AODA requirements: 20–49 vs 50+ employees
Ontario's accessibility rules scale with headcount. The two thresholds that matter most for businesses and non-profits are 20 and 50 employees.
The short version: at 20+ employees you must file the compliance report; at 50+ the documentation duties get stricter — written public policies, a multi-year plan, WCAG 2.0 AA websites, and formal training records.
| Requirement | 20–49 employees | 50+ employees |
|---|---|---|
| File accessibility compliance report (every 3 years) | Yes | Yes |
| Accessibility policies | Required; written documentation recommended | Required in writing and publicly available |
| Multi-year accessibility plan | Not legally required | Required |
| Website WCAG 2.0 Level AA | Not required at this size | Required (with limited exceptions) |
| Accessibility training records | Recommended | Required |
Counting employees
The threshold is based on your number of employees in Ontario. If you are near a boundary — growing, or using many part-time staff — confirm your count against Ontario's official guidance before deciding which tier you are in.
When in doubt, document anyway
Even where written documentation is only "recommended" (for example, training records at 20–49 employees), keeping it is cheap insurance. It makes the compliance report easier and puts you in a stronger position if you grow past 50.
Common questions
Do part-time employees count toward the 20-employee threshold?
Ontario's guidance focuses on your number of employees in the province. If your count is borderline, check the official rules or get advice rather than assuming.
We have 45 employees but are hiring. Which rules apply?
Plan for the tier you will be in when you file. If you will be at 50+, start meeting those documentation requirements now.
Get it filed before December 31, 2026
WebGray's filing kit gives you a website accessibility check, ready-to-customize policy and planning templates, a training record template, and a step-by-step filing walkthrough. Founding-member pricing is $99.
Important: This guide provides general information and practical planning help. It is not legal advice and does not replace official Government of Ontario guidance.