AODA compliance report 2026: how Ontario online stores file it

Who must file Ontario's AODA compliance report by December 31, 2026, how to count employees, what the portal asks, and how online stores prepare.

By Hicham Mounir, Founder of FixRamp · Published · 8 min read

If your business or non-profit has 20 or more employees in Ontario, you have to file an AODA compliance report this year. Ontario's guide is clear on the date: "The deadline for the report is December 31, 2026" (Ontario). This post explains who files, how to count your employees, what the online portal asks and how an online store can prepare its answers. For the website rule itself (WCAG 2.0 Level AA), see our AODA guide for online stores.

The short answer

  • Who files: businesses and non-profits with 20 or more employees in Ontario, every three years. Designated public sector organizations file every two years; their last deadline was December 31, 2025 (Ontario).
  • When: by December 31, 2026.
  • How: online only, through the Accessibility Compliance Reporting Portal, with a My Ontario Account.
  • What it asks: Yes/No questions. Organizations with 20 to 49 employees answer 1 compliance question; those with 50 or more answer 6 (portal user guide, February 2026).
  • Who signs off: a senior officer with authority to bind the organization confirms the report is complete and accurate.

This page is general information, not legal advice. Check the official sources linked below for your own situation.

Who has to file the AODA compliance report?

Businesses and non-profits with 20 or more employees in Ontario file the report every three years, and the current deadline is December 31, 2026 (Ontario). Smaller organizations still follow the AODA rules but don't file. Your headcount also decides how much the report covers.

Employees in OntarioFollow the AODA rules?File a report?What the report covers
0No, you are exemptNoNothing
1 to 19YesNoNothing
20 to 49YesYesCustomer service standard only (1 question)
50 or moreYesYesAll applicable standards (6 questions)

The 20 to 49 row comes from section 86.1 of the Integrated Accessibility Standards regulation (O. Reg. 191/11), which limits their report to the customer service standard. The question counts come from the 2026 portal user guide.

How do you count your employees?

Ontario counts every full-time, part-time and seasonal employee, plus contract workers, but not employees outside Ontario, volunteers or independent contractors (Ontario). The same page adds: "You are exempt if you do not have employees in Ontario." Getting this number right tells you whether you file and which questions you see.

Online stores often have mixed teams, so it's worth a careful count:

  • Seasonal staff count. Holiday warehouse or packing help is part of the total.
  • Freelancers usually don't. A Shopify or WooCommerce developer you hire as an independent contractor is not an employee.
  • Location matters. Staff working outside Ontario are left out, even if they work for an Ontario business. A store that sells into Ontario but has no employees there is exempt.

If your count sits close to 20 or 50, the line between contract workers and independent contractors can change your answer. That's a good question for an accountant or lawyer.

What does the 2026 portal ask?

The 2026 report is a set of Yes/No compliance questions: 1 for organizations with 20 to 49 employees and 6 for those with 50 or more (portal user guide). Answering No opens checkboxes where you mark the areas of non-compliance.

One example from the guide: "Is your organization in compliance with all applicable requirements of the General Section?"

If any answer is No, a confirmation window appears when you select Submit. The guide describes it as a legal reminder that outlines next steps for organizations reporting non-compliance, and you can submit or go back. It's not a reason to answer Yes when the honest answer is No: the report has to be accurate, as the section on signing off explains.

For 2026, every report is filed through the online portal. You can print a blank copy to circulate internally, but answers must be entered in the portal to submit.

What about the website question?

The website rule applies to organizations with 50 or more employees in Ontario, so a store with 20 to 49 employees reports only on customer service (O. Reg. 191/11). Larger stores need to think about their website when they answer. For a store with 50 or more employees, the website rule is one of the requirements behind the compliance questions.

The rule itself is set out on Ontario's page on how to make websites accessible: WCAG 2.0 Level AA, except live captions and pre-recorded audio descriptions, for web content published after January 1, 2012. Our AODA guide explains what that means for a Shopify or WooCommerce theme, with examples of the issues that come up most.

Before the person signing off answers, it helps to know where your store stands. One practical approach:

  1. Start with an automated check. Our free scan checks one page in about 20 seconds and shows up to 5 of the most serious issue types it finds.
  2. Cover more of the store. Most issues live in theme templates, so they repeat across product and collection pages. A Starter report (USD 249) covers up to 25 pages; Pro (USD 599) covers up to 150 pages, including the cart. Both include corrected code for most issues. See a sample report.
  3. Test what automation can't. Tab through your store with a keyboard, and try a screen reader on one product page.
  4. Keep a record. Dated re-scans show what changed between one check and the next.

A scan report and the compliance report are two different things. The compliance report is what you file with the province. A scan report is engineering guidance for your developer: it helps you find and fix issues, but it doesn't file anything, and an automated scan alone can't confirm that a site meets WCAG 2.0 Level AA.

How do you file the report, step by step?

You file online only, through the Accessibility Compliance Reporting Portal, using a My Ontario Account (an email, a password and a one-time email verification code to set it up) (portal user guide). The official pages don't mention a fee.

What to have ready

  • Your organization's legal name
  • Your business number (BN9), or an AODA identifier if you don't have one
  • Your number of employees in Ontario
  • The name and contact information of the senior officer who signs off on the report
  • The organization's business and mailing addresses
  • Primary contact details

The steps

  1. Go to the portal and select Sign In/Create Account.
  2. Create your My Ontario Account if you don't have one: enter an email and password, then the verification code emailed to you.
  3. Sign in with your email and password.
  4. Select New Submission, choose Accessibility Compliance Report, then Begin Submission.
  5. Answer the questions, review your answers and select Submit.

Tips from Ontario's guide and portal

  • Save often. You can save and return later, but sessions end after 60 minutes of inactivity.
  • Share the draft. You can share a draft with the senior officer who signs off, so they can review it before it is submitted.
  • Group filings. One form can cover up to 20 organizations if they share the same organization category, employee range, signing officer and answers to every compliance question.
  • Keep the confirmation. A confirmation email with a confirmation number goes to the signing officer and the primary contact.

Who signs off, and what happens after you file?

The person who signs, a director, senior officer or other responsible person with authority to bind the organization, confirms that the information is complete and accurate (section 15 of the AODA). Under section 37, giving "false or misleading information in an accessibility report" is an offence. Accurate answers matter more than filing fast.

For an online store with 50 or more employees, this usually means the person signing off should see the evidence behind the website answer. A list of the issues found, what was fixed and when, and what's still open gives them something concrete to review.

After filing, the organization must make the report available to the public, under section 14(2) of the AODA. The portal's Print option creates a PDF you can use for your records and for posting.

What if you miss the deadline?

Ontario says that if you don't complete the report, "you could face enforcement measures which can include financial penalties" (Ontario). Ontario's enforcement data suggests most follow-up aims at getting organizations to file and comply.

The numbers from Ontario's AODA Annual Report 2024, published in December 2025:

  • 1,238 attestation audits were launched in 2024. These target organizations that missed the latest deadline after filing before, reported non-compliance, or have never filed.
  • "In 2024, 99% of verification audits were resolved as compliant. Nineteen Director's Orders and one Director's Order with Administrative Penalties were issued to achieve compliance."

The law does set penalties. Under section 37 of the AODA, the maximum fine on conviction is $50,000 a day for an individual and $100,000 a day for a corporation. Administrative penalties for corporations under Schedule 3 of O. Reg. 191/11 range from $500 to $15,000, depending on how serious the contravention is and the organization's history. In the most serious cases, section 83 lets a director apply the penalty daily, up to $100,000 for a corporation.

Where can you get help?

Ontario lists these contacts for accessibility help:

For your store's website, start with the AODA guide, run a free scan of your homepage, and see what a full report contains. Our guides to missing alt text on Shopify and low color contrast cover two of the most common fixes.

This page is general information, not legal advice. Talk to a lawyer about your own obligations.

Sources

Prepared with AI assistance by the FixRamp team. Statistics link to their sources.