Every organization covered by the accessibility standards needs accessibility policies, at every size (O. Reg. 191/11 s. 3(1)). What changes at 50 employees is that the policies must be written down and made public.
Who needs policies
The standards apply to organizations that provide goods, services or facilities to the public or other third parties and have at least one employee in Ontario (s. 1(3)). Each must “develop, implement and maintain policies governing how the organization achieves or will achieve accessibility” (s. 3(1)).
| Employees in Ontario | What the regulation requires |
|---|---|
| 1–49 | Policies developed, implemented and maintained (s. 3(1)), and customer service policies (s. 80.46(1)–(3)). No requirement to write them in a document or publish them. |
| 50 or more | The same, plus a statement of organizational commitment (s. 3(2)); documents describing the policies, made public and provided in an accessible format on request (s. 3(3)); and customer service documents given to anyone on request, with notice that they are available (s. 80.46(4)–(6)). |
Even under 50, a written policy is the simplest way to show what your policies are and to train people on them.
What a compliant policy covers
- Customer service principles: dignity, independence, integration and equal opportunity, and communicating in a way that takes the person’s disability into account (s. 80.46(2)).
- Assistive devices people bring with them (s. 80.46(3)).
- Service animals and support persons, if the public comes to premises you own or operate (s. 80.47).
- Notice of temporary disruptions to facilities or services people with disabilities rely on (s. 80.48).
- Training on the standards and the Human Rights Code for employees, volunteers and others (s. 7; s. 80.49).
- Feedback: how you receive and respond to it, including complaints (s. 80.50; s. 11).
- Accessible formats and communication supports on request, at no more than the regular cost (s. 12).
- Emergency and public safety information in an accessible format on request, if you prepare it and make it public (s. 13).
- Employment: accommodation notices in recruitment and offers, informing employees of supports, and individualized workplace emergency information when needed (ss. 22–27).
- At 50 or more: 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).
Free sample policy
This sample was built for a fictional organization with 38 employees. It is illustrative, not a policy to adopt as-is: yours should name your own contacts and describe what you actually do.
Sample policy (PDF) See the sample on the home page
The Deadline Pack builds your policy and the other documents for your size from one questionnaire.
Sources
- O. Reg. 191/11, Integrated Accessibility Standards (ss. 1(3), 3, 7, 11–14, 22–29, 80.46–80.50)
Common questions
Do small businesses in Ontario need an accessibility policy?
Yes. Every organization covered by the standards must develop, implement and maintain accessibility policies (O. Reg. 191/11 s. 3(1)). Under 50 employees they do not have to be written down or published.
When must the accessibility policy be written and public?
At 50 or more employees in Ontario: documents describing the policies, including a statement of organizational commitment, made publicly available (s. 3(2), (3)).
Can I use the sample policy as my own?
It is illustrative and written for a fictional organization. Your policy should name your contacts and describe what your organization actually does.
Related guides
- AODA Customer Service Standard for small businesses: what every Ontario organization with 1 to 49 employees must do
- The multi-year accessibility plan for Ontario organizations with 50 or more employees
- AODA training requirements in Ontario: who must be trained, on what, and what records to keep
- AODA compliance report 2026: what Ontario businesses file by December 31