AODA 2005 · O. Reg. 191/11
What changes when you reach 50 employees in Ontario
The Integrated Accessibility Standards Regulation treats 20 and 50 employees as two different worlds. At 20 you file a compliance report. At 50 the obligations become documentary and public: a written policy anyone can read, a multi-year plan reviewed at least every five years, web content that meets WCAG 2.0 level AA, and individual accommodation plans in writing.
The two thresholds, side by side
| Obligation | 1 to 19 | 20 to 49 | 50 or more |
|---|---|---|---|
| Accessibility standards apply | Yes | Yes | Yes |
| Compliance report filed | No | Yes | Yes |
| Policy in writing and public | No | No | Yes |
| Multi-year accessibility plan | No | No | Yes |
| Web content WCAG 2.0 AA | No | No | Yes |
| Individual accommodation plans documented | No | No | Yes |
| Training records kept | Yes | Yes | Yes |
How the count works
Employees who work in Ontario, full time, part time and seasonal. Contractors, agency staff and volunteers are not employees for this purpose. The number is what it is on the day, not an average, and organisations sitting at 48 or 52 should count carefully, because the answer decides four obligations rather than one.
The policy has to be public, not internal
A statement of organisational commitment, available to the public, provided in an accessible format on request. Most organisations already have something in a staff handbook; what section 3 asks for is a document a customer can find, which is a different artefact with a different tone.
The multi-year plan is the one auditors read
It sets out the strategy to prevent and remove barriers, it is posted publicly, it is provided in an accessible format on request, and it is reviewed at least every five years. The plans that fail are the ones with no dates, no owner and no mention of what was achieved since the last review. An inspector comparing the 2021 plan with the 2026 report can see immediately whether anything happened in between.
WCAG 2.0 AA, with the two carve-outs
Section 14 requires public web content to conform to WCAG 2.0 level AA, excluding live captions and pre-recorded audio descriptions. It covers websites and web content controlled directly by the organisation or through a contractual relationship, which pulls in the booking widget, the careers portal and the payment page even when a vendor runs them. The standard is 2.0, older than what European rules point at, so a test run at 2.2 covers it and gives you something useful for buyers as well.
Individual accommodation plans
A written process for documenting accommodations for employees with disabilities, including how the employee participates, how medical evaluation is handled, how privacy is protected, how the plan is reviewed and how it is communicated. Return-to-work processes are documented too. This is the obligation most likely to be missing entirely, because it sits with HR rather than with the team doing the web work.
What the 2026 report asks you to certify
The compliance report is a self-certification signed by an officer in the Accessibility Compliance Reporting portal. At 50 or more employees the questions cover each of the obligations above, and the honest answer requires the underlying documents to exist before the officer signs. Penalties reach 100,000 dollars a day for a corporation and 50,000 a day for a director or officer on conviction, which is why the signature should follow the evidence rather than the other way round.
Training, feedback and formats apply from the first employee
Below the reporting threshold the standards still bite. Staff who deal with the public are trained on accessible customer service and on the Human Rights Code as it relates to persons with disabilities, records of that training are kept, feedback processes are accessible, and information is provided in an accessible format on request within a reasonable time and at ordinary cost.
Organisations that discover the AODA at 20 or at 50 employees usually find these gaps first, because nobody owned them when the company was small.
Where organisations get caught between the two thresholds
Seasonal hiring is the usual trap. A retailer at 44 employees in February sits at 61 in December, and the obligations that come with 50 do not appear and disappear neatly with the payroll. The workable answer is to build for the higher number: a public policy and a plan cost little to maintain and remove the argument entirely.
Acquisitions are the other one. Buying a small Ontario operation moves the combined count across the line, and the obligations land on the acquired staff from the day the payroll merges rather than at the next report cycle.
Federally regulated as well
An Ontario employer that is also federally regulated, a bank, a telecom, an interprovincial carrier, carries the Accessible Canada Act on top: an accessibility plan, a progress report each year between plans by 1 June, a documented feedback process and a notice to the Commissioner within 48 hours of publication. One test can serve both files. See the AODA report in full and the federal obligations.
What we prepare
Policy and multi-year plan written for your organisation and ready to publish, the WCAG test under section 14 run by hand and by crawler and checked against 2.2 as well, each report answer prepared with the document that proves it, a record signed by Goldman Services INC in Ontario with a public code, and a hosted feedback process kept for five years.
Questions we get before buying
Do contractors count towards 50?
No. Full time, part time and seasonal employees working in Ontario count; contractors, agency staff and volunteers do not.
Is the policy the same as the plan?
No. The policy is the statement of commitment; the plan is the strategy with dates, reviewed at least every five years.
Why WCAG 2.0 and not 2.2?
Section 14 names 2.0 level AA. Testing at 2.2 covers it and gives you a report buyers accept.
Does section 14 cover a vendor-hosted booking tool?
Yes, where the content is controlled through a contractual relationship. The vendor being responsible operationally does not move the obligation.
What if we dropped below 50 employees?
The obligations follow the count. Keep the documents: you will be asked what was in place during the period covered by the report.
Who signs the compliance report?
An officer of your organisation, in the reporting portal. No provider can sign it for you.
Are the accommodation plans reported?
The report asks whether the documented process exists. The plans themselves stay confidential.
How often is the multi-year plan reviewed?
At least every five years, and in practice whenever the report cycle comes round, so the two documents agree.
Do the standards apply below 20 employees?
Yes, from the first employee: customer service, feedback, accessible formats and training. What smaller organisations do not have is the report to file.
Can you file the report for us?
No, and nobody can. We prepare every answer with the evidence behind it, and your officer certifies it in minutes.
Get the documents in place before the officer signs
Policy, plan, WCAG record and every report answer with the proof beside it, signed in Ontario.