How often are organizations required to file an AODA compliance report?
In Ontario, businesses and nonprofits with 20 or more employees must file an accessibility compliance report under the Accessibility for Ontarians with Disabilities Act (AODA) every three years; the next deadline is December 31, 2026. AODA compliance reporting for Ontario employers is a legislated requirement for every organization. Designated public sector organizations must file a compliance report every two years. The deadline for the report was December 31, 2025. Designated public sector organizations that missed this deadline are still required to file their 2025 report.
AODA compliance reporting for Ontario employers
If either of those criteria apply to your organization, filing the compliance report is a legal obligation under AODA. In this expert-led webinar, HR consultants Kim Morris and Noah Martin, CPACC, break down what Ontario employers need to know, including:
- What organizations must file a report and by when
- The five accessibility standards and what they mean for your workplace
- How to make filing straightforward and repeatable, instead of a last-minute scramble
Together, they detail the obligations and reporting requirements, digital accessibility, and how to build accessibility into your policies and staff training.
Top insights from this webinar:
- Know when your organization must file a compliance report.
- Discover how the five accessibility standards affect hiring, onboarding, accommodation and performance.
- Explore the government of Ontario’s accessibility compliance reporting portal and where to find support when you need it.
If accessibility compliance reporting has been sliding down your to-do list, watch the full webinar replay or check out the expert Q&A below for immediate answers to frequently asked questions.
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AODA compliance and reporting for Ontario Employers: A Q&A from our HR experts
In this Q&A, adapted from the session, co-presenters Noah and Kim answer the questions Ontario employers ask most about AODA obligations, the accessibility compliance report, and getting ready before the upcoming deadline.
Adapted from webinar transcript
AODA compliance reporting for Ontario employers: Understanding your obligations
Kim: What is the AODA, and who does it apply to?
Noah: The Accessibility for Ontarians with Disabilities Act (AODA) is Ontario’s framework for removing barriers so more people can take part in work and daily life. It applies to every organization operating in Ontario with at least one employee: private businesses, nonprofits, and public-sector bodies alike. Your team size doesn’t decide whether you’re covered by AODA; it shapes how much you document and report.
Kim: What are the five accessibility standards, and where does HR fit?
Noah: They sit under the Integrated Accessibility Standards Regulation (IASR) and cover customer service, information and communications, employment, transportation, and the design of public spaces. HR naturally focusses on the employment standard, but picture someone’s whole experience with you: can they reach your services, understand your information, navigate your spaces? Accessibility is a shared responsibility: HR, operations, facilities, and communications each own a piece.
Building accessibility into the workplace
Noah: Where does accessibility show up in employment?
Kim: Everywhere. And it works best when it isn’t boxed into a standalone policy. Your job postings signal that accommodations are available; at interview you invite requests; at offer you share your accommodation policy; at onboarding you show new hires where the policies live and how to ask. It carries on through performance, career development, and emergency planning, including temporary needs, like someone on crutches for a few weeks. At 50 or more employees, you also need a documented return-to-work process.
Noah: Who needs training, and what records should you keep?
Kim: Accessibility training isn’t a box to tick; it’s about making sure people understand the standards and how they apply to their role, and it reaches leaders, supervisors, volunteers, and anyone involved in writing policies.
Keeping training records is required once you reach 50 employees, and it’s a smart practice at any size. At 50 or more employees, you also need a multiyear accessibility plan you review at least every five years, because needs, technology, and teams all change.
Who must report and by when
Kim: Do the same requirements apply to every organization?
Noah: The foundation does; the paperwork grows with you. Every Ontario employer needs accessibility policies, training for staff and volunteers, accessible customer service with a feedback process, accessible employment practices, and individualized emergency response information where someone needs it. What changes as you grow is how much you must document, publish, and report.
Kim: When is the next compliance report due?
Noah: Private businesses and nonprofits with 20 or more employees file an accessibility compliance report every three years, and the next deadline is December 31, 2026. Designated public-sector organizations file every two years; the most recent deadline was December 31, 2025, and any that missed it still must file. The report is a self-assessment you submit through the province’s online portal, not an audit, confirming where you stand against the standards that apply to you.
Kim: We have fewer than 20 employees; are we off the hook?
Noah: You don’t need to file a report, and your policies don’t technically have to be in writing, but please don’t read that as your organization having “no AODA duties.” Every core obligation still applies. Writing things down simply proves you’re doing what you’re already required to do, keeps your practices consistent, and sets you up smoothly if you grow past 20 employees and then 50 employees.
Kim: What changes once we pass 50 employees?
Noah: At 50 or more employees, you move to the fuller, documented program: written accessibility policies available to the public, a multiyear accessibility plan that’s posted and reviewed at least every five years, public websites and web content that meet the WCAG 2.0 Level AA standard (with limited exceptions), training records, and documented processes for individual accommodation and returnto work.
AODA compliance for Ontario employers: Completing your report
Kim: How do Ontario employers file an AODA compliance report?
Noah: Sign in or create an account on the Ontario government’s reporting portal, then select your organization category and employee range, which decides which questions you see, so get it right. Work through each question, answer yes or no, and add a comment where it helps. Having your documentation open beside you is what lets you answer quickly and with confidence. Citation Canada members also have an accessibility compliance report checklist on the Atlas platform to work through first.
Kim: Who signs off on AODA reports for businesses?
Noah: Your certifier, an internal senior officer, director, or owner with legal authority to sign off on the report, confirms the information is accurate, confirms their authority, and enters the certification date. The certifier can be the person who completed the report or someone else. You also add a primary contact for any follow-up. Once you submit, the certifier and primary contact receive a confirmation e-mail with a confirmation number and a PDF copy; keep both for your records and the next cycle.
Kim: Should we still file if we’re not meeting every requirement yet?
Noah: Yes, absolutely. The duty to submit applies whether you’ve met every requirement, and filing is the honest first step. It surfaces the gaps so you can plan who fixes what and by when. If there’s a shortfall, a representative from the Accessibility Directorate may reach out to help you reconcile it.
Your top AODA compliance reporting questions from the live session
Kim: How do we count employees for reporting?
Noah: Use the highest number of employees you had at any one point in the past 12 months, not an average or a full-time-equivalent calculation. Full-time, part-time, seasonal, and contract employees all count; volunteers and independent contractors don’t; and only your Ontario employees go into the total. So, if your numbers swing seasonally, say a conservation area that adds 25 summer students, that peak is your reporting figure.
Kim: If the company is fully remote with no customers or public-facing site, does AODA still apply?
Noah: It does. One of the IASR standards is employment, which covers the job application process, career development, and return to work. So even with a remote team and no customers, the legislation applies; your postings, your onboarding, and your everyday systems still need to be accessible.
Kim: Does the customer feedback process have to be on a website?
Noah: It needs to be readily available in whatever way your organization operates. If you have a website, put it there; if you take calls or e-mails from the public, offer it that way. The requirement applies regardless of your size.
Kim: Do board members and volunteers need the AODA training too?
Noah: Yes, training includes volunteers and board members. Board members may need a little extra on the information and communications standard, especially anyone involved in writing policy or running operations.
Kim: Do AODA training records have to be digital?
Noah: No, as long as it’s recorded, it counts, so a paper record is fine. The report itself is submitted digitally through the portal, but your underlying training records don’t have to be.
Kim: What happens if you miss the December 31 deadline?
Noah: The reporting window stays open, so you can still submit after the date, but the deadline is the line, and there can be consequences for filing late. The simplest path is to start now, while there’s room to fix anything the report turns up.
Top AODA compliance reporting insights from our HR experts
Getting AODA-ready isn’t a one-day project, and it isn’t meant to be. As Kim put it, the accessibility compliance report is a legal obligation under AODA once you meet the criteria, and the employers who find it easiest treat accessibility as something they keep current all year so when a reporting year lands, filing is a formality rather than a fire drill.
Preparing for December 31, 2026:
- Confirm which requirements apply to you and whether you need to file based on your highest employee count in the past 12 months.
- Gather your documentation, policies, training records, and accommodation processes before you open the portal.
- Line up your certifier and primary contact early and submit with time to review.
Between reporting cycles:
- Keep an eye on changes to your headcount, your website, and your obligations and update your portal profile if you employee count or status changes.
- Build accessibility into recruitment, accommodation, performance, and emergency plans rather than treating it as a separate consideration.
- Note any gaps, give each one an owner and a timeline, and keep training current for staff, volunteers, and board members.
Want the full picture before you file? We support AODA compliance for Ontario employers
Our Resource Centre is stocked with practical HR and compliance tools built for Canadian employers, including guides, templates, and on-demand webinars you can use today.
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Need help getting AODA-ready before Dec. 31?
Accessibility compliance reporting can feel like an enormous task until you have the right support. Whether you’re filing for the first time or tightening things up before the deadline, Citation Canada’s HR software packages and employee training add-ons remove the guesswork. With any of our service plans, your HR professionals and business leaders can equip staff with better tools and user-friendly software for more effective employee management.
- Canadian-made content for every jurisdiction: A library containing hundreds of ready-to-use and current HR policies and documents, including accessibility policies, built for Canadian businesses.
- Online training for staff and leaders: Assign and track accessibility and legislatively required courses through our Canadian-made learning management platform.
- Live HR advice and consulting: Connect with an experienced Canadian HR advisor when you need guidance or contact our professional HR consulting team for project-based support.
See how our products and services can help your team build a more accessible business for all Ontarians. Request a live demo of our HR and health and safety software or learn more about our other professional services.