Who must file an AODA compliance report — and who signs it

The thresholds

One number decides your obligations

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:

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.)

Keep reading

• The AODA compliance checklist for 2026, by business sizeEvery requirement that applies to your organization — 1–19, 20–49, or 50+ employees — as a checklist mapped to the report.
• AODA penalties and fines: the honest pictureThe $100K-per-day number in context: how enforcement actually works, and why the certification signature is the real exposure.
• AODA website compliance: what Ontario law actually requiresThe WCAG 2.0 AA rule for 50+ organizations, what real scans find, free ways to check your own site, and how to fix it in time.
• The 2026 AODA compliance report: every question, verbatimThe complete guide this article builds on — the exact wording of the government form.

All guides →