AODA Compliance Checklist for Ontario Businesses (2026)

A complete AODA compliance checklist covering 55+ items — training, policies, customer service, employment, and website accessibility — organized by headcount tier.

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This checklist covers every major AODA obligation for Ontario businesses, organised by headcount tier. Work through the sections that apply to your organization, mark each item as complete or not started, and use the result to prioritize your next compliance steps.

The checklist is structured for practical use: each section can be worked through with the relevant team in under an hour. A ‘not started’ item is a compliance gap. An ‘in progress’ item needs a deadline and an owner.

Confirm your headcount tier before you start

AODA obligations scale with employee count. Confirm which tier applies before working through the checklist:

1–19 employees:

Sections A, B (partial), C, E apply.
20–49 employees:

All of the above + Section D (compliance reporting).
50+ employees:

All sections apply in full.

Count all workers — full-time, part-time, seasonal, casual, and regular contractors.

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Download the Printable Version

The checklist below is the full online version. A print-ready PDF — formatted with larger checkboxes, space for notes, and a gap summary template — is available as a free download.

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Download the free AODA compliance checklist (PDF)

Includes all sections below, formatted for printing and team workshops. Enter your email to receive it directly.

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The AODA Compliance Checklist

A. Staff Training

Applies to: all organizations with 1+ employee

All full-time employees have completed Customer Service Standard training

All part-time, seasonal, and casual employees have completed Customer Service Standard training

All volunteers who interact with the public or help develop policies have completed Customer Service Standard training

All third-party contractors who deliver services to customers on the organization's behalf have completed training

All employees have completed IASR training, including Ontario Human Rights Code content

Managers and supervisors have completed Employment Standard training (IAPs, accessible recruitment, return-to-work)

Digital and content staff have been trained on Information & Communications Standard requirements (WCAG 2.0 Level AA)

AODA training is part of the onboarding process for every new hire

Training has been updated and re-delivered whenever accessibility policies changed

Training covers the organization's specific accessibility policies — not just generic AODA content

Training records exist for all current employees (required for 50+ employees; best practice for all)

B. Policies & Documentation

Items marked * required for 50+ employees only

Organization has a written accessibility policy *

Accessibility policy is publicly available (on website or on request) *

Accessibility policy has been reviewed and updated within the last 12 months *

Multi-year accessibility plan has been created and is publicly posted *

Multi-year accessibility plan has been reviewed and updated within the last year *

Organization has a written process for receiving and responding to accessibility feedback from customers

Organization has a written procedure for notifying customers when accessible services are temporarily disrupted

Accessible formats and communication supports are available on request at no extra cost

Emergency procedure information is available in accessible formats for employees with disabilities

Individualized workplace emergency response information is prepared for employees with disabilities who need it *

C. Customer Service Practices

Applies to: all organizations with 1+ employee

Staff know how to interact respectfully with customers who have various types of disability

Staff know the four principles of accessible customer service: dignity, independence, integration, equal opportunity

Staff know how to assist customers using wheelchairs, white canes, hearing aids, and other assistive devices

Staff know the organization's policy on service animals — customers cannot be denied service because of a guide dog or service animal

Staff know the organization's policy on support persons — customers cannot be denied access to a support person

Staff know what to do when a customer with a disability is having difficulty accessing goods or services

Staff know how to provide or arrange accessible formats of information when a customer requests them

Customers know how to provide accessibility feedback — information is publicly available

When a service or accessible facility is temporarily disrupted, affected customers are notified with alternatives

D. Compliance Reporting

Applies to: organizations with 20+ employees

Organization has filed its most recent AODA compliance report with the Ontario government

The compliance report was filed on time (every 3 years; check ontario.ca/aoda for your last filing and next due date)

The compliance report accurately reflects the organization's actual compliance status at the time of filing

The organization is prepared to demonstrate compliance if audited following its compliance report filing

Directors and officers are aware of their personal liability under AODA for compliance report accuracy

E. Employment Practices

Items marked * required for 50+ employees only

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 a candidate requests accommodation for a selection process, it is provided in a format that meets their needs

Successful candidates are notified 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 *

IAPs are reviewed regularly and updated when an employee's circumstances change *

Organization has a documented return-to-work process for employees returning after a disability-related absence *

Performance management and career development processes account for accessibility needs of employees with disabilities

F. Website & Digital Accessibility

Scope varies by size — see notes in section

Website pages can be navigated entirely by keyboard alone (no mouse required)

All meaningful images have descriptive alt text; decorative images use empty alt text (alt="")

All pre-recorded videos have accurate, reviewed captions

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

All page headings follow a logical hierarchy (H1 → H2 → H3) without skipping levels

Every page has a unique, descriptive page title

All form fields have visible, descriptive labels

Form error messages identify the field with the error and explain how to fix it

Link text is descriptive — no "Click here" or "Read more" links without context

A skip navigation link is present on every page

PDFs and documents published online are tagged for accessibility or offered as accessible alternatives

Website includes an accessibility statement noting compliance status and how to request accessible formats

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How to Interpret Your Results

Once you have worked through the checklist, count the unchecked items in each section. The table below tells you what your results mean and what to do next.

Unchecked items	Risk level	What to do
0 items unchecked in a section	Compliant in this area	Document the date of assessment. Schedule a review in 12 months or when policies change.
1–2 items unchecked	Low — minor gaps	Assign an owner and a 30-day deadline for each unchecked item. Low urgency but real compliance exposure.
3–5 items unchecked	Medium — significant gaps	Prioritize remediation. These gaps represent real risk if a complaint is filed or a review is triggered.
6+ items unchecked in a section	High — substantial non-compliance	Act immediately. Commission professional training, update policies, and address website issues without delay. Do not file a compliance report until major gaps are resolved.

Special note on Section F (website)

Six or more unchecked items in Section F typically indicates significant inaccessibility that affects real users right now. A free automated scan using WAVE or axe DevTools on your key pages will surface the highest-impact issues without cost. For a complete picture, a professional accessibility audit is recommended.

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The Most Commonly Unchecked Items

Across Ontario organizations of all sizes, these are the compliance items most frequently left unchecked — and the ones that generate the highest enforcement and complaint risk.

Section	Most common unchecked item	Why it matters
A — Training	New hires have never received training — records only exist for original staff	Every untrained hire is an ongoing violation. Onboarding is the fix — it takes 30 minutes per person and costs nothing with online training platforms.
A — Training	Training covers generic AODA content but not the organization's own accessibility policies	The Customer Service Standard specifically requires training on the organization's own policies. Generic training alone does not satisfy this requirement.
B — Policies	No written process for receiving accessibility feedback from customers	This is a universal requirement at 1+ employee, not just for large organizations. A contact email on your website satisfies it.
B — Policies	Multi-year accessibility plan not created or not publicly posted	Required for organizations with 50+ employees. Many organizations in this bracket have never created a plan. The government provides a template.
D — Reporting	Compliance report not filed or filed late	Non-filing is itself an AODA violation and is one of the primary ways organizations are selected for compliance reviews.
E — Employment	Job postings and interview invitations do not include accommodation statements	A simple, low-cost requirement missed by the majority of organizations. One sentence added to posting templates resolves it permanently.
F — Website	Missing alt text on images across the site	One of the highest-volume WCAG failures in any sector. Affects blind users directly. Fixable through content editor training and a CMS workflow update.
F — Website	Keyboard navigation failures — menus and interactive elements require a mouse	Prevents blind users and users with motor impairments from using key site functionality. Requires developer involvement to fix.

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Using This Checklist Before Filing Your AODA Compliance Report

Organizations with 20 or more employees must file an AODA compliance report every three years. The report is a legal declaration that your organization meets applicable AODA requirements.

This checklist is the practical preparation tool for that filing. Work through every section that applies to your organization. Every unchecked item represents a requirement you cannot honestly declare as met. Address the gaps before filing — not after.

Do not file a compliance report until you can check most items in the applicable sections

Filing a compliance report when your organization is materially non-compliant creates personal liability for directors and officers who sign the declaration — in addition to organizational liability for the underlying violations. The compliance report is a legal document. Treat it accordingly.

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Frequently asked questions

How often should I run through the AODA compliance checklist?

At minimum, annually — and whenever a significant change occurs: a website redesign or relaunch, a change in headcount that crosses the 20 or 50 employee thresholds, a revision to your accessibility policies, a new complaint, or when your compliance report cycle is approaching. The checklist is most useful as a living document your organization returns to regularly rather than a one-time exercise.

Does completing the checklist demonstrate AODA compliance?

No. Working through the checklist and documenting the results demonstrates that your organization is actively reviewing its compliance obligations — which matters in enforcement contexts. The compliance protection comes from actually meeting the requirements the checklist identifies, not from having completed the checklist itself. A checklist with many unchecked items is not compliance evidence; it is a gap analysis.

Can I use this checklist for my AODA compliance report?

The checklist is preparation for the compliance report, not a substitute for it. The Ontario government’s compliance report is filed through the Accessibility Directorate’s online portal at ontario.ca/aoda. The checklist helps you confirm that the requirements you are declaring as met in that report are genuinely met.

My organization has 18 employees. Which sections apply to me?

At 18 employees, Sections A (training), B (policies — excluding items marked with *), C (customer service practices), and F (website) all apply. Section E (employment practices) also applies for the non-asterisked items — accessible recruitment statements, notifying candidates of accommodation, informing new employees of support policies, and providing accessible employment information on request. Section D (compliance reporting) and the asterisked items in B and E apply only once you reach 20 and 50 employees respectively.

We have no written accessibility policy. Where do we start?

The Ontario government provides a sample accessibility policy template at ontario.ca/aoda — it can be adapted to your organization in under an hour. A compliant accessibility policy covers your commitment to accessible service, how staff are trained, your approach to assistive devices and service animals, how customers can provide accessibility feedback, and your service disruption procedure. Once written, it must be shared with all staff — and training must cover it specifically.

What's the fastest way to fix the most common compliance gaps?

The three highest-impact steps that most organizations can complete within a week: (1) enrol all untrained staff in an AODA training course and add it to your onboarding checklist; (2) add a one-sentence accommodation statement to every job posting template; (3) add a one-line accessibility feedback contact to your website footer or contact page. Together these address the three most frequently unchecked items across all organization sizes and cost nothing except staff time.

On this page

01 How to use this checklist 02 Download printable PDF 03 The full checklist 04 Interpreting your results 05 Most commonly missed items 06 Before filing your report 07 FAQs

Train Your Team and Check Training Off Your List Today

If Section A revealed untrained staff — current employees, recent hires, or a gap in onboarding — our online AODA training platform lets you enrol your entire team today. Every staff member gets a dated completion certificate, and your training records are exportable for compliance report purposes.

IASR training including Ontario Human Rights Code content
Information & Communications module for digital and content teams
Training records exportable for compliance report and audit purposes
Training covers your organization's specific accessibility policies (add-on)

Aoda Training

AODA Compliance Checklist for Ontario Businesses (2026)

Quantity Discounts

Price per course

6 to 20 courses

$20.95

21 to 50 courses

$17.95

51 to 200 courses

$13.95

201+ courses

Custom offer

Download the Printable Version

Download the free AODA compliance checklist (PDF)

The AODA Compliance Checklist

How to Interpret Your Results

The Most Commonly Unchecked Items

Using This Checklist Before Filing Your AODA Compliance Report

Frequently asked questions

Train Your Team and Check Training Off Your List Today

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