About this guide

This guide will help you understand how Ontario’s accessibility laws apply to your organization and what you need to do to comply.

This information is for businesses or organizations that do not provide goods, services or facilities directly to the public.

Use this guide if you are a part of:

  • the construction industry
  • the manufacturing and/or wholesale trade sector
  • the mining and extraction sector
  • other sectors that don’t service the public directly

Who needs to comply

You must comply with Ontario’s accessibility laws and standards if you:

  • have at least one employee in Ontario
  • provide goods, services or facilities to the public or other organizations

Even if your organization does not provide services, goods or facilities directly to the public on-site you still must comply with accessibility laws.

About Ontario’s accessibility laws

Ontario has laws that work together to create an Ontario that is more accessible for everyone.

The Integrated Accessibility Standards Regulation (IASR) under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) sets accessibility standards to help businesses and organizations identify, prevent and remove barriers to accessibility in five areas:

  • customer service
  • access to information
  • public transportation
  • employment
  • public spaces

These accessibility standards are laws that government, businesses, non-profits and public sector organizations must follow to become more accessible.

The 2012 Building Code covers most requirements for making buildings accessible. These include requirements for ramps, washrooms, power door operators and signs.

The Ontario Human Rights Code addresses discrimination and requires organizations to accommodate people with disabilities.

Accessibility requirements you need to meet

This information helps you understand which accessibility requirements apply to you and how to comply with them.

Count your employees

Count your employees, because some specific requirements only apply if you have a certain number of employees.

The number of employees is determined by your organization’s peak employee count at any one time during the previous twelve months.

When determining this number, count:

  • all full-time and part-time employees
  • seasonal employees
  • contract workers

Don’t count employees outside of Ontario or outside contractors. Consider whether you:

  • pay the employee (wages or a salary)
  • have control over the work assigned to them
  • have a right to control the details of the work.

Seek legal advice if you are not sure whether to count someone as an employee or a contractor.

File an accessibility compliance report

The requirements and deadlines you need to follow depend on the type and size of your organization.

20 or more employees

If you have 20 or more employees, you must file an accessibility compliance report every three years.

The last reporting deadline was December 31, 2023. You are still required to file a 2023 report even though the deadline has passed.

The next reporting deadline will be December 31, 2026. We will share information on how to complete your report for this deadline in 2026.

Fewer than 20 employees

If you have fewer than 20 employees, you do not have to file a compliance report, but you still must comply with all applicable accessibility requirements.

Have accessible employment practices

You are required to accommodate employees with disabilities throughout their employment under both the AODA employment standards and the Ontario Human Rights Code.

Your requirements include:

  • making your recruitment process accessible — for instance, someone with a disability may require alternate formats for written materials or physical adjustments to a computer set-up
  • informing your employees of supports available
  • offering accessible formats and communication supports for employees
  • providing individualized accessible workplace emergency response information
  • documenting individual accommodation plans
  • adjusting the employee’s duties, so that they can still provide necessary services while avoiding certain tasks
  • creating a return to work process and plan for employees who have been absent from work due to a disability
  • adjusting an employee’s schedule to work around medical appointments, treatments or medications

Types of disabilities

The term “disability” covers a broad range and degree of conditions. Common types of disabilities include:

  • physical
  • intellectual
  • mental
  • developmental.

Many disabilities, such as dyslexia or depression, can often be invisible.

If you cannot make an accommodation

You have a duty as an employer under the Ontario Human Rights Code to accommodate people with disabilities unless it causes the employer undue hardship.

"Undue hardship" is when making an accommodation:

  • is so costly that your business could cease to be viable or would need to change its essential nature
  • would create significant health or safety risks

You must have proof to claim undue hardship. Factors such as inconvenience to your business, employee morale, and customer and third-party preferences are not valid considerations in assessing whether an accommodation would cause undue hardship.

Resources

Provide accessible customer service

You must comply with the customer service standard even if your organization operates as “business-to-business” or only provides goods, services or facilities to organizations who meet your eligibility criteria, such as manufacturers, wholesalers and professional services.

The Customer Service Standard requires you to:

  • have accessible ways for people to provide you with feedback about your organization
  • train your employees on Ontario’s accessibility laws
  • provide customers, clients, members, and consumers with the right customer service so they can access:
    • goods
    • services
    • facilities (for example, rooms or spaces used to provide a service, such as a stadium or banquet hall)

Learn more about how to provide accessible customer service.

Train your employees about accessibility

If you have one or more employees, you must provide training to:

  • all employees (paid and unpaid, full-time, part-time and contract positions)
  • anyone involved in developing your organization’s policies (including managers, senior leaders, directors, board members and owners)

You are required to train all your employees on:

You don’t need to train employees based outside of Ontario.

Recordkeeping requirement

If you have 50 or more employees you must keep training records that include the:

  • number of people who were trained
  • dates that the training was provided

Unionized construction employees

Responsibility for training requirements in the construction sector depends on whether the employer is a construction company or union.

If an employee is employed by the union and not with the construction company, then the union as their employer may be responsible for accessibility training.

If an employee is represented by a union but working for the construction company on a contract, even for one day, that individual may be considered a contract employee and the construction company may be responsible for accessibility training.

Volunteers and outside contractors

If a volunteer or outside contractor is providing goods, services or facilities in Ontario on behalf of your organization, you are responsible to ensure that they meet your legal obligations under Ontario’s accessibility laws. You may need to ensure these individuals are trained to meet the requirements.

The Ministry for Seniors and Accessibility cannot provide advice on specific situations. You may wish to seek independent legal advice.

Resources

Create accessibility policies and plans

Accessibility policies

You are required to create and maintain accessibility policies. They set out the rules your organization will put in place to become more accessible.

These policies must include a statement that summarizes your organization’s commitment to meeting the accessibility needs of people with disabilities.

If you have fewer than 50 employees, you are not required to document these policies, but it’s a good idea to do so. Documenting helps you:

  • consider accessibility as part of your overall planning
  • be ready to meet documentation requirements should your organization expand

If you have 50 or more employees, you must document these policies.

Multi-year accessibility plans

If you have 50 or more employees, you must develop a written multi-year accessibility plan, update it at least once every five years and post it on your website (if you have one).

A multi-year accessibility plan outlines what steps your organization will take to prevent and remove barriers to accessibility and meet its accessibility regulatory requirements. It should also outline when the steps will be taken.

Requirements for a multi-year accessibility plan include:

  • posting the plan on your website, if you have one
  • providing the plan in an accessible format, upon request
  • reviewing and updating the plan at least once every five years.

It is up to you to decide how much detail to include in your plan.

Resources

Accessibility requirements for public spaces

These requirements only apply to new construction and planned redevelopment of existing public spaces.

Accessible public spaces have specific features that make it easier for people with disabilities to move through and use the environment. These features can include:

  • accessible parking spaces along streets or in parking lots
  • sidewalks or access aisles (between accessible parking spaces)

Temporary unplanned changes, such as emergency repairs or regular maintenance, are exempt.

Resources

Learn more about the laws

AODA and the Building Code

Ontario’s Building Code sets technical requirements when:

  • buildings are being constructed
  • existing buildings are undergoing major renovations.

Ontario’s Building Code and the Design of Public Spaces Standards under the AODA work together to promote an accessible built environment.

The AODA and the Design of Public Spaces standards do not apply to the construction of buildings. Accessibility in buildings at the time of construction or major renovation (which could involve ramps, accessible washrooms, elevators and entrances) is governed by Ontario’s Building Code, which is administered by the Ministry of Municipal Affairs and Housing.

Ontario’s Building Code does not set standards for retrofit or maintenance or deal with matters related to operational building maintenance.

AODA and the Ontario Human Rights Code

The AODA sets standards for how organizations and people must make themselves accessible to people with disabilities; it is not designed to address complaints from individuals who feel that they have been discriminated against because of a disability.

The Ontario Human Rights Code addresses discrimination and prohibits actions that discriminate against people, including those with a disability. It requires organizations to accommodate people with disabilities and applies to both organizations and individuals in the public and private sectors.

Contact us

If you need help with meeting requirements or have questions, contact us by:

Disclaimer

The aim and purpose of this guide is to help individuals and businesses with information related to the Accessibility for Ontarians with Disabilities Act, 2005 and its associated regulation O. Reg. 191/11. This guidance is not intended to, nor does it, provide legal advice and should not be relied upon or treated as legal advice. Those seeking legal advice should consult with a qualified legal professional.

In case of a discrepancy between website content and relevant Ontario legislation and regulations, the official version of Ontario Acts and Regulations as published by the King's Printer for Ontario will prevail.