plainkit

AODA: what changes at 50 employees

The regulation has one rulebook and two sizes. Under 50 employees, you must do the things. At 50 and over, you must also write them down — and publish some of them. Everything else is detail.

The same at every size

Every Ontario business and non-profit with employees must: have accessibility policies (informal is fine under 50); train staff and volunteers on the regulation and the Human Rights Code; provide accessible customer service — assistive devices, service animals, support persons, notice of temporary disruptions; run a feedback process; provide accessible formats and communication supports on request; tell applicants and staff that accommodation is available; and prepare individualised workplace emergency response information for any employee with a disability who needs it. That last one is written at every size.

What 50 adds

ItemUnder 5050 and over
Accessibility policyIn place; writing optionalWritten, with a statement of commitment; made public; accessible format on request
Multi-year accessibility planNot requiredRequired; posted on your website; reviewed at least every 5 years
Training recordsNot required (but the obvious evidence)Written record with dates and number trained
Customer service policyIn placeDocumented, with notice that it's available on request
Feedback processIn placeDocumented
Public websiteNo WCAG requirementWCAG 2.0 Level AA for all public sites (since Jan 1, 2021), except live captions and pre-recorded audio description
Individual accommodation plansIn placeWritten process for documented plans
Return-to-work processDocumented

Why this matters for the report

The compliance report asks the same kind of yes/no questions at both sizes, but a "yes" at 50+ means "yes, and it's written down and where it should be". If you crossed 50 since your last report — or will during this cycle — your answers may have changed even if your practices haven't.

Two dates that also shift at 50

Design-of-public-spaces rules apply to spaces newly built or redeveloped on or after January 1, 2017 for organisations at 50+, and January 1, 2018 for smaller ones. Existing spaces don't have to be retrofitted at either size.

See exactly which items apply to you, with the evidence to keep for each: the free checker.

Sources

Checked against these pages on September 11, 2026. Information, not legal advice.