Yes. Ontario treats non-profits and businesses the same under the accessibility regulation: 20 or more employees means a report is due by December 31, 2026. Charitable status doesn't change it.
This is the part non-profits get wrong in both directions. For the 20-employee threshold, count paid staff in Ontario — full-time, part-time, seasonal, fixed-term — and not volunteers. But for training, the regulation is explicit: every employee and volunteer, everyone who develops your policies, and everyone providing goods, services, or facilities on your behalf must be trained on the regulation and the Human Rights Code. A 15-employee charity with 80 volunteers doesn't file, but it trains all 95.
Some organisations that look like non-profits are designated public-sector organisations under the regulation — hospitals, school boards, colleges and universities, and certain other bodies named in it. They file every two years (the last deadline was December 31, 2025) with broader obligations. If you receive most of your funding from the province and aren't sure, check the regulation's schedule; if you're a charity or community organisation with a board and a payroll, you're almost certainly in the business/non-profit stream.
Under 50 staff you must have the practices in place; at 50 and over they must be written and some must be published — the accessibility policy, a multi-year accessibility plan on your website, training records with dates and numbers, and WCAG 2.0 AA for public websites. Non-profits with a public-facing website and 50+ staff often find the website item is the one they haven't checked. Details: what changes at 50.
Nothing in the regulation ties the report to funding, but some funders and government programs ask whether you're compliant. Having the filing confirmation and an evidence folder makes that a one-line answer.
See the list for your size, with the evidence to keep for each item: the free checker.
Checked against these pages on September 11, 2026. Information, not legal advice.