EnAbling Nonprofits Ontario FAQs

Frequently Asked Questions

Our project, EnAbling Nonprofits Ontario, aims to help the sector lead a culture of accessibility. To strengthen the capacity and ability of nonprofits, take a look at the questions below regarding The Accessibility for Ontarians with Disabilities Act (AODA).

Is there a question that wasn’t answered? Please email info@theonn.ca.

All organizations with 1 or more employee(s) must comply with the requirements under the AODA. It applies to all organizations in the public and private sectors of Ontario, including all municipalities in the province as well as ministries and agencies of the Ontario government.

To understand your organization’s obligations, please visit the Government of Ontario Accessibility website. Persons or organizations that have any questions or concerns about their specific obligations are encouraged to consult their legal counsel on matters pertaining to compliance.

If you are entirely volunteer run, you are not legally obligated to comply. Only organizations with one or more employees need to comply with the AODA. However, all organizations are encouraged to adopt accessibility practices wherever possible.

Volunteers are not included in the count to determine an organization size. All full-time, part-time, seasonal and contract employees, regardless of their status, should be counted when determining the number of employees in an organization.

All organizations with one or more employees in Ontario are required to provide training. Training requirements vary under the different standards of the AODA:

Customer Service Standard

Anyone who works with the public or third parties who act on your behalf must receive customer service training. This includes those who develop policies, procedures and practices about the provision of goods or services to the public or third parties.

Integrated Accessibility Standards Regulation

All employees and volunteers, people who develop an organization’s policies, and people who provide goods, services or facilities on behalf of an organization must receive training on the requirements of the Integrated Accessibility Standards (IASR) and the disability-related obligations under the Ontario Human Rights Code. Training must be appropriate to the individual’s role/responsibility within an organization.

Furthermore, organizations with 50 or more employees must keep records of the number of people who were trained and the dates that training was provided.

Individuals should to be trained as needed to perform the duties of their jobs. It is therefore important to assess the requirements in the regulation against the roles or duties of the people within the organization.

Job descriptions, if used, are a good place to start when determining what information a person should receive in a training session, considering at the same time what the person does in practice on a regular basis.

Organizations have flexibility to determine how best to provide the training. An organization may determine one training session is appropriate for various employees even though they perform different duties. In other situations, the training may vary. For example, a human resources manager will need different training than a bookkeeper in the same organization.

Organizations have the flexibility to determine the best training method for their organization. Training can be provided in a variety of ways. It can be a separate training program or included as part of an orientation session or a larger training program. The training can also be delivered in different formats such as handouts or PowerPoint presentations at orientation sessions, or staff meetings, or as on-line training modules.

Some helpful accessibility training resources include the Government of Ontario’s “How to Train Your Staff” and the website, Access Forward.

Organizations are required to train existing and new people at the organization as soon as practicable, and on an on-going basis for anyone who is new. You also need to provide training whenever changes to your accessibility policies are made.

Beginning January 1, 2014 all large organizations (those with 50+ employees) that created new internet websites had to ensure that the site and its content conform with WCAG 2.0 Level A.

A “new” website is would refer to:

1. a site with a new domain name (i.e. a brand new website address, and not a new page or link on the existing site); or

2. a site with an existing domain name undergoing a significant refresh. Significant refresh may include, but is not limited to, a new look and feel, changes to navigability, or the majority of content is being updated or changed.

By January 1, 2021, all internet websites and web content must conform with WCAG 2.0 Level AA, other than success criteria 1.2.4 Captions (Live) and success criteria 1.2.5 Audio Descriptions (Pre-recorded).

Organizations located in Ontario with one or more employee(s) that also have other offices outside Ontario are required to comply with the standards under the Accessibility for Ontarians with Disabilities Act (AODA).

Accessibility in buildings (such as requirements for elevators, power door operators, and accessible entrances) is governed by Ontario’s Building Code. The Building Code is administered by the Ministry of Municipal Affairs and Housing and sets technical requirements for building construction and renovations in Ontario, including requirements for accessibility in buildings.

Under the Building Code, barrier-free design requirements must be included when a new building is constructed, when an existing building undergoes an extensive renovation, or when a building is renovated because of a change to how the building is used.  The Building Code does not require organizations to retrofit existing buildings when no renovations are planned.

Under the AODA, the Design of Public Spaces Standard aims to remove barriers and to make it easier for people with disabilities to move through and use the environment including:

1. Recreational trails and beach access routes
2. Outdoor eating areas for public us
3. Outdoor play spaces (such as playgrounds)
4. Exterior paths of travel (such as walkways across parks or between buildings
5. Accessible on- and off-street parking
6. Service counters and waiting areas

Large private sector/non-profit organizations with more than 50 employees need to comply with the Design of Public Spaces standard starting in 2017. Small private sector/non-profit organizations with 1-49 employees, which have limited obligations under this standard, need to comply starting in 2018.

The Design of Public Spaces Standard applies to new construction and planned redevelopment of existing elements only. Organizations are not required to retrofit buildings or public spaces under the AODA. However, if an organization plans to do renovations to the office it rents, the party who is responsible for meeting accessibility requirements is the party that has this authority to undertake renovations per the legal agreement between the landlord and tenant.  It is advisable to consult legal services to determine this.

There is no legal requirement under the AODA for an organization to provide or pay for an American Sign Language (ASL) interpreter or a support person. You do need to work with the individual who makes a request for information in an accessible format.

Under the Customer Service standard, an organization is not required to cover the cost of a support person for a person with disability. However, if your organization charges admission fees, you are required to give notice, in advance, of the admission cost for a support person, so that a customer with a disability will know what to expect.

Under the Information & Communications Standard within the AODA, organizations are required, upon request, to provide information in an accessible format or communication supports to the public. There are many ways to make information accessible or offer communications support; this would depend on the needs of the person making the request and the specific situation when accommodation is requested. Organizations are urged to work closely with the person making the request to find an option to meet their request and the information or support must be provided in a timely manner and at a cost that is no more than the regular price charged to others.

Some examples of alternate formats and communication supports are: reading written information to a person directly, large print, text transcripts of audio or visual information, handwritten notes instead of spoken word, information written in plain language, an electronic document formatted to be accessible for use with a screen reader.

The organization may wish to contact the Ministry of Community and Social Services office in their area to get help with interpreter and intervener services.

If you are specifically considering how to make meetings and events more accessible, you may wish to consult the Guide to Conducting Accessible Meetings produced by the Ontario Municipal Social Services Association.