer service and accessible communication

Review how clients, customers, members, or other service users can access your organization.


Check your arrangements for assistive devices, service animals and support persons, accessibility-related feedback, and notices when an accessibility-related service or facility is temporarily unavailable.


Accessible customer service also matters for organizations serving other businesses.

For information and communication requests, consult with the person about their needs. Applicable accessible formats and communication supports must be provided in a timely manner without charging more than for the usual format.


Practical step: Test your contact and feedback channels. Would someone who cannot use the phone have another way to reach you? Does your team know what to do if a client cannot use your usual document format?


7. Additional checks at 50 or more employees

If you have reached 50 Ontario employees, check the additional requirements rather than relying on the system you used as a smaller employer.


These include:

  • A documented multi-year accessibility plan, posted on your website if you have one and reviewed at least every five years.

  • A written process for developing documented individual accommodation plans.

  • A documented return-to-work process for employees returning after disability-related absence who require accommodation.

  • Applicable public website and web-content accessibility requirements.


For covered businesses and nonprofits, the public website standard is WCAG 2.0 Level AA, with specified exceptions, including live captions and pre-recorded audio descriptions. It generally covers public websites and web content published after January 1, 2012 that the organization controls.


Practical step: Ask your web provider to identify the applicable requirements, review the site, and document findings and fixes. A website that looks polished is not proof that it is accessible.


8. Requirements linked to your activities

An HR-focused review will not necessarily cover every obligation.


Depending on your operations, requirements involving public spaces, transportation, education, or training resources may also apply. For example, certain public-space requirements are triggered when covered spaces are newly constructed or redeveloped.


Practical step: Include the people responsible for facilities, technology, and service delivery. Confirm which standards apply to your activities before certifying the report.

A practical preparation schedule

Start early enough to correct gaps. The timing below is a suggested work plan, not a statutory schedule.

Stage

What to do

First week

Confirm your category and headcount. Assign a coordinator and certifier. Review the reporting questions and applicable requirements.

Next two weeks

Gather policies, training information, recruitment templates, and other supporting evidence. Ask operational teams to check their responsibilities.

Following weeks

Complete missing training, update processes, and address identified barriers. Give larger or technical fixes an owner and timeline.

Before submission

Review each answer with the certifier, confirm supporting evidence, and resolve uncertainties.

Before December 31

Submit and retain the confirmation and a record of what was filed.


For a simple internal tracker, use:

Requirement

Current evidence

Gap or action

Owner

Due date

Recruitment accommodation notices

Current posting and interview templates

Add notice to interview invitation

Hiring lead

Set internally

Accessibility training

Completion log

Train recent hires

HR/operations

Set internally

Accessibility plan, if required

Published plan

Review outdated actions

Assigned lead

Set internally

Do not label an item complete just because a document exists. Confirm that the process is being used.

How to submit your report

Once your review is complete:

  1. Gather your legal organization name, nine-digit business number, employee count, and certifier’s contact information.

  2. Open Ontario’s Accessibility Compliance Reporting Portal.

  3. Sign in or create an account.

  4. Begin a new Accessibility Compliance Report submission.

  5. Complete the questions for your organization and arrange certification by someone with legal authority to bind it.

  6. Submit by December 31, 2026.

  7. Retain the submission information and confirmation number in your compliance records.


Ontario sends a confirmation email to the certifier and primary contact after submission.

Plan around holiday absences. If the person who must certify the report is away in late December, arrange the review before they leave.

Common questions from employers


We have fewer than 20 employees. Do we need to do anything?

Yes. You are generally exempt from filing the report, but applicable accessibility requirements still apply. Check your training, recruitment, employee supports, communication, and customer service arrangements.


We have never received an accommodation request. Are we compliant?

The absence of a request does not demonstrate compliance. Requirements such as training and notifying candidates about available accommodation still need to be addressed.


We filed in 2023. Do we need to file again?

If you remain in the business or nonprofit reporting category and meet the reporting threshold, yes. The next reporting deadline is December 31, 2026.


What if we identify a gap?

Assign responsibility and address it promptly. Answer the reporting questions accurately. If you cannot resolve the issue before the deadline or are uncertain how to report it, contact Ontario’s accessibility reporting support for guidance.

An internal action plan does not make an unmet requirement complete.


Does filing mean we have an accessibility certification?

Filing is a compliance reporting obligation. It should not be treated as an independent audit or a blanket assurance that every part of your organization is accessible.

Make accessibility part of how you operate

The strongest preparation leaves you with more than a submitted form.


Employees know where to ask for support. Managers understand their responsibilities. Candidates can participate in hiring. Clients have a practical way to access your services and information.


Start with the requirements that apply to your organization, identify the gaps, and give each action an owner. That makes the December deadline easier to manage and your processes easier to maintain afterward.

Need help preparing?

A&A Consulting can help review your HR policies, training records, recruitment templates, and accommodation processes, and organize a practical action plan. Book a conversation with our team to discuss the support you need or contact us today.


Want more practical employer updates? Subscribe to the A&A newsletter for HR guidance, compliance reminders, and useful tools for managing your team.

Sources and official resources

Information checked October 8, 2026.

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