AODA training requirements: what’s mandatory, what’s free, and what to keep
Guide · Updated 2026-09-07 · 8 min readEvery organization in Ontario with at least one employee must train all employees and volunteers on Ontario's accessibility standards and on the Human Rights Code as it applies to people with disabilities. The training itself can be completely free — the province publishes ready-made modules. If you have 50 or more employees, you must also keep dated records of who was trained and when. In our experience, the missing records — not the missing training — are what stop businesses from answering "Yes" on the December 31, 2026 compliance report.
Who and what
Who must be trained, on what
The duty is broader than most owners expect. It covers every employee — full-time, part-time, contract — plus volunteers, anyone who helps develop your policies, and anyone providing goods, services, or facilities on your behalf (yes, including some third parties). Board members and managers included.
Required training content
- The purpose of the AODA and the requirements of the standards relevant to each person's duties
- Accessible customer service: interacting with people with various disabilities, assistive devices, service animals, and support persons
- The Ontario Human Rights Code as it relates to people with disabilities
- Retraining whenever your accessibility policies change
Timing: "as soon as practicable" after someone joins — in practice, put it in onboarding. Any format counts: online module, classroom session, orientation talk.
The free part
The government already built the training — use it
Before anyone sells you a training package: AccessForward offers free modules, funded by the Ontario government, covering every accessibility standard plus the Human Rights Code module developed with the OHRC. They're online, downloadable, and there's a printable condensed booklet for small teams. For most organizations these modules fully satisfy the content requirement.
The records rule
Records: mandatory at 50, wise at any size
Organizations with 50+ employees must keep written records of the training: when it was delivered, and who (or how many) attended. Under 50, records aren't legally required — but they're the only way to prove the training happened, and the compliance report's General question has two separate checkboxes for "Training staff" and "Training records." A signed one-page acknowledgement per employee is enough.
If training happened years ago and nobody wrote it down, you don't need to pretend otherwise: run the free modules again this quarter, capture sign-offs as people complete them, and your records begin now — honestly.
The exact requirement
What AODA training records must include
The regulation asks for two things. Under section 7 of O. Reg. 191/11, an organization with 50 or more employees must keep a record of the training provided, including the dates on which the training was provided and the number of individuals to whom it was provided. That is the legal minimum: dates, and a headcount.
In practice, nobody can prove a headcount without names, which is why every usable record is kept per person: the employee's name and the date they completed the training. That's also the answer the government's free training modules teach. Anything beyond that (which modules, who delivered them, a signature) is good practice, not law.
A record that survives the December certification
- Name of the person trained — employee, volunteer, or contractor acting for you
- Date completed — the field the regulation actually names
- What was covered — which standards, plus the Human Rights Code module
- Sign-off — a signature or a completion email from the module
- The running total — so the "number of individuals" is a number you can state
Format: a spreadsheet or a signed one-page sheet per employee is enough. Keep it where the person who signs the report can find it.
Common questions
Expiry, certificates, and how many modules
Does AODA training expire?
No. The regulation sets no expiry date and no renewal cycle. It does require retraining whenever your accessibility policies change, and training for every new hire "as soon as practicable." It also sets no retention period for the records, so keep them at least through the next reporting cycle in 2029.
Is there an official AODA certificate?
There is no government-issued certificate and none is required. Some training providers print a completion certificate, which is fine as evidence, but what the law asks for is your own record of who was trained and when. A certificate with no date on your file is weaker than a dated spreadsheet.
How many modules are in AODA training?
AccessForward publishes one module per accessibility standard (customer service, information and communications, employment, transportation, design of public spaces), plus a general-requirements module and the Human Rights Code module developed with the Ontario Human Rights Commission. Nobody needs all of them: each person is trained on the standards relevant to their duties, and everyone covers customer service and the Human Rights Code.
Is AODA training mandatory for every role?
Yes, for every employee and volunteer, plus anyone who develops your policies or provides goods, services or facilities on your behalf. Administrative staff, part-timers, board members and managers are all included. The content is scaled to the role, the obligation is not.
Where we fit
What AODAPrep adds to free training
Our training kit is deliberately thin, because the modules are already free: we assemble the right module set for your organization, provide the sign-off sheets and tracking log, set up the backfill acknowledgement process for existing staff, drop training into your onboarding checklist, and file the records into your evidence binder under the exact report question they answer. You get the "Yes" — and the proof behind it.
Want your training records report-ready in a week?
Book a free 15-minute readiness call. We’ll tell you whether your current training and records would survive the December certification — and what to do if not.
Keep reading
Sources — Official
- O. Reg. 191/11, Part I — General (s. 7: training and training records)
- Ontario.ca — How to train your staff on accessibility
- AccessForward — free government-funded training modules
- Ontario — Accessibility Training Requirements Checklist
Report question and checkbox wording captured from the Accessibility Compliance Reporting Portal, July 2026. This guide is general information, not legal advice.