No jargon, no fear-mongering — just what you need to do before December 31, 2026.
Do you even have to file?
It comes down to employee count (full-time, part-time, seasonal, contract all count):
- 1–19 employees: No report required. (You still have obligations under the Human Rights Code and must provide accessible formats on request.)
- 20–49 employees: Yes — file an ACR by December 31, 2026.
- 50+ employees / public sector: Yes, plus you must meet WCAG 2.0 AA on your public website, keep documented policies, and maintain a multi-year accessibility plan.
What the ACR actually is
The Accessibility Compliance Report is a self-attestation you submit to the Ontario government confirming you've met your obligations across the AODA standards (Information & Communications, Employment, Customer Service, Design of Public Spaces where applicable). It's a series of yes/no questions — but answering "yes" honestly means you've actually done the underlying work.
Important: the ACR is not a VPAT. They're different documents for different purposes — confusing them is a common and costly mistake. Here's the difference.
Where and how to file
- Go to the Accessibility Compliance Reporting portal on ontario.ca.
- Sign in (you'll need a ONe-key / Service Ontario business account).
- Confirm your organization details and headcount.
- Answer the compliance questions for your organization type.
- Have an officer/director certify and submit.
It takes minutes if the underlying work is done. The work is the part that takes planning.
The 4 things to do before you file
- Audit your site against WCAG 2.2 AA (automated + manual). What that costs in Ontario.
- Remediate the real source code (not an overlay).
- Document an accessibility statement, policy, and remediation plan.
- File the ACR before Dec 31, 2026.
What if you don't file?
Enforcement is progressive, not instant maximum fines: the Accessibility Directorate sends a notice of non-compliance with time to fix; then a director's order; then administrative penalties (historically hundreds to low thousands); prosecution and the headline "$100,000/day" maximum are reserved for severe, repeated cases and have not been applied as of 2026.
But "low odds of the max fine" is the wrong thing to optimize for. A missing or false report reads as willful non-compliance — exactly the posture you don't want if a Human Rights Tribunal complaint ever lands (that's the real litigation path; the AODA itself has no private right of action). A filed report backed by a real audit is the opposite: evidence of good faith.
Common mistakes
- Treating an overlay widget as "done." It isn't — here's why.
- Assuming "under 50 = nothing applies." The strict web mandate starts at 50+, but reporting starts at 20+, and Human Rights Code exposure has no size floor.
- Filing "yes" without the work behind it.
- Forgetting public PDFs and Word documents are in scope too.
Get a head start in 30 seconds — free
Before you touch the portal, know where you stand. The PassProof Report scans your site against Ontario's rules and tells you exactly what applies to a company your size — plus a fixed-price path to "yes."
👉 Get your free PassProof Report
PassProof is a remote-first accessibility-engineering studio serving Ontario. Accessibility-engineering guidance, not legal advice; we work alongside your counsel.