AODA Requirements for Small Business: What Applies at 1–19, 20–49 and 50+ Employees

Yes, the AODA applies to small businesses. The AODA requirements for small business cover every organization with at least one employee in Ontario that provides goods, services or facilities to the public or to other businesses. There is no minimum size below which the law stops applying.

What changes with size is how much you have to write down and report. A business with fewer than 50 employees in Ontario is a "small organization" under the Integrated Accessibility Standards Regulation (IASR). It must provide accessible customer service, train its people, provide accessible formats on request and follow accessible employment practices. It does not need written policies, a multi-year accessibility plan, training records or a website that meets WCAG. Those start at 50 employees.

Within the small band, there is one more line at 20 employees: from 20, you have to file a compliance report every three years, covering customer service. This guide sets out each requirement by size band, with the regulation section behind it, so you can see exactly where your business sits.

Does AODA apply to small business?

Section 1 of the Integrated Accessibility Standards Regulation applies it to every person or organization that provides goods, services or facilities to the public or other third parties and has at least one employee in Ontario. A two-person bookkeeping firm, a café, a dental clinic and a software start-up selling to other businesses are all covered.

The regulation uses two sizes: a small organization has 1 to 49 employees in Ontario, and a large organization has 50 or more. The 20-employee line comes from the reporting rules, not from the standards themselves. For a business with 1–19 employees and one with 20–49, the obligations are the same; only the second files a report.

AODA under 20 employees: how to count

Ontario's guidance says to use your peak employee count at any one time in the previous 12 months. Count full-time, part-time, seasonal and contract workers in Ontario. Don't count staff outside Ontario or outside contractors. A landscaping company with 12 year-round staff and 15 summer workers has 27 employees for AODA purposes, not 12.

AODA requirements for small business, by size band

The table covers the requirements most businesses deal with. Transportation providers, educational institutions and libraries have extra rules that aren't shown here. Ontario's own summary, accessibility rules for businesses and non-profits, lists the same requirements by size.

Customer service: the core of AODA for small business

The customer service standards (Part IV.2 of the IASR) apply to every provider of goods, services or facilities, whatever its size. In practice, this is most of what a small business has to do.

• Policies. Have policies on how you serve people with disabilities, using reasonable efforts to respect dignity, independence, integration and equal opportunity, and communicating in a way that takes a person's disability into account. They must deal with the use of assistive devices.
• Service animals. Let customers bring a guide dog or other service animal onto premises open to the public, unless another law excludes the animal. If it is excluded, offer another way to serve the person.
• Support persons. Let a support person come in with the customer. You may require a support person only after consulting the customer and deciding it's needed to protect health or safety, with no other reasonable way to do so. If you charge admission, give advance notice of any fee for a support person, and waive it if you required one.
• Temporary disruptions. When something people with disabilities rely on is unavailable, such as an elevator or accessible washroom, post a notice giving the reason, how long it's expected to last and any alternatives.
• Feedback. Have a way for customers to give feedback on how you serve people with disabilities, say what you'll do about complaints, make the process easy to find, and offer accessible formats on request.
• Training. Train staff, volunteers, anyone who helps write your policies and anyone serving customers on your behalf. Training covers how to interact with people with different disabilities, with assistive devices, service animals and support persons, how to use any accessibility equipment you have, and what to do when someone is having trouble accessing your services.

Small organizations don't have to document any of this, but a one-page policy and a short training log are the easiest way to show the ministry you've done it. Our article on AODA training requirements covers what good training looks like.

General requirements: policies, training and kiosks

Every organization, small or large, must develop, implement and maintain policies on how it meets the IASR (section 3). Every organization must train employees, volunteers and anyone providing services on its behalf on the IASR and on the Ontario Human Rights Code as it applies to people with disabilities (section 7). Training must suit each person's duties, happen as soon as practicable after they start, and be repeated when your policies change.

If you design, buy or acquire self-service kiosks, including point-of-sale terminals customers use themselves, you must have regard to accessibility when you choose them (section 6).

Information and communications: what small businesses owe

This is where small businesses most often misread the law, in both directions.

What applies to everyone

• Accessible formats on request. If someone asks for information in a format they can use, such as large print, an accessible electronic file or plain language, you must provide it in a timely way, at no more than your usual cost, after talking to them about what works (section 12).
• Telling the public. You must let people know that accessible formats and communication supports are available. A line on your website, menu, invoices or a sign at reception does the job.
• Emergency information. If you publish emergency procedures or public safety information, provide it in an accessible format on request, as soon as practicable (section 13).
• Information you can't convert. If converting something isn't technically feasible, explain why and give the person a summary (section 9).

Websites: required at 50, sensible earlier

The website rule in section 14, WCAG 2.0 Level AA apart from live captions and pre-recorded audio description, applies to large organizations and the public sector. A business with fewer than 50 employees is not legally required to make its website conform.

That's not the end of the story, for three reasons.

• The duty to provide accessible formats on request still applies to information on your website. If a screen reader user can't get your prices or booking form, you have to provide that information another way.
• The Ontario Human Rights Code's duty to accommodate applies to businesses of every size.
• Public sector organizations must build accessibility criteria into what they buy (section 5), so small suppliers increasingly meet accessibility requirements in RFPs. See accessibility requirements in RFPs.

If you expect to reach 50 employees, building to WCAG now is cheaper than retrofitting later. Our AODA website compliance checklist is a practical place to start.

Employment: AODA under 50 employees

The employment standards apply to paid employees, not volunteers, and most of them apply regardless of size. A small employer must:

• Tell employees and the public that accommodation is available for applicants with disabilities during recruitment.
• Tell applicants selected for an interview or assessment that accommodation is available on request.
• Tell successful applicants about its policies for accommodating employees.
• Tell employees about its policies supporting employees with disabilities.
• Provide accessible formats and communication supports for job information and general workplace information when an employee with a disability asks.
• Provide individualized workplace emergency response information to employees whose disability makes it necessary, and review it when they move, when their accommodation is reviewed, or when the general emergency policies are reviewed.
• Take accessibility needs into account in performance management, career development and redeployment, where it uses them.

Two things are only for employers with 50 or more employees: a written process for documented individual accommodation plans, and a documented return-to-work process.

What changes at 20 employees

At 20 employees, you start filing an accessibility compliance report every three years. Section 86.1 of the IASR limits the report for businesses with 20 to 49 employees to the customer service standards, and the 2026 online report asks them a single compliance question. Our step-by-step guide on how to file an AODA compliance report walks through the portal.

What changes at 50 employees

At 50, you become a large organization and the paperwork grows: written policies with a statement of commitment, a multi-year accessibility plan posted on your website, training records, written customer service documents available on request, a WCAG 2.0 AA website, and the two documented employment processes. Our guide to the AODA accessibility policy and multi-year plan covers the documents. Penalties are covered on our AODA requirements and penalties page.

Example: a 30-person dental clinic

Size: 30 employees in Ontario, so a small organization that has to report.
Must do: customer service policies covering assistive devices, service animals and support persons; staff training; a notice process for disruptions such as an out-of-service ramp; an accessible feedback route; accessible formats of forms and appointment information on request, and a notice saying so; accessible hiring and employee emergency information; a compliance report every three years.
Doesn't have to do: written policies, a multi-year plan, training records or a WCAG-conformant website. If a patient can't use the online booking form, though, the clinic still has to offer another way to get the information and book.

A small business AODA checklist

• Count your peak number of Ontario employees over the last 12 months.
• Write a short accessible customer service policy, even though it's optional.
• Train every employee and volunteer, and keep a simple log of who and when.
• Add a line to your website and premises saying accessible formats and communication supports are available on request, with a contact.
• Set up a feedback route customers can use by phone, email or in person.
• Prepare a template notice for temporary disruptions.
• Add accommodation wording to job postings and offer letters.
• If you have 20 or more employees, put the next compliance report in your calendar.
• Run a free accessibility scan of your website to see how far it is from WCAG, especially if you're growing towards 50 employees.

Frequently asked questions