Aoda Training

AODA Audit Checklist 2026: Free Download for Ontario Businesses

A structured self-assessment covering every major area of AODA compliance — from your website to your HR practices to your policy documentation. Identify your gaps, prioritize where to start, and brief an auditor on areas of concern.

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Before commissioning a professional AODA audit, most organizations want to understand where they stand. This checklist lets you do exactly that — a structured self-assessment covering every major area of AODA compliance, from your website to your HR practices to your policy documentation.

Use it to identify obvious gaps, prioritize where to start, and brief an auditor on areas of concern. It is not a substitute for a professional audit, but it will tell you a great deal about your compliance status in under an hour.

Download the free AODA audit checklist

The full checklist is available as a PDF — formatted for printing, sharing with your team, and working through offline. 61 items across all five compliance areas.

Download Free PDF →
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How to use this AODA compliance checklist

Work through each section with the relevant person in your organization: your web developer or IT team for the website section, HR or a manager for the employment section, your compliance lead or senior management for policies and documentation.

Mark each item as complete, in progress, or not started. Items marked “not started” are your compliance gaps. Items marked “in progress” need a deadline and an owner. The goal is not to achieve a perfect score on the first pass — it is to know exactly where you stand.

Before you start: know your organization size
1–19 employees

Customer Service + IASR training required. No mandatory records or reporting.

20–49 employees

All of the above + compliance report required every 3 years.

50+ employees

All of the above + written policy, accessibility plan, training records, IAP process, return-to-work process — all mandatory.

The AODA compliance audit checklist

A
Website & Digital Accessibility (WCAG 2.0 Level AA)
Website pages can be navigated entirely by keyboard (no mouse required)
All meaningful images have descriptive alt text; decorative images have empty alt text (alt="")
All pre-recorded videos have accurate captions
All live video has captions (if applicable)
Body text meets minimum colour contrast ratio of 4.5:1 against its background
Large text (18pt+ or 14pt+ bold) meets minimum contrast ratio of 3:1
Non-text content (icons, buttons) that conveys meaning meets 3:1 contrast ratio
Colour is not the only visual means of conveying information
All page headings follow a logical hierarchy (H1 → H2 → H3) without skipping levels
Every page has a unique, descriptive <title> element
The page language is declared in the HTML (lang attribute)
All form fields have visible, descriptive labels
Form error messages clearly identify the field with the error and how to fix it
Link text is descriptive — no "Click here" or "Read more" links without context
Skip navigation link is present, allowing keyboard users to bypass repeated header content
No content flashes more than three times per second
Moving, blinking, or scrolling content can be paused, stopped, or hidden
Auto-playing audio can be stopped or muted
PDFs published on the website are tagged for accessibility or available in an alternative format
Word documents and presentations published online are accessible or available in alternative formats
Website includes an accessibility statement explaining compliance status and how to request accommodations
B
Policies & Documentation
Organization has a written accessibility policy
Accessibility policy is publicly available (on website or provided on request) — required for 50+ employees
Accessibility policy has been reviewed and updated within the last 12 months
Organization has a multi-year accessibility plan — required for 50+ employees
Multi-year accessibility plan is posted publicly — required for 50+ employees
Multi-year accessibility plan has been reviewed and updated within the last year
Organization has filed its most recent AODA compliance report with the Ontario government — required for 20+ employees every 3 years
Organization has a written process for receiving and responding to accessibility feedback from customers
Organization has a written procedure for notifying customers when an accessible service or facility is temporarily disrupted
Accessible formats and communication supports are available on request at no extra cost
Emergency procedures are available in accessible formats for employees with disabilities — required for 50+ employees
C
Staff Training
All current full-time employees have completed Customer Service Standard training
All current part-time, seasonal, and casual employees have completed Customer Service Standard training
All volunteers have completed Customer Service Standard training (if they interact with the public or develop policies)
All third-party contractors who serve customers on the organization's behalf have completed Customer Service Standard training
All employees have completed IASR training, including content on the Ontario Human Rights Code
Managers and HR staff have completed Employment Standard training (IAPs, accessible recruitment, return-to-work)
Digital and content staff have been trained on WCAG 2.0 Level AA requirements
AODA training is part of the onboarding process for new hires
Training has been updated and re-delivered whenever accessibility policies changed
Training records exist for all current employees showing what was completed and when — required for 50+ employees
Training content has been reviewed within the last 12 months
D
Employment Practices
All job postings include a statement that accommodation is available for applicants with disabilities
When inviting candidates to interviews, applicants are notified that accommodation is available on request
When accommodation is requested by a candidate, it is provided in a format that meets their needs
Successful applicants are informed of the organization's accommodation policies in the job offer
New employees are informed of accommodation support policies as part of onboarding
Employment information (offer letters, training materials, performance reviews) is available in accessible formats on request
Organization has a documented Individual Accommodation Plan (IAP) process — required for 50+ employees
IAPs are reviewed regularly and updated when the employee's circumstances change
Organization has a documented return-to-work process for employees returning from disability-related absence — required for 50+ employees
Performance management and career development processes account for the accessibility needs of employees with disabilities
E
Customer Service Practices
Staff know how to interact respectfully with customers who have various types of disability
Staff know how to assist customers who use assistive devices (wheelchairs, white canes, hearing aids)
Staff know the organization's policy on service animals and support persons
Staff know how to provide or arrange accessible formats of information when requested by a customer
Staff know what to do when a customer with a disability is having difficulty accessing goods or services
The organization has a process for customers to provide feedback about accessibility and receives that feedback
Customers know how to provide accessibility feedback (information is publicly posted)
When a service disruption affects accessibility (e.g. ramp under repair), affected customers are notified with alternatives
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How to interpret your checklist results

Once you have worked through each section, you will have a picture of where your organization stands. Here is how to read what you find.

Result What it means What to do next
All items complete in a section Your organization is likely compliant in this area at the time of assessment Document the date of assessment. Schedule a review in 12 months or when policies change.
1–3 items not complete Minor gaps that are unlikely to trigger enforcement on their own, but represent real risk Assign an owner and a completion deadline for each gap. Address within 30–60 days.
4–7 items not complete Significant gaps. If a complaint or audit occurs, these will be found Prioritize by impact. Consider a professional audit to get a full picture before filing any compliance report.
8+ items not complete in a section Substantial non-compliance. Immediate attention required Commission a professional AODA audit. Do not file a compliance report until gaps are understood and addressed.
If you have 10 or more items not complete in Section A, your website has significant accessibility barriers. Automated tools alone will not reveal all of them. A professional website accessibility audit is the most efficient way to get a complete, prioritized remediation list.
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What a professional AODA audit adds that this checklist cannot

A self-assessment checklist tells you whether things are in place. A professional audit tells you whether they work.

Website: depth of testing

A checklist confirms that alt text exists. A professional audit confirms that the alt text is accurate and useful — not placeholder text, not filename dumps. It tests how a screen reader actually navigates your site, not just whether technical attributes are present.

Policies: substance, not just existence

A checklist confirms you have a written accessibility policy. A professional audit reviews whether the policy contains everything it needs to, whether it reflects current regulatory requirements, and whether it matches how your organization actually operates.

Training: records versus reality

A checklist confirms training records exist. A professional audit reviews whether the training covered everything it needed to, whether records are complete and properly formatted for audit purposes, and whether any groups were missed.

Employment: process versus practice

A checklist confirms a documented IAP process exists. A professional audit confirms the process meets the IASR's requirements, has been used when needed, and is accessible to employees who need it.

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The most common AODA compliance gaps we find

Based on audit experience across Ontario organizations of all sizes, these are the gaps that appear most frequently — and the ones most likely to surface in a government audit or complaint investigation.

Compliance area Most common gap Why it matters
Website Keyboard navigation failures — interactive elements that cannot be reached or operated without a mouse Prevents users with motor impairments, blind users using keyboard navigation, and switch access users from completing tasks
Website Missing or meaningless alt text on images — absent, filename-based, or generic Prevents blind users from accessing visual information. WCAG 1.1.1 failure — one of the most commonly cited in audits
Website Colour contrast failures — text that is too light against its background Affects users with low vision and colour blindness. Often widespread and requires design-level fixes
Training No training records for staff hired in the past 2+ years Makes it impossible to demonstrate compliance for any staff member without records. High-risk in government audits
Training Training covers generic AODA content but not the organization's own accessibility policies Specific policy content is a legal requirement under the Customer Service Standard, not optional
Policies No multi-year accessibility plan, or a plan that was created once and never updated Required for organizations with 50+ employees. An outdated plan demonstrates the organization has not actively managed compliance
Employment Job postings and interview invitations do not include accommodation statements A simple, low-cost requirement that is widely missed. Generates significant exposure under both AODA and the Human Rights Code
Documentation Compliance report not filed, or filed without understanding what the declaration covers Filing a false compliance report carries the same penalties as non-compliance. Organizations must actually be compliant before filing

Frequently asked questions

Is this checklist sufficient to demonstrate AODA compliance?
  • No. A self-assessment checklist documents your review of compliance items at a point in time. It does not carry the same weight as a professional audit report or verify that what is in place actually works. For organizations filing a compliance report, responding to a government audit, or addressing a complaint, a professional audit provides significantly stronger evidence of compliance.
  • At minimum, annually — and whenever significant changes occur: a website redesign, a change in organizational size that crosses the 20 or 50-employee thresholds, an update to your accessibility policies, or following a complaint about accessibility. The checklist is most useful as a living document that your organization returns to regularly rather than a one-time exercise.
  • Prioritize the gaps by risk: website accessibility issues that prevent users from completing core tasks, missing training records, and absence of required policies carry the highest compliance risk. For significant gaps, particularly in the website section, commission a professional accessibility audit to get the full picture. Do not file an AODA compliance report before gaps are understood and addressed.
  • Not in itself. Working through the checklist and documenting the results does demonstrate that your organization is actively managing its compliance obligations — which matters in enforcement contexts. But the protection comes from actually fixing the gaps the checklist identifies, not from having completed the checklist.
  • The Ontario government’s compliance reporting tool asks organizations to declare whether they have met specific AODA requirements. This checklist helps you assess whether those requirements are actually met before you make that declaration. It is a preparation tool, not a reporting tool.

Get the full checklist — free PDF download

The printable version includes all 61 items across all five sections, with checkboxes and space for notes. Formatted for team workshops, management review, and audit preparation.