Ontario employer compliance calendar 2026–2027: every AODA and ESA date for small employers

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.

Most Ontario employer deadlines fall on four kinds of dates: a fixed date (December 31, 2026 for the accessibility report), a yearly date (January 1 and March 1 for the ESA policies), an event date (a job posting, an interview, a new hire) and a retention period (three years). This calendar lists them in order. Which rows apply depends on your employee count.

Fixed dates

Fixed compliance dates 2026 to 2029
Date	Who	What	Source
December 31, 2026	Organizations with 20 or more employees in Ontario that serve the public or other businesses	File the accessibility compliance report on the Accessibility Compliance Reporting Portal. 20 to 49 employees answer one question about the Customer Service Standards; 50 or more answer about every applicable standard. A director, senior officer or other person with authority to bind the organization certifies it. Make the filed report available to the public.	O. Reg. 191/11 s. 86.1; AODA ss. 14, 15
December 31, 2029	Same	Next report. The cycle runs every three years from the December 31, 2014 report date.	O. Reg. 191/11 s. 86.1(3)

Yearly dates

Yearly compliance dates
Date	Who	What	Source
January 1, 2027 (and every January 1)	All employers	Count employees in Ontario, heads not full-time equivalents. 25 or more means the disconnecting from work and electronic monitoring policies are required for the year.	ESA ss. 21.1.2, 41.1.1
Before March 1, 2027 (and every year the count is 25+)	Employers with 25+ on January 1	Written disconnecting from work and electronic monitoring policies in place, dated. Copies to all employees within 30 days of the policy being prepared or changed. An existing policy does not need to be rewritten; recount, give copies to new staff and re-issue if the wording changes.	ESA ss. 21.1.2, 41.1.1
At least once every five years	Organizations with 50+ employees	Review and update the multi-year accessibility plan.	O. Reg. 191/11 s. 4(1)(c)

Event-driven dates

Event-driven compliance dates
Trigger	Who	What	Source
Publishing a job posting	Employers with 25+ on the posting day	Posting includes expected pay or a range no wider than $50,000 a year (unless above $200,000), a statement whether the posting is for an existing vacancy, a statement if AI is used to screen, assess or select applicants, and no Canadian experience requirement. No age preference at any size.	ESA ss. 8.2 to 8.5; O. Reg. 476/24; Human Rights Code
Interviewing an applicant	Same	Within 45 days of the interview (or last interview), tell the applicant whether a hiring decision has been made. See the 45-day notice guide.	ESA s. 8.6; O. Reg. 476/24 s. 5
A new employee’s first day	Employers with 25+ on that day	Before the first day (or as soon after as reasonably possible), the written new hire information: employer names, contact details, work location, starting pay, pay period and pay day, anticipated hours.	O. Reg. 285/01 s. 1.2
Within 30 days of a new employee starting	All employers	Give the employee a copy of the Ministry of Labour’s employment standards poster.	ESA s. 2(7)
Within 30 days of a new employee starting	Employers with 25+ on January 1	Copies of the disconnecting from work and electronic monitoring policies.	ESA ss. 21.1.2(3), 41.1.1(4)
As soon as practicable after joining	Every organization with an Ontario employee that serves the public or other businesses	Training on the accessibility standards, the Human Rights Code and accessible customer service; tell the new employee about your accommodation policies. See AODA training.	O. Reg. 191/11 ss. 7, 25, 80.49
Changing an accessibility or customer service policy	Same	Train affected people on the change.	O. Reg. 191/11 ss. 7(4), 80.49(4)
A temporary disruption to a facility or service people with disabilities rely on	Same	Post a notice with the reason, expected duration and any alternatives.	O. Reg. 191/11 s. 80.48

Retention periods

Record retention periods
Record	Keep for	Source
Each job posting and associated application form, including linked pages	Three years after public access to the posting is removed	ESA s. 15(7.1)
Each 45-day interview notice	Three years after it was given	ESA s. 15(7.1.1)
Each version of the disconnecting from work policy	Three years after it stops being in effect	ESA s. 15(8.1)
Each version of the electronic monitoring policy	Three years after it stops being in effect	ESA s. 15(8.2)
Accessibility training records (dates, numbers trained)	Required at 50+ employees; no period stated in the regulation	O. Reg. 191/11 ss. 7(5), 80.49(5)

What is not on the calendar

Nothing here is a penalty date. Enforcement of these rules has historically been complaint-driven, and the sensible reason to meet each date is that a director or senior officer certifies the accessibility report and employees are entitled to the ESA documents. If you want this calendar filled in for your own headcount and dates, the free check builds one.

Sources

Common questions

When is the AODA compliance report due?

December 31, 2026, for organizations with 20 or more employees in Ontario that provide goods, services or facilities to the public or other businesses. The next report is due December 31, 2029 (O. Reg. 191/11 s. 86.1).

What Ontario employer deadlines fall on January 1 and March 1?

On January 1 you count employees in Ontario. If the count is 25 or more, written disconnecting from work and electronic monitoring policies must be in place before March 1 (ESA ss. 21.1.2 and 41.1.1).

How long do Ontario employers keep job postings?

Three years after public access to the posting is removed, including any associated application form and linked pages (ESA s. 15(7.1)). Interview notices are kept three years after they are given (s. 15(7.1.1)).

Do these dates apply if I have fewer than 20 employees?

The accessibility report does not, and the 25-employee ESA rules do not. The accessibility standards themselves (policies, training, feedback, customer service), the ESA poster within 30 days and the Human Rights Code apply at every size.