The AODA customer service policy: what the standard requires, and what yours needs to say
Guide · Updated 2026-10-22 · 9 min readThe Customer Service Standards are the oldest part of Ontario's accessibility law and the only part the compliance report asks a 20–49 employee organization about. They are also the part most organizations assume they already meet. The rules sit in Part IV.2 of O. Reg. 191/11, sections 80.45 to 80.51, and they ask for five things: policies on serving people with disabilities, a welcome for service animals and support persons, notice when an accessible feature is out of service, a feedback process, and trained staff. Below 50 employees none of it has to be written down. At 50 and above most of it does, and you have to tell customers the documents exist.
Who it covers
Every organization with one employee. The paperwork starts at 50.
The regulation applies to every person or organization that provides goods, services or facilities to the public and has at least one employee in Ontario (s. 1(3)). Inside the customer service part, the word that matters is "small organization": one with fewer than 50 employees in Ontario. Every document-and-notice duty in Part IV.2 is written as "every provider, other than a small organization," so the practices apply to everyone and the written versions kick in at 50.
| Requirement | 1–49 employees | 50+ employees |
|---|---|---|
| Policies on serving people with disabilities (s. 80.46) | Develop, implement and maintain them | Same, plus a written document, given on request, and notice to customers that it exists |
| Service animals and support persons (s. 80.47) | Admit both; fee for a support person disclosed in advance | Same, plus a written policy document and notice |
| Notice of temporary disruption (s. 80.48) | Give public notice: reason, expected duration, alternatives | Same, plus a written document of the steps you take, and notice |
| Training (s. 80.49) | Train every employee, volunteer, policy-maker and agent, as soon as practicable | Same, plus dated training records and a written training policy |
| Feedback process (s. 80.50) | Have one, say what you do with complaints, make it public and accessible | Same, plus a written document and notice |
| Accessible formats of the documents (s. 80.51) | On request, timely, at no extra cost | Same |
Two small print points. "Notice" can be a sign on the premises, a line on your website, or any other reasonable method (ss. 80.46(6), 80.47(10), 80.48(5), 80.50(7)). And the training duty in s. 80.49 sits on top of the general training duty in s. 7, which covers the Human Rights Code; our training guide has both.
The five requirements
In plain English, with what "done" looks like
Policies (s. 80.46)
Decide, and be able to say, how you serve people with disabilities: in a way that respects dignity and independence, integrated with how you serve everyone else unless an alternative is genuinely necessary, with equal opportunity, and communicating in a way that takes the person's disability into account. The policies must cover assistive devices. Done: a page or two your staff have read, and at 50+ a document anyone can ask for.
Service animals and support persons (s. 80.47)
A person with a guide dog or other service animal comes in with the animal, unless the law excludes animals from that area (a food-preparation area, for example), in which case you offer another way to serve them. A person with a support person comes in with the support person and keeps access to them. You may require a support person only for health or safety, after consulting the person, when no other reasonable way exists, and then you waive the support person's admission fee. Any fee for a support person is disclosed in advance. Done: a short written practice, and the front-line staff know it.
Notice of temporary disruption (s. 80.48)
When an elevator, ramp, accessible washroom, accessible entrance or any other facility people with disabilities rely on is out of service, you tell the public: the reason, how long you expect it to last, and what alternative exists. Done: a fill-in-the-blanks notice, a decision about where it goes (the door, the website), and a named person who posts it.
Training (s. 80.49)
Everyone who deals with the public or shapes your policies, including volunteers and contractors acting for you, learns the purpose of the Act, your customer-service policies, how to interact with people with different disabilities, assistive devices, service animals and support persons, the equipment on your premises, and what to do when someone is having difficulty. As soon as practicable after they join, and again when the policies change. Done: the free AccessForward customer-service module plus a dated sign-off per person; the records are mandatory at 50+ and wise below it.
Feedback process (s. 80.50)
A way for people to tell you how you did serving someone with a disability, a stated procedure for what happens when a complaint arrives, information about the process made readily available to the public, and accessible formats or communication supports for the process itself on request. Done: an email address and phone line someone actually checks, a sentence on your website saying so, and a response commitment in days.
The report
How the compliance report asks about it
For a 20–49 employee organization, the entire compliance section of the December 31, 2026 report is this one question. Organizations with 50 or more employees get it as their sixth.
Compliance question — Customer Service Standards
“Is your organization in compliance with all applicable requirements of the Customer Service Standards?”
If you answer “No,” you must check which of these apply:
- Customer service policies for accessibility
- Service animals and support persons
- Feedback process and providing information in accessible formats upon request
- Notice of temporary disruption for facilities and services that support accessibility
"All applicable requirements" is the phrase to read twice. A truthful "Yes" means all five practices above are in place, and at 50+ that the documents and notices exist too. Training is not a checkbox here because it has its own checkboxes under the General question on the 50+ form; at 20–49 it is simply part of what "all applicable requirements" means. The pillar guide has every question on the form.
The policy
A plain outline of what the document says
The province publishes a free Accessibility Policy Sample, which is the government's own picture of "enough." It covers every standard in one document; the customer-service part of it maps to these headings. A policy that says something concrete under each one is a policy a certifier can stand behind.
| Heading | What it says |
|---|---|
| Statement of commitment | Dignity, independence, integration, equal opportunity; a sentence that the Human Rights Code applies regardless |
| Communication | You communicate in ways that take a person's disability into account; staff will ask how a person prefers to communicate |
| Assistive devices | People may use their own devices; which of your own devices or measures are available and where |
| Service animals | Welcome in all public areas; the law-excludes-animals exception and the alternative you offer; when documentation from a regulated health professional may be asked for |
| Support persons | Welcome; any admission fee for them stated up front; the health-and-safety-only rule for requiring one, and the fee waiver when you do |
| Notice of temporary disruption | What triggers a notice, what it contains (reason, duration, alternatives), where it is posted and who posts it |
| Training | Who is trained, on what, when (as soon as practicable, and on policy changes), and that records are kept |
| Feedback process | How to give feedback (email, phone, in person, in writing), who responds, within how many days, and how complaints are handled |
| Documents and accessible formats | That this policy is available on request, in an accessible format or with communication support, at no extra cost |
| Changes to this policy | Anything inconsistent with the principles above will be changed or removed; date and owner of the document |
Three to five pages is normal. Longer is not better; a policy nobody at the front desk has read is the common failure, not a policy that is too short.
Common gaps
Where "we treat everyone the same" falls apart
What we actually find
- No feedback process. There is a contact form, but nothing says it is for accessibility feedback, nobody owns the response, and there is no stated procedure for complaints
- No disruption notice. The elevator has been out before; the notice was a handwritten sign with no alternative and no expected duration
- Support-person fees not disclosed. Venues and programs that charge admission rarely say what a support person pays
- Training happened once, years ago, for the people who were there then, and never for anyone hired since
- The policy exists but customers cannot find out it exists. At 50+, the notice-of-availability duty is its own requirement, and a PDF in a shared drive does not meet it
Each of these is a page of writing and a decision about who owns it. Together they are the difference between a "Yes" the certifier can sign and a "No" with four boxes checked.
Questions
Written, posted, template, animals, fees
Do we need a written customer service policy with 20 to 49 employees?
Not by law. The document-and-notice duties in Part IV.2 apply to every provider "other than a small organization," and a small organization is one with fewer than 50 employees in Ontario. But the report asks whether you comply with all applicable requirements, and a written policy is the simplest way to show that the practices exist and that staff were trained on them. Most 20–49 organizations write one anyway, and it is a few pages.
Is there a free AODA customer service policy template?
Yes. The Ontario government's Accessibility Policy Sample is free and covers customer service alongside the other standards. It is a fillable form with blanks for your organization's name; the work is deciding what goes in each section, not finding the structure.
Does the policy have to be on our website?
At 50 or more employees you must give customers notice that the documents are available on request, and the regulation says that notice may be posted on your premises, on your website if you have one, or by another reasonable method. Posting the policy itself on the site is the easiest way to meet both the notice duty and the on-request duty at once. Under 50 there is no posting duty at all.
Can we refuse a service animal?
Only where the animal is excluded by another law from that part of your premises, such as areas where food is prepared under public health rules. Then you must offer another way for the person to get your goods or services. Where the animal is not readily identifiable as a service animal, the regulation lets you ask for documentation from one of the listed regulated health professionals; it does not let you ask for the person's diagnosis.
Can we charge a support person admission?
You can, if you say so in advance. If an admission or similar amount applies, notice of what a support person pays must be given beforehand. If you are the one requiring the support person for health or safety reasons, you waive their fee.
What does a notice of temporary disruption have to say?
Three things: the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any. Post it where people will see it, which usually means the affected entrance or feature and your website.
Where we fit
The 20–49 package is exactly these four pieces
For a 20–49 employee organization, our File-Ready Package is this guide made real for your business: the customer service policy, the feedback process text for your website, the disruption-notice template with a named owner, and the service-animal and support-person wording, each written from your actual situation, plus the training sign-off kit and your drafted report answer. You read it, approve it, and your certifier signs a "Yes" with the documents behind it. We prepare; you certify.
Need the four customer-service pieces written and ready to post?
The File-Ready Package drafts your customer service policy, feedback process and disruption notice from your real situation, with the training sign-off kit and your drafted report answer. We prepare, you certify.
Delivered by email. Full refund if it turns out you do not have to file.
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Keep reading
Sources — Official
- O. Reg. 191/11, Part IV.2 — Customer Service Standards (ss. 80.45–80.51)
- Ontario.ca — How to make customer service accessible
- Ontario — Accessibility Policy Sample (ON00090)
- Ontario.ca — Completing your accessibility compliance report
Report question and checkbox wording captured from the Accessibility Compliance Reporting Portal, July 2026. This guide is general information, not legal advice.