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What your AODA compliance report must include

· 2 min read

In briefOrganizations with 20 or more employees in Ontario must file an AODA compliance report by 31 December 2026 in the Accessibility Compliance Reporting portal. The report is a self-certification signed by a senior officer; no third party can file it on your behalf. Behind the signature must sit four documents: a written accessibility policy, a multi-year accessibility plan, a WCAG test of public web content, and a dated signed record.
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Organizations with 20 or more employees in Ontario must file an AODA compliance report by 31 December 2026. The report is filed in the Accessibility Compliance Reporting portal. It is a self-certification: a senior officer of the organization signs it. No external provider can complete that step.

What the four required documents are

The signature on the report needs evidence behind it. Four documents make up that file:

All four relate directly to the obligations set out under the Accessibility for Ontarians with Disabilities Act, 2005 and its Integrated Accessibility Standards Regulation (O. Reg. 191/11).

How the threshold at 50 employees changes your obligations

At 20 employees, you must have the documents and file the report. At 50 or more employees, the requirements increase:

Employee count includes full-time, part-time, and seasonal staff who work in Ontario. Contractors, agency staff, and volunteers are not counted. The count matters: 49 employees and 50 employees face different obligations.

What happens if the report is not filed

The Accessibility Directorate of Ontario can inspect, issue orders, and apply administrative penalties. On conviction, a corporation faces fines of up to 100,000 dollars for each day the offence continues. Directors or officers face fines of up to 50,000 dollars per day.

Missing one reporting cycle is common. Missing two is a pattern an inspector notices. The deadline — 31 December 2026 — is written in the regulation, not set by any service provider.

How the report cycle works

AODA compliance reports are due every three years. The 2026 deadline follows the 2023 cycle. Organizations that missed 2023 should file in 2026 and retain evidence of what is currently in place. The report is not a government certification and no private company can issue one. Ontario does not certify organizations; the report is a dated record of your own self-assessment.

One annual fee covers all four documents, the WCAG test, and any retesting needed during the year — no charge per page or per retest.

Key points

  • The AODA compliance report deadline is 31 December 2026 for organizations with 20 or more employees in Ontario.
  • Only a senior officer of the organization can sign and file the report; no third party can do it on their behalf.
  • Four documents must sit behind the signature: an accessibility policy, a multi-year plan, a WCAG test, and a dated signed record.
  • At 50 or more employees, policies must be public, the plan reviewed at least every five years, and individual accommodation plans documented.
  • Fines on conviction reach up to 100,000 dollars per day for corporations and 50,000 dollars per day for directors or officers.

Frequently asked questions

Who has to file an AODA compliance report in 2026?

Private businesses and non-profit organizations with 20 or more employees in Ontario. The deadline is 31 December 2026 and reports are filed in the Accessibility Compliance Reporting portal.

Can a third-party provider file the AODA report for us?

No. The report is a self-certification that must be signed by a senior officer of your organization. A provider can prepare all the supporting documents, but your officer must submit the report.

How do we count employees for the AODA threshold?

Count full-time, part-time, and seasonal employees who work in Ontario. Contractors, agency staff, and volunteers are excluded. The thresholds at 20 and 50 employees each trigger different obligations, so count carefully.

What changes at 50 employees under the AODA?

Accessibility policies must be written and made public, the multi-year accessibility plan must be reviewed at least every five years, and individual accommodation plans for employees with disabilities must be documented.

What are the penalties for not filing an AODA compliance report?

The Accessibility Directorate of Ontario can inspect and issue orders. On conviction, corporations face fines of up to 100,000 dollars per day and directors or officers up to 50,000 dollars per day.

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