Training is required from your first employee — there is no under-20 exemption. What changes with size isn't whether you train, it's whether you have to write it down.
Under the Integrated Accessibility Standards Regulation (O. Reg. 191/11), training covers every employee and volunteer, everyone who develops your policies, and anyone who provides goods, services, or facilities on your behalf — so a contractor who deals with the public on your behalf is in scope even though they're not on payroll. It has to be appropriate to each person's duties, given as soon as practicable after they start, and repeated when your policies change.
Two things, from two different sections:
The regulation doesn't prescribe a course or a length. A short in-house session that covers both subjects, with a record of who attended and what materials were used, meets the requirement.
| Item | Under 50 | 50 and over |
|---|---|---|
| Must training happen | Yes — from employee one | Yes |
| Written record | Not required | Required — training dates and the number of individuals trained |
Under 50, nobody checks your paperwork for this unless you're filing the compliance report — but "training" is the item most often answered "yes" on the strength of one session years ago, for people who've since left. A log is the obvious way to make a "yes" true, required or not.
The ones that show up most: new hires trained but nobody re-trained after a policy changed; volunteers and contractors left out because "training" gets read as an HR-onboarding item rather than a regulation requirement; and sessions that cover customer service but skip the Human Rights Code half of s. 7.
One row per person per session is enough: name, role (employee / volunteer / contractor / policy developer), date trained, topics covered, and who delivered it. At 50+, add a yearly summary of total dates and number trained — that's the specific pair the regulation asks for.
See exactly which training obligations apply to your size, alongside every other attestation item: the free checker. A ready-made log template with the columns above, plus the policy and plan templates most organisations are missing, is in the AODA 2026 Compliance Report Kit.
Checked against these pages on September 11, 2026. Information, not legal advice.