Ontario organizations with 50 or more employees are required to maintain a written Multi-Year Accessibility Plan (MYAP) under the IASR (Integrated Accessibility Standards Regulation, Ontario Regulation 191/11). The plan must be reviewed and updated at least once every five years and posted publicly on the organization's website. The initial deadline for large private-sector organizations was January 1, 2014 — meaning a plan created then and reviewed in 2019 was due for its second review no later than January 1, 2024. As of June 2026, many Ontario employers are preparing to file the AODA (Accessibility for Ontarians with Disabilities Act) Accessibility Compliance Report by December 31, 2026 without a current MYAP in place.
That compliance report requires an attestation — not a promise — that IASR obligations are being met. For 50+ employee organizations, the MYAP is part of that obligation. A plan last reviewed in 2017 or never updated since 2014 cannot support an honest attestation.
Key facts
- Ontario Regulation 191/11 (IASR), Section 4 requires organizations with 50 or more employees to establish, maintain, and document a written Multi-Year Accessibility Plan (Government of Ontario, ontario.ca).
- The plan must be reviewed and updated at least once every five years and posted on the organization's website, if one exists, and provided in an accessible format upon request (O.Reg. 191/11, Section 4; ontario.ca/page/how-create-accessibility-plan-and-policy).
- The initial deadline for large private-sector and non-profit organizations (50+) to have their first MYAP was January 1, 2014; following the 5-year review cycle, subsequent reviews were due by January 1, 2019 and January 1, 2024 (O.Reg. 191/11 compliance schedule; aoda.ca).
- Organizations with 1 to 49 employees (small organizations) are exempt from the MYAP requirement, though they still have other IASR obligations — including accessible customer service, accessible formats on request, and employment accessibility policies.
- The AODA Accessibility Compliance Report due December 31, 2026 covers organizations with 20 or more employees and requires attestation of IASR compliance — which for 50+ employee organizations includes the MYAP obligation (ontario.ca).
- The MYAP must address barriers across all areas of the IASR — employment, information and communications, customer service, and (where applicable) transportation and the built environment — not just the organization's website.
What is an AODA Multi-Year Accessibility Plan?
A Multi-Year Accessibility Plan is a written document that sets out your organization's strategy for preventing and removing accessibility barriers over a defined planning period. Unlike a one-page accessibility policy, which states that you are committed to accessibility, the MYAP explains how your organization plans to achieve compliance: which steps will be taken, in what order, and on what timeline.
The plan must cover the full scope of IASR requirements that apply to your organization. For most private-sector employers with 50 or more employees, that scope includes accessible customer service, accessible formats and communication supports, accessible employment practices (from recruitment through return-to-work), and website accessibility (WCAG (Web Content Accessibility Guidelines) 2.0 Level AA for public-facing web content — the legal floor under the IASR).
A MYAP is not a project plan for a single website redesign. It is an organization-wide accessibility roadmap that touches every department that interacts with employees or the public.
Who must have a Multi-Year Accessibility Plan in Ontario?
The obligation under Section 4 of O.Reg. 191/11 applies to two groups:
- Private-sector and non-profit organizations with 50 or more employees in Ontario
- Designated public sector organizations of any size — including government ministries, agencies, Crown corporations, hospitals, school boards, universities, colleges, and municipalities
Organizations with 1 to 49 employees (small organizations under the IASR) are not required to have a MYAP. They do still have other IASR obligations — including customer service accessibility, accessible formats on request, and accommodation-related employment policies — but the written multi-year plan is not among them.
If your organization has grown through the 50-employee threshold, the MYAP obligation applies from that point forward, not just from the next reporting year.
What must the plan contain?
The regulation does not prescribe a rigid template, but the plan must outline your organization's strategy to prevent and remove barriers and meet its IASR obligations. A well-constructed MYAP typically contains:
- A statement of commitment to accessibility, signed by or on behalf of senior leadership
- Current state: a summary of accessibility measures already in place across employment, customer service, information and communications, and web content
- Planned steps: the specific actions the organization will take to address known gaps, with target completion dates
- Responsibilities: which roles or departments are accountable for each commitment
- Feedback mechanism: how employees and customers can report accessibility barriers and how those reports are addressed
For designated public sector organizations, the regulation additionally requires that the MYAP be developed in consultation with persons with disabilities, and that the organization prepare an annual status report on progress toward the plan's commitments (O.Reg. 191/11, Section 4; ontario.ca/page/how-create-accessibility-plan-and-policy).
When must the plan be reviewed and updated?
Section 4 of the IASR requires organizations to review and update the accessibility plan at least once every five years. The clock runs from whenever the plan was last reviewed, or from when it was first created if it has never been reviewed. An organization that created its first MYAP in January 2014 and reviewed it in January 2019 was due for its next review by January 2024 — roughly 18 months ago as of this writing.
A five-year review requires more than a date change on a document. It means:
- Assessing which commitments from the previous plan were completed and documenting the outcomes
- Identifying new accessibility gaps — including those introduced by new digital products, new services, or changed operating models
- Updating the timeline and responsibility assignments for the next planning period
- Re-posting the revised plan publicly in an accessible format
A plan that still describes commitments in future tense from a decade ago — "we will review our recruitment materials by 2016" — is not a current MYAP. And a plan composed of language that was never acted on cannot support an attestation that accessibility obligations have been met.
Does the plan need to be posted publicly on our website?
Yes. The IASR requires organizations subject to Section 4 to post the accessibility plan on their website, if the organization has one, and to provide it in an accessible format upon request (ontario.ca/page/how-create-accessibility-plan-and-policy). Accessible formats include HTML, tagged PDF, accessible Microsoft Word, large print, braille, and audio recordings.
The plan must be accessible as a public document — not stored only in an internal policy folder, not behind a login, and not provided only as an image-based or untagged PDF that a screen reader cannot parse. Organizations whose own MYAP document is inaccessible are in the unusual position of violating the IASR in the act of posting evidence of IASR compliance.
How does the MYAP connect to the December 31, 2026 compliance report?
The AODA Accessibility Compliance Report is an attestation: organizations are confirming that they are meeting their IASR obligations, not merely that they intend to. For organizations with 50 or more employees, those obligations include the MYAP. An outdated, missing, or non-publicly-posted plan means the compliance attestation cannot be made honestly.
There is also a practical connection to HRTO (Human Rights Tribunal of Ontario) exposure. If an employee or customer files an accessibility complaint under the Human Rights Code — the more common real-world enforcement path, since the AODA itself has no private right of action — a documented and up-to-date MYAP is part of the evidence base for a good-faith response. Organizations that cannot produce a current plan are in a weaker position than those with an actively maintained accessibility program. Our guide to how an HRTO complaint unfolds explains the complaint process and what documentation helps.
Enforcement under the AODA itself follows a progressive sequence — notice, Director's Order, Administrative Monetary Penalties, and, in the most serious cases, prosecution. The statutory maximum is up to $100,000 per day for a corporation on conviction — a ceiling that, as legal commentators and industry observers have noted, has not been applied to small or mid-sized businesses in practice; typical penalties have ranged from several hundred to several thousand dollars. The enforcement path is real, and the process is progressive; the risk is real, but is not the daily-maximum level that the statute permits in the most extreme cases.
The HRTO path remains more active in practice. How AODA and the Human Rights Code interact is explained in our overview of AODA enforcement for Ontario businesses.
What this means for your business
If your organization has 50 or more employees, three questions determine whether your MYAP obligation is current: Does a written MYAP exist? Was it reviewed within the last five years? Is it posted on your website in an accessible format? If any answer is "no" — or "I'm not sure" — the six months before the December 31, 2026 deadline is the right window to close that gap.
The ACR filing itself is a short online form. The preparation work takes weeks: reviewing and updating the plan, documenting completed commitments, identifying current gaps, reformatting the document to accessible standards, obtaining sign-off, and publishing it publicly. Discovering a missing or outdated MYAP in November 2026 is a harder problem than addressing it now. Our realistic remediation timeline for the December deadline shows how the MYAP update fits into a broader compliance calendar.
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PassProof is a remote-first accessibility-engineering studio serving Ontario. General information, not legal advice.