Guide
The AODA accessibility policy: what it must contain
Every obligated organization must have accessibility policies. Organizations with 50 or more employees, and all public sector organizations, must write them down and make them public. Here is what the regulation asks for and an outline to draft from.
What section 3 requires
- Everyone: develop, implement and maintain policies governing how you achieve or will achieve accessibility by meeting the regulation's requirements (s. 3(1)).
- 50 or more employees and public sector: include a statement of organizational commitment to meeting the accessibility needs of persons with disabilities in a timely manner (s. 3(2)); prepare one or more written documents describing the policies; make them publicly available; provide them in an accessible format on request (s. 3(3)).
- 1 to 49 employees (businesses and non-profits): no written document is required. Ontario's page: “not required to document these policies, but it's a good idea”.
The customer service standard has its own policy duty (s. 80.46): policies on providing goods, services or facilities to persons with disabilities, following dignity, independence, integration and equal opportunity, and dealing with assistive devices. At 50 or more employees it must be written and available on request (s. 80.46(4)). Many organizations put both in one document.
A plain outline
- Statement of commitment. One or two sentences: your organization is committed to meeting the accessibility needs of people with disabilities in a timely manner, and to meeting the requirements of the AODA and its standards.
- Scope. Who the policy covers: employees, volunteers, people who develop your policies, anyone providing goods, services or facilities on your behalf.
- Training (s. 7): who is trained, on what, when, and how it is recorded.
- Information and communications (ss. 11 to 14): feedback process, accessible formats and communication supports on request, emergency information, website (50 or more).
- Employment (ss. 22 to 32): recruitment notices, accommodation, individualized emergency response information, accommodation plans and return to work (50 or more).
- Customer service (ss. 80.45 to 80.51): assistive devices, service animals, support persons, disruption notices, training, feedback.
- Design of public spaces (Part IV.1): if you build or redevelop.
- Multi-year accessibility plan (s. 4, 50 or more): reference and where it is posted.
- Availability. Where the policy is posted, how to request it in an accessible format, who to contact.
- Review. Who owns the policy and when it is reviewed. Signature and date.
What a policy does not do
Having a written policy is one duty. Doing what it says is the rest. The government's report asks whether you meet the standards, not whether you have a document, so a policy nobody follows helps no one. Keep the records that show the policy in action: training lists, feedback received and answered, notices posted.
Lisavel's full report drafts your accessibility policy from your questionnaire answers, so it describes what your organization actually does and commits to, with a signature block and posting instructions. For 20 to 49 employees it is a recommended template, not a requirement. Start with the free check (about a minute), then see pricing.
Sources
- O. Reg. 191/11, s. 3 (accessibility policies) and s. 80.46 (customer service policies).
- Ontario: Accessibility rules for businesses and non-profits, “Create accessibility policies”.
Not legal advice. The regulation on e-Laws prevails.