On June 6, 2016, the Ontario government announced impending
changes to the AODA's Accessibility Standards for Customer
Service. The Customer Standard will be included in the
Integrated Accessibility Standards Regulation, creating a
streamlined resource for organizations to better understand their
obligations with respect to accessibility. In tandem with
this change, certain elements of the Customer Standard were
This post provides a summary of the key changes to the Customer
Standard, which will come into effect on July 1, 2016.
Large and Small Organizations
Previously, the Customer Standard and Integrated Standard had
different definitions of "large" and "small"
organizations, and certain requirements were differentiated on this
As of July 1, 2016, the Customer Standard's definition will
change, in that a large organization will be one with 50 or more
employees, and a small organization will be one with fewer than 50
employees, in Ontario.
This shift in the definitions means that organizations with less
than 50 employees in Ontario will no longer be obligated to reduce
to writing certain aspects of the Customer Standard (i.e. policies,
notice of disruptions, feedback process, training records, and
notification of availability of policies).
The Customer Standard currently requires that training must be
provided to the employees of an organization that interact with
customers or develop policies. As of July 1, 2016, all employees and
volunteers of an organization must receive this training,
regardless of whether they interact with customers or develop
policies. This will require not only a broader training
exercise, but also an update of the organization's Customer
Standard policy, to reflect the new training scope.
While you do not need to re-train members of your organization
who have already been trained on the Customer Standard, you must
inform them about the changes and the updated accessible customer
Service Animals and Support Persons
Currently, the Customer Standard states that if a service animal
cannot be easily identified, a note from a physician or nurse
confirming the relationship may be requested. This requirement has
been broadened to allow regulated health professionals to provide
Also expanded are those elements that an organization must
consider before requiring that a person with a disability be
accompanied by a support person due to health and safety
reasons. Before reaching such a determination, the
organization must: (i) consult with that person to understand their
needs; (ii) consider health and safety reasons based on available
evidence; and (iii) determine if there is no other reasonable way
to protect the health and safety of the person or others on the
premises. If your organization decides that a support
person is required, the amount payable on admission for the support
person must be waived.
The Customer Standard currently requires that organizations
provide a way for customers who have disabilities to provide
feedback on how the organization provides accessible customer
service. As of July 1, 2016, organizations must ensure that
this feedback process is accessible, by providing or arranging for
accessible formats and communication supports, on request.
Large organizations must not only reduce their Customer Standard
policy to writing and make it available upon request, but must also
provide it in an accessible format or with a communication support,
All organizations must comply with these changes effective July
1, 2016. It is important for your organization to update its
accessible customer service policy to reflect the aforementioned
changes, and to file your 2017 accessibility compliance report by
December 31, 2017.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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