Guide
Do I need to file an AODA report?
Two facts decide it: what kind of organization you are, and how many employees you have in Ontario.
Step 1: does the regulation apply to you at all?
O. Reg. 191/11 applies to every person or organization that provides goods, services or facilities to the public or to other third parties and has at least one employee in Ontario (s. 1(3), and Ontario's page: “You are exempt if you do not have employees in Ontario”). Almost every business and non-profit with staff in Ontario is covered. Federally regulated organizations (banks, airlines, telecoms, interprovincial transport) follow the federal Accessible Canada Act instead; Ontario's page lists “federally regulated” among the status changes to tell the ministry about.
Step 2: find your row
| You are | Do you file? | When | Section |
|---|---|---|---|
| Business or non-profit, 1 to 19 employees in Ontario | No | — | s. 86.1(1)(a) |
| Business or non-profit, 20 to 49 employees | Yes: one question, on customer service | December 31, 2026, then every three years | s. 86.1(1)(b), 86.1(3) para. 4 |
| Business or non-profit, 50 or more employees | Yes: six questions, one per standard | December 31, 2026, then every three years | s. 86.1(3) para. 3 |
| Designated public sector organization, any size | Yes, on all standards | Every two years; 2025 was due December 31, 2025; next expected end of 2027 | s. 86.1(3) para. 2 |
| Government of Ontario, Legislative Assembly | Yes | Every year | s. 86.1(3) para. 1 |
Counting employees
Ontario's page says to count full-time, part-time, seasonal and contract employees in Ontario, and not volunteers, independent contractors or employees outside Ontario. The regulation's size classes use the number of employees in Ontario (s. 2). If you hover around 20 or 50, count carefully and keep a note of how you counted.
“We did not know, and we have never filed.”
The reporting cycles for businesses and non-profits were 2014, 2017, 2020, 2023 and now 2026. If your organization had 20 or more employees in those years, those reports were due too. The 2026 report is filed the same way, on Ontario's portal. If you are unsure about earlier cycles, Ontario's page gives the ministry's contact details.
Not filing is not the only duty
Organizations of every size must do what the standards say: serve customers with disabilities as the Customer Service Standards require, train staff, provide accessible formats on request, accommodate in employment. Filing is how organizations with 20 or more employees tell the province they do. See what applies at 20 employees.
The free check asks your type, size, website and filing history and gives you this answer with its citations, in about a minute.
Sources
- O. Reg. 191/11, ss. 1(3), 2, 86.1.
- Ontario: Accessibility rules for businesses and non-profits.
- Ontario: Completing your accessibility compliance report.
Not legal advice. The regulation on e-Laws prevails.