Do churches, charities and other non-profits have to file an AODA compliance report?

Yes, if they have 20 or more employees in Ontario. The AODA has no religious or charitable exemption. Volunteers do not count toward the 20, but they must still be trained.

Do part-time, seasonal and contract staff count toward the 20 employees?

Yes. Anyone on your Ontario payroll counts regardless of hours: full-time, part-time, seasonal and employees on contract. Volunteers, true independent contractors and staff outside Ontario do not count.

What if we do not have an accessibility policy?

At 20 to 49 employees a written policy is not required and the form does not ask about one. At 50 or more employees a written policy is required and it is the first checkbox under the General question, so write one before you file.

Is there a tool or software for filing the AODA compliance report?

Only the Ontario government's own Accessibility Compliance Reporting Portal, which is free. There is nothing to buy in order to file.

How often must the AODA compliance report be filed?

Every three years for businesses and non-profits. The current cycle closes December 31, 2026 and the next is due in 2029.

Guide · Who Must File

Who must file an AODA compliance report? Every Ontario organization with 20 or more employees

Guide · Updated 2026-09-07 · 7 min read

Every business and non-profit with 20 or more employees in Ontario must file an accessibility compliance report with the provincial government by December 31, 2026. Organizations with 1–19 employees don't file (the accessibility rules still apply to them), and designated public-sector organizations were on an earlier cycle that closed December 31, 2025. Filing is free and done online — but it must be certified by someone with authority to legally bind your organization.

The thresholds

One number decides your obligations

Employees in Ontario	Must file by Dec 31, 2026?	Compliance questions on the form
1–19	No	— (rules still apply)
20–49	Yes	1 — Customer Service Standards
50+	Yes	6 — General, Information & Communications, Employment, Transportation, Design of Public Spaces, Customer Service

The report repeats every three years — this cycle's deadline is December 31, 2026, and the next lands in 2029. For the exact wording of every question on the form, see our complete guide to the 2026 report.

Counting correctly

How to count your employees

Count the people on your payroll in Ontario: full-time, part-time, seasonal, and employees on contract all count. Don't count volunteers, true independent contractors, or staff located outside Ontario. A federation of locations under one employer counts everyone together.

The count matters twice: at 20 it triggers the filing duty, and at 50 it changes your form from one question to six — plus written-documentation duties that don't exist below 50. If you hover near either line, work out the number carefully before you do anything else.

The signature

Someone has to certify it — personally

The report can be prepared by anyone, but it must be certified by a senior officer — an owner, CEO, or someone else with authority to bind the organization. The certification statement on the portal reads:

Verbatim — from the portal“I certify that all the information is accurate, and I have the authority to bind the organization.”

That is a named person attesting, on the record with the Ministry for Seniors and Accessibility, that every answer is true. The questions ask whether you comply with rules that have been in force for years — so before anyone signs, the honest move is to check whether the answers are true. Our checklist by business size is the fastest way to find out.

Missed past cycles?

If you've never filed before, you're not alone

Reporting cycles have existed since 2012, and government-commissioned reviews found that most obligated businesses never filed. If that's you, the practical path is simple: get compliant, then file this cycle properly. The form asks about your compliance today, and filing late is treated far more gently than not filing at all — non-filers are the easiest violation for the ministry to detect, because it holds the list of who filed. (More on that in our penalties guide.)

Edge cases

The questions people actually ask about the 20-employee rule

Do churches, charities and other non-profits have to file?

Yes, if they have 20 or more employees in Ontario. The AODA has no religious or charitable exemption: the government's own category is "businesses and non-profits," and a church, mosque, temple, charity or association with 20 paid staff files the same report as a company with 20. Volunteers don't count toward the 20, but they still have to be trained.

We have exactly 20 employees. Do we file?

Yes. The bracket is 20 to 49 inclusive, so 20 is in. At 19 or fewer, no report is required this cycle. If you hover around the line, count carefully on the date you file, and keep the payroll list you counted from.

Do part-time, seasonal and contract staff count?

Yes. Anyone on your Ontario payroll counts, regardless of hours: full-time, part-time, seasonal, and employees on contract. Don't count volunteers, true independent contractors, or staff who work outside Ontario.

We have several locations, or several companies

Count every Ontario employee of the same legal employer together, across all locations. Separate legal entities each have their own count and their own report, though the portal lets up to 20 related organizations share one form when every answer is identical.

What if we don't have an accessibility policy?

At 20 to 49 employees, a written policy isn't required and your form doesn't ask about one; the single question is about accessible customer service. At 50 or more, a written policy is required and it's the first checkbox under the General question, so write one before you file. The province publishes a free sample; our checklist by size lists everything else the 50+ form expects.

Is there a tool or software for the report?

Only the government's own portal, and it's free. There is nothing to buy to file. What costs time or money is making the answers true. See where and how to file.

How often does this repeat?

Every three years for businesses and non-profits. This cycle closes December 31, 2026; the next lands in 2029. The obligations behind the questions don't pause in between.

Not sure which bracket you’re in — or what your form will ask?

Book a free 15-minute readiness call. We’ll confirm whether you must file, which questions apply, and where you stand on each — free, no obligation.

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Sources — Official

Report question and checkbox wording captured from the Accessibility Compliance Reporting Portal, July 2026. This guide is general information, not legal advice.