Ontario organizations with 20 or more employees are required to file an Accessibility Compliance Report under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) by December 31, 2026. The filing cycle is prompting many employers to revisit their accessibility obligations—particularly those that have expanded, restructured, or changed service delivery since their last reporting period.
According to Laura Gurr, Partner at Cohen Highley LLP, the AODA deadline offers an important opportunity to take stock of accessibility policies, training records, employment practices, multi‑year accessibility plans, and communication procedures to ensure they still meet provincial standards. She also notes that organizations uncertain about their obligations or current compliance status should consider a proactive review to identify gaps and reduce regulatory risk. Failure to file, or filing without meeting applicable requirements, may result in enforcement action, including administrative penalties.
The Accessibility Compliance Report requires organizations to certify compliance with the Integrated Accessibility Standards Regulation (IASR), covering customer service, information and communications, employment standards, and general accessibility policies. When determining employee count, organizations must include all full‑time, part‑time, seasonal, and contract workers in Ontario. Volunteers, independent contractors, and employees outside Ontario are excluded, though organizations remain responsible for ensuring that services delivered on their behalf meet accessibility standards.
Organizations with 1–19 employees must comply with the AODA but are not required to file a report. Those with no employees in Ontario should submit an Organization Profile Update. Organizations with 20 or more employees must file every three years through the Accessibility Compliance Reporting Portal.
Before filing, employers should confirm compliance across key areas such as accessibility policies, multi‑year plans, training records, recruitment and accommodation processes, accessible communication practices, and customer service procedures. Filing constitutes a certification of compliance, making it essential to address any gaps beforehand.
To submit the report, organizations will need their legal name, BN9, employee count, and the contact information of the senior officer certifying the report. Those without a BN9 must obtain an AODA identifier from the Ministry.
After filing, organizations must make their Compliance Report available to the public and retain documentation demonstrating compliance, including policies, training records, accessibility plans, public notices, and internal assessments. These records may be requested during an audit or review by the Ministry for Seniors and Accessibility. Any subsequent changes to organizational information such as address, primary contact, or employee count, must be reported through an Organization Profile Update.
Housing providers with legal questions may contact Laura Gurr at 5 [email protected]
