AODA Customer Service Standard for small businesses: what every Ontario organization with 1 to 49 employees must do
Updated 2026-10-30. Rules current to October 23, 2026. A plain-language summary, not legal advice. EmployerReady is not affiliated with the Government of Ontario.
The Customer Service Standard in Part IV.2 of O. Reg. 191/11 applies to every organization in Ontario with at least one employee that provides goods, services or facilities to the public or to other businesses. There is no 20-employee floor for the obligations themselves; the 20-employee floor only decides whether you report. If you are a small organization (1 to 49 employees), most of these duties can be met without written documents, but you still have to meet them.
Six duties, one standard
| Duty | Section | What a small organization must do | Extra for 50+ |
|---|---|---|---|
| Policies | 80.46 | Have policies on serving persons with disabilities that follow four principles: dignity, independence, integration and equal opportunity. The policies must deal with the use of assistive devices. | Policies in writing; public notice that documents are available on request. |
| Service animals and support persons | 80.47 | Where the public has access to your premises, let people bring their service animal and, if the animal is excluded by another law, find another way to serve them. Let people bring a support person. Give advance notice of any fee for the support person. | Written policy and notice. |
| Disruption notices | 80.48 | If a facility or service that people with disabilities rely on is temporarily unavailable, post a notice with the reason, the expected duration and any alternatives. | Written procedure. |
| Training | 80.49 | Train every employee and volunteer, everyone who helps develop your customer service policies, and anyone else who provides goods, services or facilities on your behalf. See the topics below. | Training policy document and records of dates and numbers trained. |
| Feedback | 80.50 | Have a way to receive and respond to feedback about how you serve people with disabilities. It must say what you will do about complaints, accept feedback in accessible formats on request, and be readily available to the public. | Written feedback process document. |
| Format of documents | 80.51 | If you are required to give someone a copy of a document under this standard, give it in an accessible format or with communication supports, in a timely way, at no more than the regular cost, after consulting the person about a suitable format. | Same. |
Service animals and support persons in more detail
An animal is a service animal if it is readily apparent that it is used for reasons relating to a disability (a harness or vest, for example), or if the person provides documentation from a regulated health professional listed in s. 80.45(4) confirming they need the animal for that reason. When the need is readily apparent, the animal qualifies without documentation.
You may require a person with a disability to be accompanied by a support person only after consulting with them and only if a support person is necessary to protect the health or safety of that person or others on the premises and there is no other reasonable way to do so. If you require one, you must waive any fee for the support person.
Training topics
Section 80.49(2) lists what the training must cover:
- the purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standard;
- how to interact and communicate with people with various types of disabilities;
- how to interact with people who use an assistive device or need a service animal or support person;
- how to use any equipment or devices you provide to help people with disabilities access your goods, services or facilities;
- what to do if a person with a particular type of disability is having difficulty accessing your goods, services or facilities.
Train as soon as practicable, and again whenever your customer service policies change. Section 7 of the regulation separately requires training on the other accessibility standards and the Human Rights Code; see AODA training requirements. The regulation does not require a particular course or provider.
Where this fits with the compliance report
If you have 20 to 49 employees in Ontario, the accessibility compliance report due December 31, 2026 asks about the Customer Service Standard only, in one question. The report does not change the obligations; it asks whether you meet them. Under 20, you do not report but the duties above still apply. See the AODA compliance report guide and the report checklist.
Sources
- O. Reg. 191/11, Integrated Accessibility Standards (Part IV.2, ss. 80.45 to 80.51; s. 86.1 reporting)
- Accessibility for Ontarians with Disabilities Act, 2005
Common questions
Does the AODA Customer Service Standard apply to a business with fewer than 20 employees?
Yes. Part IV.2 of O. Reg. 191/11 applies to every organization with at least one employee in Ontario that provides goods, services or facilities to the public or other businesses. The 20-employee threshold only decides whether you file a compliance report.
Does a small business need written accessibility policies?
A small organization (1 to 49 employees) must have customer service policies and meet the other duties, but the regulation requires the policies to be in writing only for organizations with 50 or more employees (s. 80.46(4)). Writing them down anyway makes training and reporting easier.
Can I ask a customer for proof that their animal is a service animal?
Only if it is not readily apparent that the animal is used for reasons relating to a disability. In that case you may ask for documentation from one of the regulated health professionals listed in s. 80.45(4).
Can I charge a fee for a support person?
If you charge an admission fee, you must give advance notice of the amount, if any, payable for the support person. If you are the one requiring the support person for health or safety reasons, you must waive that fee (s. 80.47).
Who has to take customer service accessibility training?
Every employee and volunteer, every person who participates in developing your customer service policies, and every other person who provides goods, services or facilities on your behalf, as soon as practicable and again when the policies change (s. 80.49).