An organization with 50 or more employees in Ontario is a “large organization” under the accessibility standards (O. Reg. 191/11 s. 2) and must have a documented multi-year accessibility plan. Under 50, the plan is not required.
What the regulation requires
Section 4(1) of O. Reg. 191/11 says large organizations shall:
- establish, implement, maintain and document a multi-year accessibility plan that outlines the organization’s strategy to prevent and remove barriers and meet its requirements under the regulation;
- post the plan on their website, if they have one, and provide it in an accessible format on request; and
- review and update the plan at least once every five years.
If the design of public spaces standards (Part IV.1) apply to you, the plan must also include procedures for preventive and emergency maintenance of the accessible elements in those public spaces, and for dealing with temporary disruptions when they are not working (s. 80.44).
What it does not require
The annual status report on the plan and consultation with people with disabilities in s. 4(2) and (3) apply to the Government of Ontario, the Legislative Assembly and designated public sector organizations, not to private businesses or non-profits. The regulation does not prescribe a format or a list of headings for the plan.
A practical structure
Because the plan is a strategy for meeting the regulation, a table that walks through the requirements that apply to you works well:
- a short statement of the plan’s purpose and the date of the next review;
- the requirement, with its section number (policies, training, feedback, accessible formats, emergency information, website, employment, customer service);
- what you have done or will do, who is responsible and by when; and
- how to get the plan in an accessible format.
List only actions you will actually take. The plan is public, and a director can ask for information about how you are meeting the rules (AODA s. 17).
Free sample
Here is a sample plan built for a fictional organization with 85 employees. It is illustrative: the Responsible and Status columns are left for you to fill in, and your own plan should reflect what you actually do.
Sample plan (PDF) Read it as a web page
Other 50+ requirements that go with it
At 50 or more you also need written accessibility policies with a statement of commitment, made public (s. 3(2), (3)); training records (s. 7(5)); a website that meets WCAG 2.0 Level AA (s. 14); and written processes for individual accommodation plans and return to work (ss. 28, 29). See the accessibility policy guide.
Sources
- O. Reg. 191/11, Integrated Accessibility Standards (s. 2 definitions; s. 4 accessibility plans; s. 80.44; ss. 3, 7, 14, 28, 29)
- Accessibility for Ontarians with Disabilities Act, 2005 (s. 17)
Common questions
Who needs a multi-year accessibility plan in Ontario?
Large organizations, meaning 50 or more employees in Ontario, along with the Government of Ontario, the Legislative Assembly and designated public sector organizations (O. Reg. 191/11 ss. 2, 4(1)).
How often must the plan be updated?
Reviewed and updated at least once every five years (O. Reg. 191/11 s. 4(1)(c)).
Does a private business need an annual status report on its plan?
No. The annual status report in s. 4(3) applies to the Government of Ontario, the Legislative Assembly and designated public sector organizations.
Does the plan have to be on our website?
If you have a website, yes. The plan is posted there and provided in an accessible format on request (s. 4(1)(b)).
Related guides
- AODA accessibility policy template for Ontario: what a compliant policy contains
- AODA compliance report checklist 2026: what to have in place before you certify
- How to count employees in Ontario for the AODA and ESA thresholds (20, 25 and 50)
- AODA compliance report 2026: what Ontario businesses file by December 31