Ontario employers should be turning their attention to their ongoing obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and its related accessibility standards. The AODA applies broadly across Ontario’s public and private sectors and establishes requirements intended to identify, remove, and prevent barriers for persons with disabilities in areas such as goods, services, facilities, accommodation, employment, buildings, structures, and premises.
For employers, accessibility compliance is not a one-time exercise. It requires ongoing attention to workplace policies and practices, employee training, accommodation procedures, documentation, and, for certain organizations, periodic accessibility reporting.
Upcoming AODA Reporting Deadlines
The AODA establishes different accessibility compliance reporting requirements and deadlines depending on the type and size of the organization.
Private sector businesses and non-profit organizations with 20 or more employees are required to file accessibility compliance reports every three years. Their next reporting deadline is December 31, 2026.
Designated public sector organizations are required to file accessibility compliance reports every two years. Their most recent reporting deadline was December 31, 2025, and their next regular reporting deadline is December 31, 2027.
Filing an accessibility compliance report is a legal obligation under the AODA. Failure to submit a required report may result in enforcement action, including compliance audits and financial penalties. Employers should also be aware that missing an accessibility compliance reporting deadline does not eliminate the obligation to file. Organizations that failed to submit a required report for an earlier reporting period remain responsible for addressing that outstanding obligation.
Employers who are required to file accessibility compliance reports should begin preparing well in advance rather than treating the filing as a year-end administrative task. The report requires an organization to confirm that it has met applicable AODA requirements, and it must be certified as accurate by an individual with proper authority to bind the organization. Employers should therefore ensure that the information being reported is complete, current, and supported by internal records.
Reviewing Workplace Accessibility Options
As part of their ongoing compliance efforts, Ontario employers should review whether they have the required accessibility policies in place, whether those policies are being implemented, and whether staff have received appropriate accessibility training.
Employers should also confirm that their employment practices appropriately address accessibility throughout the employment relationship, including recruitment, hiring, workplace information, accommodation processes, performance management, career development, return-to-work processes, and communications with employees with disabilities.
Where an employee with a disability requests accessible formats or communication supports for information needed to perform their job or information generally available to employees in the workplace, the employer must consult with the employee to determine suitable supports, subject to the applicable regulatory requirements.
Designated public sector organizations and private sector businesses and non-profit organizations with 50 or more employees have additional documentation obligations, including maintaining a multi-year accessibility plan. That plan must outline the organization’s strategy for preventing and removing accessibility barriers and meeting its accessibility obligations under the applicable standards. It must also be reviewed and updated at least once every five years, posted on the organization’s website where applicable, and made available in an accessible format upon request.
Employers should not wait until the reporting deadline to review these materials, as gaps in documentation may reveal broader compliance issues that take time to correct.
AODA Compliance and Human Rights Obligations
Employers should also remember that AODA compliance does not replace their obligations under human rights legislation. Accessibility standards operate alongside the duty to accommodate employees with disabilities to the point of undue hardship. As a result, an employer may be technically compliant with certain AODA requirements but still face risk if its workplace practices do not properly address individual accommodation needs. A strong compliance review should therefore consider both the organization’s general accessibility systems and its individualized accommodation practices.
Preparing for Compliance
With the December 31, 2026 reporting deadline approaching for private sector businesses and non-profit organizations with 20 or more employees, affected employers should take steps now to assess their compliance with applicable AODA requirements.
This includes reviewing accessibility policies and plans, confirming employee training, assessing accommodation procedures and gathering the information required to complete their accessibility compliance reports.
Designated public sector organizations should similarly continue reviewing their accessibility obligations in preparation for their next December 2027 reporting cycle.
Failure to meet applicable reporting requirements may result in enforcement action, including financial penalties.
Taking a proactive approach will help employers reduce compliance risks, promote more accessible workplaces and demonstrate that accessibility remains an ongoing organizational priority rather than simply a last-minute reporting obligation.
Employers can use the Ontario government’s Accessibility Standards Checklist to assess their organization’s obligations under the AODA and identify potential compliance gaps.