AODA compliance update: January 1, 2015 requirements

17 juillet 2014

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Now that the half-way point  of 2014 has come and gone, employers that have not already considered the next set of requirements under Ontario’s Accessibility for Ontarians with Disabilities Act, 2005 (the AODA) would be wise to do so.  In addition to those AODA requirements under the Customer Service and Integrated Accessibility Standards that are already in force, effective January 1, 2015 a number of additional requirements come into force under such legislation. 

This post is intended to provide an outline of these new requirements as they apply to private and not-for-profit organizations (Organizations). 


Organizations with 50 or more employees in Ontario must ensure that training is provided on the requirements of the Integrated Accessibility Standards as well as Ontario’s Human Rights Code (the Code) as it pertains to persons with disabilities.  While the AODA does not provide further direction as to the specific content of such training, the Ministry of Economic Development, Employment, and Infrastructure has stated that the training should include information about achieving accessibility by 2025 and highlight the applicable requirements of the the integrated standards (Information and Communication, Employment, Transportation and Design of Public Spaces).  The Ministry has also stated that in providing such training Organizations must understand their requirements under the Code and the differences between the Code and the the integrated standards.

The training must be provided to employees, volunteers, individuals who participate in the development of an Organization’s policies, as well as all any other persons who provide goods, services, or facilities on its behalf.  Notably, the training must be tailored to the specific duties and roles of the individuals being trained and records of any conducted training must be kept.  New employees and other individuals coming within the scope of the training obligation must be trained as soon as practicable and on an ongoing basis to the extent there are any changes to an Organization’s accessibility policies. 

For Organizations with less than 50 employees, training obligations will become effective on January 1, 2016.


Organizations with 50 or more employees in Ontario must ensure that any processes currently in place for receiving and responding to feedback (i.e. questionnaires, surveys, etc.) are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communications, upon request.  Such Organizations with feedback processes are also required to notify the public about the availability of accessible formats and supports.  Notably, the AODA does not require Organizations that do not currently use feedback processes to create them. 

Feedback-related obligations applicable to Organizations with less than 50 employees will be effective as of January 1, 2016. 

Establishment of Accessibility Policies

Organizations with less than 50 employees will be required to develop, implement, and maintain policies governing how they achieve or will achieve accessibility through meeting the requirements of the Integrated Accessibility Standards. 

As previously outlined, Organizations with 50 or more employees were required to have such policies as of January 1, 2014.  As of that date, such Organizations were also required to have (a) reduced such policies to writing, (b) created a written “statement of commitment” relating to their obligations under the Integrated Accessibility Standards, and (c) created a detailed written accessibility plan outlining the steps to be taken to achieve compliance.  Such Organizations were also required to have these documents publicly available and in accessible formats upon request. 

Self-Service Kiosks

While the Integrated Accessibility Standards already require government and designated public sector organisations to include accessibility features in any self-service kiosks they design or otherwise procure, Organizations with less than 50 employees will only be required to consider the accessibility of any such kiosks by January 1, 2015.  Examples of self-service kiosks are: those used for parking payments, ticket validation, retail self-check-out purchases or license renewals.  When considering accessibility while designing or purchasing kiosks, the following should be taken into account:

  • Technical aspects, such as colour contrast and voice activated features; and
  • Structural aspects, such as height and stability, specialized keypads or keyboards and headset jacks with volume control.

Organizations with 50 or more employees were required to consider kiosk accessibility as of January 1, 2014. 

We would also note that additional January 1, 2015 requirements apply to educational and training-related institutions and organizations that are beyond the scope of this blog post.

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