Accessibility compliance has a way of slipping down the priority list, until it can’t. Ontario employers with 20 or more employees are required to file an accessibility compliance report under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) every three years, and the next deadline is December 31, 2026. Filing is not optional; it is a legal obligation. Failure to comply with the AODA, including submitting an accessibility report, can trigger enforcement measures, including financial penalties of up to $100,000 per day for corporations and $50,000 per day for individual directors and officers.

With fewer than five months on the clock, now is the time to take stock, close any gaps, and make sure the organization can file with confidence and avoid a last-minute rush in December.

AODA 101: The obligations Ontario organizations can’t afford to overlook

The AODA applies to every organization operating in Ontario with at least one employee (private businesses, non-profits, and public-sector bodies alike). Its goal is to identify, prevent, and remove barriers for people with disabilities through mandatory accessibility standards in five key areas: customer service, employment, information and communications, transportation, and the design of public spaces.

The specifics scale with an organization’s headcount, but here are the obligations every Ontario organization needs to have on their radar:

Written accessibility policies and plans

Organizations with 50 or more employees must develop, maintain, and make publicly available written accessibility policies describing how they meet their AODA obligations. These larger organizations must also prepare and post a multi-year accessibility plan, reviewing and updating it at least every five years. While the written policy requirement does not apply to smaller organizations, they are strongly encouraged to adopt and maintain basic written accessibility policies as a best practice. Having a written policy provides clear evidence of the organization’s efforts to meet its AODA obligations and, without one, it can be difficult to demonstrate or substantiate compliance.

Employee training

All organizations, regardless of size, must train employees, volunteers, and individuals acting on behalf of the organization on the AODA and the Ontario Human Rights Code as they relate to persons with disabilities. Training must be provided as soon as reasonably practicable, ideally during onboarding, and updated whenever policies change. Organizations with 50 or more employees are required to keep records of the training provided.

This is one of the most misunderstood AODA requirements and a common source of non-compliance. Organizations often assume that meeting the requirement means training only their employees, but the obligation extends beyond employees to volunteers and other individuals who provide goods, services, or facilities on behalf of the organization.

Website and digital content accessibility

Organizations with 50 or more employees must ensure their public-facing websites and web content conform to the Web Content Accessibility Guidelines (WCAG) 2.0, Level AA. This standard applies to all web content created or significantly refreshed after January 1, 2012. This is by far one of the most time-consuming areas of AODA compliance, largely because it often requires input and implementation support from internal or external IT and web development teams.

Given the technical work that may be required to identify and remediate accessibility issues, organizations should begin assessing their websites and digital content well in advance of the compliance deadline. While the AODA currently references WCAG 2.0, Ontario is expected to transition to WCAG 2.2 by 2027, making it worthwhile for organizations to consider the updated standard as part of any accessibility remediation work already underway.

Accessible employment practices

The AODA’s Employment Standard requires organizations to build accessibility into every stage of the employment lifecycle. This includes notifying job applicants that accommodations are available during the recruitment process, providing workplace information in accessible formats upon request, developing documented individual accommodation plans, maintaining a return-to-work process for employees who have been absent due to a disability, and considering accessibility needs in performance management and career development.

Customer service standards

Every organization that provides goods, services, or facilities to the public must establish policies and practices that respect the dignity, independence, and integration of persons with disabilities. This includes permitting service animals and support persons, providing notice of temporary service disruptions, and establishing a feedback process for accessibility-related concerns.

More than a box-checking exercise

The compliance report, while a self-assessment, is more than simply a paperwork exercise. It requires a senior officer to certify that the information provided is complete and accurate. In other words, an organization must actually be compliant, not just say it is. Organizations that have let their training obligations lapse, neglected their digital accessibility, or did not implement or update written policies may find themselves unable to sign off honestly when the time comes.

Enforcement has historically been complaint-driven, but the Accessibility Directorate of Ontario conducts audits and has issued compliance orders and penalty notices against non-compliant organizations. With increased regulatory focus heading into the 2026 reporting cycle, the risk of an enforcement action is not one to take lightly.

Don't wait for December: Start now

The AODA’s requirements span employment practices, customer service, digital content, and corporate reporting. If an organization has not revisited its compliance framework in a few years, there may be more ground to cover than it expects. A proactive compliance review can help identify gaps before they become liabilities. Whether it involves updating written policies, refreshing training programs, auditing digital content against WCAG standards, or preparing the compliance report itself, addressing these requirements early can help avoid last-minute issues.

In our experience, the AODA filing portal can become congested as the reporting deadline approaches, particularly on the final day. Completing and submitting the report well in advance of the deadline can therefore help avoid unnecessary delays, technical issues, or other last-minute surprises. The AODA compliance report form can be downloaded from the Ontario government’s AODA compliance reporting page.

How Gowling WLG can help

Our Employment, Labour & Equalities team regularly advises Ontario employers on accessibility compliance—from full organizational audits to targeted guidance on specific obligations. If your organization could use a compliance check-up before the December deadline, we would welcome the conversation.