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AODA training requirements in Ontario: who must be trained, on what, and what records to keep

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.

Two sections of O. Reg. 191/11 require training. Section 7 covers the accessibility standards and the Human Rights Code and applies to every organization with at least one employee in Ontario. Section 80.49 covers customer service and applies to every such organization that serves the public or other businesses. Both say “as soon as practicable” and both apply at every size; only the record-keeping and training-policy document duties start at 50 employees.

Who must be trained

Under s. 7(1): all employees and volunteers, everyone who participates in developing your policies, and every other person who provides goods, services or facilities on your behalf. Section 80.49(1) uses the same three groups for customer service training, so the two lists are the same: train everyone.

What the training must cover

Section 7 (general standards)Section 80.49 (customer service)
  • The requirements of the accessibility standards in the regulation that apply to your organization.
  • The Human Rights Code as it pertains to persons with disabilities.
  • The purposes of the AODA and the requirements of the Customer Service Standard.
  • How to interact and communicate with persons 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 access your goods, services or facilities.
  • What to do if a person with a disability is having difficulty accessing them.

Section 7(2) says the training must be appropriate to the duties of the people being trained. A warehouse picker and a front-desk receptionist do not need identical sessions; both need to know the rules that touch their work and the Human Rights Code basics.

When

  • As soon as practicable after a person joins or begins providing services on your behalf (ss. 7(3), 80.49(3)).
  • Again when your policies change. Section 7(4) requires ongoing training on changes to the policies in s. 3; s. 80.49(4) requires training on an ongoing basis when customer service policies change.

The regulation does not set a fixed refresher interval, a minimum duration, or an approved provider. It does not require a certificate. You can deliver training in a meeting, online, or with a written module, as long as it covers the required content and suits people’s duties.

Records

Organizations with 50 or more employees in Ontario must keep a record of the training, including the dates it was provided and the number of individuals trained (s. 7(5)), and must document their customer service training policy and keep customer service training records (s. 80.49(5) to (7)). Small organizations are not required to keep these records. A simple log with the date, the topics and who attended is still the easiest way to show, when you certify your compliance report, that the training happened.

Related duties people forget

  • Telling employees about accommodation. Section 25 requires every employer to inform employees of its policies for supporting employees with disabilities, including accommodation, as soon as practicable after they begin, and to tell them when those policies change. Section 26 requires accessible formats for workplace information on request. These are not training sections but they are commonly covered in the same onboarding.
  • Individualized emergency response information. Section 27 requires it for employees with disabilities where the disability makes it necessary and the employer is aware of the need.
  • Job applicants. Sections 22 to 24 require notice that accommodation is available during recruitment and, when a candidate is selected, on request during the selection process, and notice to the successful applicant of your accommodation policies.

Sources

Common questions

Is AODA training mandatory for small businesses in Ontario?

Yes. Section 7 of O. Reg. 191/11 requires every organization with at least one employee in Ontario to train employees, volunteers, policy developers and others who act on its behalf on the accessibility standards that apply to it and on the Human Rights Code as it relates to disability. Customer service training under s. 80.49 applies to every such organization that serves the public or other businesses.

How often does AODA training have to be repeated?

The regulation does not set an interval. It requires training as soon as practicable and again when your accessibility or customer service policies change (ss. 7(4), 80.49(4)).

Do I need to keep AODA training records?

Only organizations with 50 or more employees in Ontario must keep records, including training dates and the number of people trained (s. 7(5)) and customer service training records (s. 80.49(5)). Small organizations are not required to, though a short log is useful when certifying the compliance report.

Does AODA training need a certificate or an approved provider?

No. The regulation specifies the content and timing, not the format or provider. Any training that covers the required topics and is appropriate to people’s duties meets the wording.