Quick Hits

  • Under the Accessibility for Ontarians with Disabilities Act (AODA), companies with twenty or more employees in Ontario must file an accessibility compliance report by December 31, 2026.
  • The AODA applies to provincially regulated organizations in the Province of Ontario, Canada.
  • Failure to submit the report may lead to potential enforcement action.

Background Facts

Enacted in 2005, the AODA is Canada’s oldest and most fulsome accessibility legislation.

Provincially regulated organizations are required to meet the standards set out in the AODA and its regulations if they operate in Ontario.

Organizations will be considered to operate in Ontario if they provide goods, services, or facilities; employ people; offer accommodation; own or occupy a building, structure, or premises; or are engaged in business in Ontario.

Preparing for Compliance

Every three years, organizations covered by the AODA that have twenty or more Ontario employees (including full-time, part-time, seasonal, and fixed-term contract employees) must submit a report regarding their compliance to the Ontario Ministry of Seniors and Accessibility via the Accessibility Compliance Portal.

Failure to submit the report may lead to potential enforcement action.

To prepare, employers should access the Accessibility Compliance Portal to update their organization profile and review the questions that the organization will be required to answer.  The questions track closely with the requirements set out in the Integrated Accessibility Standards (Ontario Regulation 191/11). Once the organization is satisfied with its answers to the questions set out in the accessibility compliance report, the organization can finalize and submit the report.

Ogletree Deakins’ Toronto office and Disability Access Practice Group will continue to monitor developments and will post updates on the Canada, Cross-Border, and Disability Access blogs as additional information becomes available.

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