Who has to file an AODA compliance report?
The Accessibility for Ontarians with Disabilities Act (AODA) says organizations covered by an accessibility standard file accessibility reports when a director specifies (section 14). For businesses and non-profits, section 86.1 of the regulation sets the cycle: every three years, for organizations with 20 or more employees in Ontario. Those with 20 to 49 employees report only on the Customer Service Standards.
Count full-time, part-time and seasonal employees and contract workers in Ontario. Do not count employees outside Ontario, volunteers or independent contractors. A store based in Alberta with 30 staff and 3 in Ontario counts 3.
| Employees in Ontario | Do you file? | Questions you answer |
|---|---|---|
| 1 to 19 | No, but you may choose to | 1, if you file |
| 20 to 49 | Yes, by December 31, 2026 | 1, on customer service |
| 50 or more | Yes, by December 31, 2026 | 6 |
Under 20 employees, you still have AODA duties, such as accessible customer service, accessible feedback and staff training. Our AODA guide for online stores sets out every duty by size.
When is the AODA compliance report due?
For businesses and non-profits, the deadline is December 31, 2026. Ontario's reporting page (updated February 19, 2026) and its rules for businesses page (updated June 16, 2026) both give that date. Reports are filed every three years. Ontario had not published the date of the following report when we checked on October 17, 2026.
Designated public sector organizations, such as municipalities and school boards, file every two years and had a December 31, 2025 deadline. This page is about the business form.
What you need before you start
Have these ready
- Legal name
- The legal name of the business, not only the store name shoppers see
- Business number
- Your 9-digit CRA business number (BN9), the one on your tax return. Public sector bodies without one get an AODA identifier from the ministry.
- Headcount
- Number of employees in Ontario, counted as above
- Addresses
- Business address and mailing address
- Certifier
- Name, title, phone and email of a director or senior officer with authority to bind the organization
- Primary contact
- The person the ministry should contact, if not the certifier
- An email you will keep
- The portal account is tied to it. If you forget it, you start a new account and lose saved work.
The portal lets you save a draft and come back. It also has a Print Form option that gives you a blank copy, so the certifier can read the questions before anyone fills them in. You can work on paper, but everything must still be entered in the portal to submit.
What questions does the AODA compliance report ask?
The questions follow the parts of Ontario's Integrated Accessibility Standards (O. Reg. 191/11). Each one reads the same way. Question 1, for example, asks: “Is your organization in compliance with all applicable requirements of the General Section?” You answer yes or no, and you can add a comment either way. Each question links to the part of the regulation it covers.
Businesses with 50 or more employees in Ontario answer these six:
| Question | What it covers | What it means for an online store |
|---|---|---|
| 1. General | Policies, a statement of commitment, a multi-year accessibility plan and training (Part I) | A written policy and multi-year plan, the plan posted on your store, and staff trained with records kept. |
| 2. Information and Communications | Feedback, accessible formats, emergency information and websites (Part II) | Your Shopify store, your contact options, and how you answer a request for another format. |
| 3. Employment | Recruitment, accommodation, return to work (Part III) | Your careers page and hiring process. |
| 4. Transportation | Whether you provide transportation services and, if yes, whether you meet Part IV | Part IV is about passenger services such as transit and school transport. Most online stores answer no. |
| 5. Design of Public Spaces | Public spaces you build or redevelop (Part IV.1) | Only matters if you have a shop, service counter or parking you built or redid. |
| 6. Customer Service | Serving customers with disabilities (Part IV.2) | Phone, email, chat and in-person service, including service animals and support persons. |
Businesses with 20 to 49 employees answer one compliance question, according to the portal's user guide (February 2026). Section 86.1 of the regulation limits their report to the Customer Service Standards (Part IV.2), so the question is about serving customers with disabilities. Ontario does not publish its exact wording online, so use Print Form to read it before you start.
If you answer no, a list of checkboxes appears so you can mark which areas are not met, with an “Other” box for details.
How to answer the website part honestly
For a business with 50 or more employees in Ontario, question 2 includes the website rule. Section 14 of the regulation says large organizations must make their public websites and web content meet WCAG 2.0 Level AA, other than live captions (1.2.4) and audio description for recorded video (1.2.5). That has applied to all public websites since January 1, 2021. It covers content you control directly or through a contract that lets you change it, “except where meeting the requirement is not practicable”.
Question 2 also covers duties that apply at every size:
- Feedback (section 11). Your feedback process must be accessible, and you must tell the public that accessible formats are available for it.
- Accessible formats (section 12). On request, provide information in a format the person can use, in a timely way and at no more than your regular cost, and tell the public you do this.
Before the certifier answers yes for a Shopify store, check these:
- Run the free accessibility checker on your home page, a collection, a product page and the cart.
- Shop with only a keyboard: open the menu, pick a variant, add to cart and reach checkout. Then try a screen reader (VoiceOver or NVDA, both free).
- Check your contact page. Is the form labelled, and is there an email or phone number as well?
- Check that an accessibility page says how to ask for another format. In Shopify, add it under Online Store > Pages and link it in your footer under Content > Menus. The accessibility statement generator drafts the text.
- Write down what Shopify controls. Shopify builds checkout, so keep its checkout accessibility report on file and check the colours you set in Settings > Checkout.
Software can fully test only part of WCAG, so the hand checks matter. WCAG 2.2 AA includes everything in 2.0 AA, so working toward WCAG 2.2 AA, explained for store owners covers Ontario's rule too.
Keep the evidence behind each yes
How to file the report, step by step
- 1
Open the portal
Go to the Accessibility Compliance Reporting Portal at accessibilityreporting.ontario.ca. It is also listed in Ontario's Central Forms Repository under the Ministry for Seniors and Accessibility. - 2
Create your account
Select Sign In / Create Account, then Create Account. Enter an email address and a password, type in the verification code Ontario emails you, and add your name and phone number. - 3
Start a new report
Open the menu, choose New Submission, find Accessibility Compliance Report and select Begin Submission. - 4
Choose your category and size
Select Business / Non-profit, then your employee range in Ontario: 20 to 49 or 50 and more. These two choices decide which questions you get. - 5
Add your organization
Select Add New and enter the legal name, business number (BN9), number of employees in Ontario, business address and mailing address. - 6
Certify
The certifier ticks the statement that the information is accurate and that they have authority to bind the organization, enters the date, and adds their details and a primary contact. - 7
Answer the compliance questions
Answer yes or no to each question. If you answer no, tick the areas that are not met. Add comments to explain either answer. - 8
Review and submit
Check the summary page, go back to fix anything, then select Submit. If any answer is no, a reminder appears before you confirm. - 9
Keep the confirmation
Ontario emails a confirmation number to the certifier and the primary contact. Save it with your evidence.
You can file for up to 20 organizations on one form, but only if they share the same category, employee range, certifier and answers to every question. Otherwise, file one report each.
After you file
- Make the report public. Section 14(2) of the Act says you must make the report you filed available to the public. Posting it on your website is the simplest way. In Shopify, upload the PDF in Content > Files and link it from your accessibility page.
- Keep your profile current. If your address, contact, headcount or status changes, file an Organization Profile Update in the same portal.
- Keep your evidence. Store the confirmation email, the certifier's notes and your test records together.
- Plan the next report. Put a reminder in your calendar for three years from now, and recheck it against ontario.ca when the date is announced.
If you answer no, or you file late
An honest no is better than a yes you cannot back up. Section 37 of the Act makes it an offence to give false or misleading information in an accessibility report, with fines on conviction of up to $100,000 a day for a corporation and $50,000 a day for an individual.
If you answer no, use the comments to say what you are fixing and by when, then fix it. The portal shows a reminder before you submit a report with a no answer.
If you miss the deadline, file as soon as you can. Under section 21(3) of the Act, a director can order you to file within a set time and can issue an administrative penalty. The regulation sets the amount by how serious the breach is and your history (section 83). Our AODA guide lists the penalty ranges and how they have been applied.
Common mistakes
- Counting only full-time staff, or counting staff outside Ontario.
- Having someone sign who cannot bind the organization, such as a junior employee.
- Answering yes on the website part without testing the site, or with only a widget installed.
- Forgetting the email used for the portal account and losing a saved draft.
- Putting several companies on one form when their answers differ.
- Filing, then not posting the report where the public can see it.
How Inclusely helps
AODA compliance report questions
When is the AODA compliance report due?
For businesses and non-profits with 20 or more employees in Ontario, the deadline is December 31, 2026. Reports are filed every three years. Designated public sector organizations had a different deadline, December 31, 2025, and must still file if they missed it.
Who has to file an AODA compliance report?
Every business and non-profit with 20 or more employees in Ontario. Count full-time, part-time, seasonal and contract workers in Ontario. Do not count staff outside Ontario, volunteers or independent contractors. Organizations with 1 to 19 employees do not have to file, but must still follow the AODA.
How do I file my AODA compliance report?
Online, in the Accessibility Compliance Reporting Portal (accessibilityreporting.ontario.ca). Create an account, start a new Accessibility Compliance Report, enter your organization details and business number, have a senior officer certify it, answer the yes or no questions and submit. A confirmation number is emailed to you.
What questions does the AODA compliance report ask?
Businesses with 50 or more employees answer 6 questions: one for each part of the Integrated Accessibility Standards (General, Information and Communications, Employment, Design of Public Spaces and Customer Service) and one asking whether you provide transportation services. Businesses with 20 to 49 employees answer 1 question, and the regulation limits their report to the Customer Service Standards.
Do I need an audit or proof to file the report?
No. The report is a yes or no self-assessment, and the form has no step for uploading evidence. But the certifier signs that the answers are accurate, giving false or misleading information is an offence, and the ministry can review your report. Keep the evidence behind each yes.
What happens if I miss the AODA reporting deadline?
File as soon as you can. A director can order you to file within a set time and can issue an administrative penalty, and the amount depends on how serious the breach is and your history. Ontario's page warns that failing to file may lead to enforcement, including financial penalties.
Does the AODA compliance report ask about my website?
Indirectly. For businesses with 50 or more employees, the Information and Communications question covers the website rule: public websites must meet WCAG 2.0 Level AA, except live captions and audio description. For 20 to 49 employees, the report covers only the Customer Service Standards and the website rule does not apply, though feedback and accessible format duties still do.
What to do next
This page explains the law in general terms. It is not legal advice. For advice about your business, speak with a lawyer.