AODA Training Requirements: Who Must Be Trained, on What, and When

The AODA training requirements apply to almost every organization in Ontario. If you provide goods, services or facilities and have at least one employee in Ontario, you must train your employees, volunteers, the people who develop your policies, and anyone who provides goods, services or facilities on your behalf. The training has three parts: the accessibility standards in the Integrated Accessibility Standards Regulation (IASR) that relate to each person's duties, the Ontario Human Rights Code as it applies to people with disabilities, and accessible customer service.

People must be trained "as soon as practicable", which in practice means during onboarding, and again whenever your accessibility policies change. The Government of Ontario, the Legislative Assembly, every designated public sector organization and every business or non-profit with 50 or more employees in Ontario must also keep a record of the training: the dates it was given and how many people received it.

That is the legal minimum. This guide walks through each requirement against the text of the regulation, then covers the part most guides skip: the role-specific training your web, content and document teams need if your website is actually going to meet WCAG.

AODA training requirements at a glance

The training rules sit in two places in O. Reg. 191/11, the Integrated Accessibility Standards Regulation: section 7 (general training) and section 80.49 (customer service training). A third rule, section 16, applies only to schools and other educational institutions.

For the wider picture of what the AODA asks of your organization, including the website standard and penalties, see our overview of AODA requirements, deadlines and penalties.

Who must receive AODA training for employees and others

Both section 7 and section 80.49 list the same three groups. Ontario's own guidance, How to train your staff on accessibility, fills in who that means in practice.

• Every employee and volunteer. Paid or unpaid, full-time, part-time or on contract. There is no carve-out for seasonal staff or short placements.
• Everyone who takes part in developing your policies. Ontario's guidance names managers, senior leaders, directors, board members and owners. An owner who never serves a customer still needs training if they shape how the business runs.
• Everyone else who provides goods, services or facilities on your behalf. The province gives external contact centres and facilities management companies as examples. A staffing agency, a third-party booking line or an outsourced help desk falls in the same bucket.

Ontario's guidance also notes that employees working outside Ontario don't need to be trained.

Contractors and third parties

The third group is where most gaps appear. The regulation puts the duty on your organization, not on the contractor, so you need a way to confirm that people serving your customers have been trained. The usual approach is a clause in the service agreement requiring the supplier to train its staff to the AODA standard and to confirm it in writing, plus a copy of that confirmation in your own records.

What the training must cover

1. IASR training, appropriate to each person's duties

Section 7 requires training "on the requirements of the accessibility standards referred to in this Regulation". The IASR has five standards: information and communications, employment, transportation, design of public spaces, and customer service. Section 7(2) says the training must be "appropriate to the duties" of the person. That wording matters. It means you don't have to teach every employee every standard, but you do have to teach each person the parts that touch their job.

A warehouse associate needs a general overview. A hiring manager needs the employment standard: accommodation in recruitment, individual accommodation plans and return-to-work processes. Someone who publishes to your website needs the information and communications standard, including the rule that large organizations' public websites conform to WCAG 2.0 Level AA.

2. Human Rights Code training in Ontario

The same section requires training on the Human Rights Code "as it pertains to persons with disabilities". The AODA sets minimum standards; the Code sets broader rights, including the duty to accommodate people with disabilities. Staff should understand that meeting an AODA standard does not end the conversation if a person needs something the standard doesn't spell out. The Ontario Human Rights Commission publishes a free module, Working together: The Code and the AODA, designed for this requirement.

3. AODA customer service training

Section 80.49 adds customer service training "in addition to the requirements in section 7". It must include a review of the purposes of the AODA and the requirements of the customer service standard, plus instruction on four specific topics:

1. How to interact and communicate with people with various types of disability.
2. How to interact with people who use an assistive device, or who need a guide dog or other service animal or a support person.
3. How to use equipment or devices on your premises, or otherwise provided by you, that may help when serving a person with a disability.
4. What to do if a person with a particular type of disability is having difficulty accessing your goods, services or facilities.

The fourth item covers digital service too. If a customer phones because they can't complete your online booking form with a screen reader, the person who answers should know how to help them finish the task another way and how to log the problem so it gets fixed.

Extra rule for educators

School boards and educational or training institutions must also give educators accessibility awareness training related to accessible program or course delivery and instruction, and must keep a record of it (IASR s. 16). "Educators" means employees involved in program or course design, delivery and instruction.

When training must happen

The regulation says every person "shall be trained as soon as practicable". It doesn't give a number of days. Ontario's guidance phrases it as "as soon as possible after an employee or volunteer joins your organization". Building the modules into onboarding, before or shortly after someone first deals with customers or publishes content, is the simplest way to meet it.

There is no fixed expiry date or mandatory annual refresher in the regulation. What it does require is training "on an ongoing basis" whenever your accessibility policies change. If you update your accessibility policy, your customer service policy, or your feedback process, the people affected need to hear about the change. A periodic refresher is still good practice, especially for customer-facing staff, but it isn't a legal requirement.

Your training policy and your accessibility policy should line up. If you are writing or updating those documents, our guide to the AODA accessibility policy and multi-year plan covers what goes in each one.

AODA training records: what to keep by organization size

The IASR defines a small organization as one with at least one but fewer than 50 employees in Ontario, and a large organization as one with 50 or more. Public sector bodies are counted separately and must keep records regardless of size.

The record must include the dates training was provided and the number of individuals who received it. Organizations with 50 or more employees must also prepare a document that describes the training policy, summarizes its content and says when training is provided, give a copy to anyone who asks, and let customers know it's available.

Small organizations are exempt from the records rule but not from the training itself. Keeping a simple log anyway costs little and is the easiest way to show what you did if anyone asks. Our guide to AODA requirements for small businesses covers the rest of what applies under 50 employees.

The regulation only asks for dates and numbers. Names, module version and delivery method are optional, but they let you answer the questions that come up later: was this person trained, and did they get the version that reflects our current policy?

Beyond the legal minimum: role-specific training for web and content teams

The mandatory training is awareness training. It tells a web developer that the organization must meet WCAG 2.0 Level AA; it does not teach them how. If you have 50 or more employees, the website rule in IASR section 14 is a separate legal requirement, and the people building and publishing your site need practical skills to meet it. Without that, the same barriers come back after every audit and every redesign.

Role-specific training usually breaks down like this:

• Developers: semantic HTML, keyboard operability and focus management, accessible names for controls, form labels and error messages, and when ARIA helps or harms.
• Designers: colour contrast, visible focus indicators, not relying on colour alone, readable layouts at 200% zoom, and designing error and empty states.
• Content editors and marketers: heading structure, meaningful link text, alt text that matches the image's purpose, captions and transcripts for video.
• Document authors: building accessible Word files and tagged PDFs from the start, rather than fixing them after publication. Our guide to accessible Word documents is a good starting point.
• QA and testers: a repeatable manual test routine, including keyboard-only checks and screen reader testing, alongside automated tools.
• Procurement and product owners: how to ask vendors for accessibility evidence, read an Accessibility Conformance Report and write accessibility into contracts.

The test of good training is simple: after it, can the person spot and fix a barrier in their own work, on their own product? Hands-on exercises against your real templates and documents do that far better than slides.

AODA training checklist

• List everyone who must be trained: employees, volunteers, policy developers (including owners and board members) and third parties serving customers on your behalf.
• Cover all three parts: IASR standards relevant to each role, the Human Rights Code as it relates to disability, and the four customer service topics.
• Add the modules to onboarding so new people are trained as soon as practicable.
• Retrain affected staff whenever your accessibility, customer service or feedback policies change.
• Add a training clause to contracts with suppliers who deal with your customers.
• If you have 50 or more employees (or are in the public sector): record dates and numbers trained, write a training policy document, and tell the public it's available on request.
• If you're a school board or educational institution: give educators accessibility awareness training on course delivery, and record it.
• Give your web, design, content and document teams practical, role-specific training so your site keeps meeting WCAG 2.0 Level AA.

Frequently asked questions