A mandatory accessibility compliance report under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) is due December 31, 2026. Now is the time to take stock of your workplace, create and execute an action plan, and file before the deadline. Here’s what you need to know…
Purpose of the AODA
The purpose of the AODA is to make Ontario accessible for all Ontarians. To this end, the Integrated Accessibility Standards Regulation (“IASR”) under the AODA establishes specific requirements regarding five accessibility standards: customer service, information and communications, employment, transportation, and design of public spaces.
Who needs to file?
Every provincially regulated Ontario business or non-profit organization with 20 or more employees, other than a “designated public sector organization,” must complete a mandatory, self-assessment, accessibility compliance report by December 31, 2026. Missing the deadline may result in an audit, compliance order, or administrative penalty.
Employee count is based on the peak number of employees at any time during the previous 12 months. It includes all full-time, part-time, seasonal, and contract employees in Ontario, but excludes any volunteer, independent contractor, and employee outside Ontario. An organization or business with fewer than 20 employees in Ontario need not file a report.
Note: Even if an employer has fewer than 20 employees in Ontario, if it has at least one employee in Ontario or engages volunteers, independent contractors or employees outside of Ontario, it may still have obligations under the AODA and IASR. To learn more, contact Sherrard Kuzz LLP.
Reporting cycle
Not every organization is on the same reporting cycle. Reporting frequency depends on the sector and type of organization:
- A business or not-for-profit organization must file every three years. The last deadline was December 31, 2023.
- A designated public-sector organization must file every two years. The last deadline was December 31, 2025.
If an organization has missed a deadline, it is still required to file.
Tips to complete the compliance report
Consider the following tips and best practices:
1. Don’t wait until the deadline. If you have not already started, now is the time. Give your organization time to identify and address any compliance gap well before the deadline.
2. Confirm your organization category and size. This will determine whether your organization must file a report, and any other accessibility obligation that applies. An organization with 50 or more employees generally has additional AODA requirements.
3. Identify your business number and senior official. You will need your organization’s nine-digit business number, and a senior official with authority to bind the organization to certify the report is complete and accurate.
4. Read every question carefully. Although AODA and IASR requirements have not changed since the 2023 reporting deadline, the questions have changed, so it is important to read them carefully. Questions are worded more broadly than before and require knowledge of the requirements under each accessibility standard. If you do not fully understand a question, there are linked resources in the reporting form, or you can contact Sherrard Kuzz LLP for assistance.
5. Create an action plan. When answering questions, you may identify potential compliance gaps. Starting early allows time to address and close those gaps. If you cannot address a gap before the deadline, answer honestly. Knowingly submitting false or misleading information is an offence subject to a fine of up to $50,000 for an individual and $100,000 for a corporation for each day or part-day the offence continues.
Each question includes a comment box to provide additional details in support of your answer. As a best practice, a non-compliant organization may use the comment box to outline its action plan to address a gap. This can be helpful if your organization is audited.
6. Cooperate with any audit. Ontario’s Ministry for Seniors and Accessibility oversees AODA compliance using a model that emphasizes education and outreach before sanctions. That said, the Ministry may take proactive steps if an organization is non-compliant, unresponsive, or does not file. The Ministry continues to expand its auditing activities; in 2024-25, it completed 1,855 audits.
Although an administrative penalty may be imposed under the IASR, typically an organization is first given an opportunity to comply and a Ministry compliance officer will work with the organization to develop a plan. An organization that cooperates and achieves compliance generally avoids sanction. Of the 1,855 completed audits in 2024, 99.8% were resolved as compliant.
7. Document everything. Keep accurate and up-to-date records to meet your legal requirements and be prepared in the event of an audit. Even if not legally required, it is a best practice to keep records. For example, an organization with 49 or fewer employees need not retain training records, but it may be prudent to do so in the event the workforce grows.
To help you understand and meet your obligations under the AODA, or complete a compliance report, contact your Sherrard Kuzz LLP lawyer, the authors of this article, or info@sherrardkuzz.com.
The information contained in this presentation/article is provided for general information purposes only and does not constitute legal or other professional advice, nor does accessing this information create a lawyer-client relationship. This presentation/article is current as of September 2026 and applies only to Ontario, Canada, or such other laws of Canada as expressly indicated. Information about the law is checked for legal accuracy as at the date the presentation/article is prepared but may become outdated as laws or policies change. For clarification or for legal or other professional assistance please contact Sherrard Kuzz LLP.
