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Key Takeaways:
- Many Ontario employers must file an Accessibility Compliance Report by December 31, 2026.
- Website accessibility obligations under WCAG 2.0 Level AA remain in effect and require ongoing compliance.
- Non-compliance with the AODA may result in enforcement action or penalties.
Ontario employers should ensure they remain up to date with compliance requirements under the Accessibility for Ontarians with Disabilities Act (the “AODA”), which establishes accessibility standards and requires employers to ensure that workplace policies and practices are accessible to both prospective and current employees with disabilities.
The AODA applies to all organizations in Ontario (public, private, and not-for-profit) with one or more employees. However, specific obligations vary based on an organization’s size and sector. For example, businesses and non-profits with fewer than 20 employees are generally not required to file Accessibility Compliance Reports, although they remain subject to certain AODA obligations.
Whether an organization must file an Accessibility Compliance Report in 2026 depends on its size and sector. Private and not-for-profit organizations with 20 or more employees, as well as designated public sector organizations, are generally required to file by December 31, 2026.
The AODA mandates ongoing compliance obligations and periodic reporting deadlines, which are outlined below.
2026 AODA Compliance Reports: Who Must File and Key Deadlines
Organizations subject to the AODA are required to file Accessibility Compliance Reports, which are self-assessments outlining their current compliance with applicable accessibility standards.
The next reporting deadlines are as follows:
- December 31, 2026 – Designated public sector organizations, including municipalities and other organizations listed in Schedule 1 of Ontario Regulation 191/11 or Table 1 of Ontario Regulation 146/10, must file an Accessibility Compliance Report.
- Organizations that missed last year’s deadline must still file a 2025 report even though the deadline has passed.
- December 31, 2026 – Private sector organizations and not-for-profit organizations with 20 or more employees must file an Accessibility Compliance Report.
Accessible Websites: Ongoing WCAG 2.0 Requirements
The AODA also imposes obligations relating to digital accessibility. Web Content Accessibility Guidelines (“WCAG”) 2.0 is an internationally recognized web accessibility standard developed by the World Wide Web Consortium (W3C).
- As of January 1, 2021 – Large private sector and not-for-profit organizations (50 or more employees) and all public sector organizations must ensure that all public websites and web content published after January 1, 2012, meets the WCAG 2.0 Level AA standard, other than live captions and pre-recorded audio descriptions (criteria 1.2.4 and 1.2.5).
The Ontario government has posted guidelines to assist employers in meeting these standards. These obligations apply on an ongoing basis and should be reviewed periodically to ensure continued compliance.
Employers should review their AODA compliance obligations by these deadlines. Failure to meet applicable requirements may result in enforcement action or penalties.
If you have any questions about your organization’s obligations, including accessibility reporting, website compliance, or broader AODA requirements, please contact any of our Ontario Labour & Employment lawyers.
Thank you to Emily Strike, Articling Student, who assisted with the preparation of this blog post.
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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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