Deadline approaching for 2026 Ontario accessibility compliance report

With the next accessibility compliance report due on December 31, 2026, organizations operating in Ontario should take this opportunity to review their accessibility practices and ensure they meet Accessibility for Ontarians with Disabilities Act, 2005 (AODA) requirements.

• Why organizations should act now
• Key areas for review
• Understanding the reporting requirements
• Preparing for the December 31 deadline
• Norton Rose Fulbright is available to assist

Why organizations should act now

Although the reporting deadline is a few months away, AODA compliance is not simply a matter of completing a form. Organizations must be able to confirm that they have implemented and maintained the policies, procedures, training and practices required under the AODA. Organizations that wait until the reporting deadline may discover compliance gaps that will require further time and resources to address.

Key areas for review

AODA compliance requirements vary depending on the size of an organization and the nature of the goods, services or facilities it offers to the public. Generally, the accessibility compliance report requires that organizations have met relevant accessibility practices, including:

Accessibility Policies and Training

Organizations should ensure they have an accessibility policy in place and that employees, volunteers, and policymakers have received appropriate accessibility training. Larger organizations should also maintain a documented multi-year accessibility plan.

Accessible Customer Service

Organizations that interact with the public should confirm that customer service policies address accessibility and staff understand how to support customers with disabilities. This includes permitting the use of assistive devices, service animals, and support persons where appropriate.

Employment Practices

Accessibility considerations should be integrated throughout the employment lifecycle. Employers should review recruitment materials and processes, ensure employees are aware of available accommodations, maintain accommodation procedures and consider accessibility needs in performance management and advancement decisions.

Information and Communications

Organizations should be prepared to provide information in accessible formats upon request and ensure publicly available emergency information is accessible. They should also review their public-facing websites and online content to confirm compliance with applicable accessibility standards.

Physical Spaces and Transportation

Where applicable, organizations should assess whether public spaces, facilities and transportation services meet relevant accessibility requirements.

Understanding the reporting requirements

Private-sector organizations and non-profits report on a three-year cycle through Ontario's Accessibility Compliance Reporting Portal. December 31, 2026, is the end of the most recent cycle. Reporting obligations vary based on the number of employees:

• Organizations with 50 or more employees must report on all applicable AODA standards.
• Organizations with 20 to 49 employees are required to report only on accessible customer service compliance.
• Organizations with fewer than 20 employees are not required to submit a report.

When completing the report, organizations must certify whether they comply with the applicable requirements. Any areas of non-compliance should be identified and addressed before filing wherever possible.

Preparing for the December 31 deadline

Organizations should begin their compliance reviews now by surveying existing policies, training records, accommodation processes, accessibility plans, website accessibility measures, and other relevant practices. They should also ensure organizational information, including employee counts and contact details, is up to date for reporting purposes.

Norton Rose Fulbright is available to assist

If your organization requires assistance in preparing for the reporting deadline, please contact a member of the Norton Rose Fulbright employment and labour team. We can support developing policies and plans, provide training, and advise on compliance and reporting requirements.

The author would like to thank Catherine Héroux, articling student, for her contributions to this update.