AODA requirements at 20 employees

Sources read 2026-11-01: O. Reg. 191/11 (ss. 2, 3, 7, 11 to 14, 22 to 32, 80.45 to 80.51, 86.1) and Ontario's page for businesses and non-profits.

The two size lines in the regulation

O. Reg. 191/11 defines a small organization as a business or non-profit with 1 to 49 employees in Ontario and a large organization as one with 50 or more (s. 2). Almost every duty to write something down applies to “obligated organizations other than small organizations”, so written documents start at 50. The reporting duty has its own line: 20 employees (s. 86.1(1)).

What applies at every size (1 or more employees)

• Accessibility policies on how you meet the standards (s. 3(1)). Not required in writing below 50.
• Training for employees, volunteers, people who develop your policies and people who provide goods or services on your behalf, on the standards and on the Human Rights Code as it relates to people with disabilities (s. 7). Records required only at 50 or more (s. 7(5)).
• Information and communications: an accessible feedback process with public notice (s. 11); accessible formats and communication supports on request, at no more than the regular cost, with public notice (s. 12); accessible emergency information if you publish any (s. 13).
• Employment: notice that accommodation is available in recruitment, assessment and offers (ss. 22 to 24); informing employees of support policies (s. 25); accessible formats for employees (s. 26); individualized workplace emergency response information (s. 27); accommodation needs considered in performance management, career development and redeployment where you use them (ss. 30 to 32).
• Customer service: policies including assistive devices (s. 80.46); service animals and support persons (s. 80.47); notice of temporary disruptions (s. 80.48); customer service training (s. 80.49); a feedback process (s. 80.50). Written versions only at 50 or more.
• Design of public spaces: technical requirements when you build or redevelop certain outdoor spaces, parking, service counters or waiting areas (Part IV.1, since 2017).

What changes at 20 employees

One thing: you file an accessibility compliance report every three years, next by December 31, 2026. At 20 to 49 employees the form asks one question, about the Customer Service Standards (s. 86.1(1)(b)). The report, once filed, must be available to the public (AODA s. 14(2)).

Nothing else changes. Ontario's own page says organizations with 20 to 49 employees are “not required to document these policies, but it's a good idea”.

What changes at 50 employees

• Written accessibility policies with a statement of commitment, publicly available (s. 3(2), (3)).
• A multi-year accessibility plan, posted on your website, reviewed at least every five years (s. 4).
• Training records: dates and number of people (s. 7(5)).
• Public website and web content to WCAG 2.0 Level AA, where practicable (s. 14).
• A written process for individual accommodation plans and a documented return-to-work process (ss. 28, 29).
• Six customer service documents, each available on request with a notice: customer service policy, service animal and support person policy, temporary disruption procedure, training policy, training records, feedback process (ss. 80.46 to 80.50).
• The report asks six questions, one per standard.

How to count

Count full-time, part-time, seasonal and contract employees in Ontario. Do not count volunteers, independent contractors or employees outside Ontario (Ontario's page, “How to count your employees”). Keep a dated note of your count with your report.

Sources

• O. Reg. 191/11, ss. 2, 3, 4, 7, 11 to 14, 22 to 32, 80.45 to 80.51, 86.1.
• Ontario: Accessibility rules for businesses and non-profits, updated 2026-06-16.

Not legal advice. The regulation on e-Laws prevails.