Williams HR Law LLP

Upcoming Deadlines for Employers Under the AODA

December 11, 2019

[vc_row][vc_column width=”1/4″][vc_single_image image=”3445″ img_size=”large”][/vc_column][vc_column width=”3/4″][vc_column_text]Going into 2020, employers with 20 or more employees should be aware of a few upcoming deadlines under the Accessibility for Ontarians with Disabilities Act and its Integrated Accessibility Standards regulation (the “AODA”). The AODA sets out accessibility standards for the purpose of helping achieve accessibility for all Ontarians with disabilities by 2025.

Although the AODA applies to all employers that have at least one employee in Ontario, regardless of whether they are private, public, or non-profit, compliance deadlines under the AODA vary based on the size of employers’ organizations and the sectors in which they operate. As such, employers should carefully review the AODA compliance deadlines set out below to ensure that they are prepared to meet these deadlines.

Accessibility Compliance Reports

Employers with 20 or more employees are required to periodically self-assess their compliance with the provincial accessibility requirements under the AODA and to file Accessibility Reports regarding their compliance. There are two different upcoming deadlines for Accessibility Reports to be filed:

  • Designated public sector organizations under the AODA must file an Accessibility Report by December 31, 2019.
  • Private-sector employers and non-profit organizations with 20 or more employees must file an Accessibility Report by December 31, 2020.

Website Accessibility

The AODA requires all employers with 50 or more employees and designated public sector organizations to make their websites and web-based consent accessible, subject to certain exceptions. In particular, such employers must ensure that all web-based content adheres to the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG 2.0), at Level AA, (except for captioning and audio descriptions) beginning January 1, 2021.


Employers should be proactive in taking early steps to ensure that they meet their upcoming compliance deadlines under the AODA. In particular, all employers that are required to file Accessibility Reports should ensure that they begin conducting a compliance audit well in advance of the deadline for filing that is applicable to them. Similarly, all employers with 50 or more employees and designated public sector organizations should apprise themselves of the WCAG 2.0 guidelines and provide training to employees responsible for their web-based content, if necessary, to ensure that all content posted on January 1, 2021 or later complies with the AODA.

This blog is provided as an information service and summary of workplace legal issues.

This information is not intended as legal advice.