Accessibility StatementA Delaware company told me last week they were "out of scope" because they have no Canadian entity.
They have 25 people working in Toronto.
They file.
76 days to 31 December 2026.
Three situations. One of them is yours.
A) Your head office is outside Canada and you assumed that settles it.
B) Your head office is in another province and you assumed the same.
C) You know you have people in Ontario but you are not sure who counts.
The test is simpler than most people expect, and it has nothing to do with where your company is registered. The AODA follows your employees, not your head office. Head office: zero weight in the test. People working in Ontario: that is the whole question.
Who counts:
— full-time employees working in Ontario — yes
— part-time and seasonal — yes
— remote employees who live and work in the province — yes
Who does not:
— contractors
— agency staff
— volunteers
Count them on the day you file. Twenty or more in the province, and the compliance report is yours. Franchise systems count per legal entity, so each franchisee is its own organization, which often means a chain of thirty locations has no reporting obligation at all while one corporate office does.
And because it works both ways: if nobody works in Ontario, the AODA does not apply to you, whatever your customers are. We will tell you that rather than sell you a file you do not owe.
What each size owes differs too. From 20 to 49 employees: the report, written policies, training records, an accessible feedback process. At 50 or more: all of that, plus the published multi-year plan and public web content at WCAG 2.0 AA.
Write A, B or C in the comments. I answer every one personally and tell you whether your headcount puts you in scope.
Then send this to whoever does your payroll — they are the only person who knows the real number.
