The AODA compliance checklist for 2026, by business size

Checklist — 1–19 employees

• Train every employee and volunteer on accessible customer service, the accessibility standards relevant to their duties, and the Human Rights Code as it applies to people with disabilities (free government modules exist — see our training guide)
• Have accessibility policies for how you serve people with disabilities (they don't need to be written down at this size — but writing them down is how you prove them)
• Welcome service animals and support persons
• Give customers a way to submit accessibility feedback
• Notify applicants and staff that accommodations are available in recruitment and employment

No compliance report required. If that's you, you're done reading — though the practices above are still the law, and if you grow past 19 employees the filing duty begins.

Checklist — 20–49 employees

• Customer service accessibility policies — how your business serves people with disabilities
• A practice of welcoming service animals and support persons, with the narrow legal exceptions handled properly
• A working feedback process customers can actually find, and information available in accessible formats on request
• A way to notify customers when an accessible feature (elevator, ramp, accessible washroom) is temporarily out of service
• Staff training done — and while training records aren't mandatory at this size, keep them anyway; they're your proof
• File the report before December 31, 2026, certified by someone with authority to bind the organization

The trap: "we're nice to everyone" is not a policy, a feedback process, or a disruption notice. Most 20–49 businesses we check are missing at least two of the four areas — usually the feedback process and the disruption notice, because nobody ever wrote them down.

Checklist — 50+ employees (everything above, plus)

• Written accessibility policies and a public statement of commitment
• A multi-year accessibility plan, posted on your website and reviewed at least every five years
• Dated training records — who was trained, and when
• Your public website and content meeting WCAG 2.0 Level AA — required since January 1, 2021
• A documented, publicly available customer service policy (the informal version stops being enough at 50)
• Accommodation language in job postings, offer letters, and onboarding
• A written process for individual accommodation plans, and a written return-to-work process
• Individualized workplace emergency response information for employees who need it
• Accessible-formats and communication supports available on request, at no extra cost
• If you've built or significantly redeveloped public-facing spaces since 2017 — parking, service counters, waiting areas — the Design of Public Spaces requirements for those elements
• File the report before December 31, 2026, certified by a senior officer

Reality check: in our scans of established Ontario businesses in this bracket, most fail dozens to hundreds of automated website checks and have no posted policies at all. The gaps are normal — and fixable in weeks. What isn't fixable after the fact is a false certification.