How to create an accessibility plan and policy
Find step-by-step instructions and templates to help prepare accessibility policies and a multi-year plan as required under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).
Requirements overview
Organizations with fewer than 50 employees
If you are a business or non-profit organization with fewer than 50 employees, you are required to:
- create accessibility policies (see step one)
- maintain your policies (you are encouraged to update them periodically)
You are not required to:
- document these policies (though doing so may help you with other requirements, including training employees)
- create a multi-year accessibility plan
Organizations with 50 or more employees
If you are a business or non-profit organization with 50 or more employees, or a designated public sector organization, you must develop:
- a statement of commitment to accessibility and make it publicly available
- written accessibility policies and make them publicly available
- a written multi-year accessibility plan, update it at least once every five years and post it on your website (if you have one)
If asked, you must provide your organization’s statement of commitment, accessibility polices and plan in an accessible format.
Key terms
A statement of commitment establishes your organization’s vision and intention to achieve accessibility. It is an important first step in the development of accessibility policies and plans.
Accessibility policies are the formal rules your organization puts in place to achieve its accessibility goals.
An accessibility plan outlines what steps your organization will take to prevent and remove barriers to accessibility, meeting your AODA requirements. It should also outline when the steps will be taken.
These three elements work together to make accessibility a permanent part of your organization’s culture and business practices.
Step one: Create your accessibility policies
These policies set out the rules your organization will put in place to become more accessible. Understanding your organization’s level of accessibility and knowing where the barriers exist can be helpful as you develop your accessibility policies.
Writing your statement of commitment
The statement of commitment summarizes your organization’s commitment to meeting the accessibility needs of people with disabilities.
As you write it, consider your organization’s vision, overall goals and its current level of accessibility. Think about the accessibility message you want to convey to your employees and the public.
Keep in mind that accessibility means giving people of all abilities opportunities to participate fully in everyday life by identifying and removing barriers, and addressing the needs of those with different disabilities, as defined by the AODA.
Once you have finished your organization’s statement of commitment:
- consider telling your employees about it, for example, by posting it on your intranet or asking an executive to send an email message to all employees
- make it publicly available
- provide it in an accessible format on request
Consider putting the statement of commitment on your website, if you have one, or in the "Message from the CEO" section of your multi-year accessibility plan.
SAMPLE Statement of commitment
[Name of Organization] is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence.
We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws.
Developing your accessibility policies
You have the flexibility to determine what accessibility policies best fit your organizational culture and business practices.
This accessibility policy template provides an example of what should be included in an accessibility policy.
Here are some approaches to consider as you develop your accessibility policies.
Identify gaps in your current policies
Some of your current policies may already address accessibility or Ontario’s accessibility laws. For example, you may already have a policy about making information accessible to people with disabilities on request.
Alternatively, when assessing your organization’s level of accessibility, you may have discovered that some of your existing policies create barriers. For example, a policy that requires all purchases to be returned within seven business days creates a barrier for people with disabilities who are not able to travel easily.
Review what you are required to do under the AODA, the barriers you discovered in your assessment and your overall accessibility goals. Next, think about whether creating a policy could help you achieve your goals.
You may also adapt your current policies to include accessibility. For example, if your organization has human resource policies on recruitment or performance management, you could integrate accessibility requirements into these existing policies rather than creating new ones.
Organize and write your policies
Once you have decided what content to include, organize it in a clear, logical sequence that’s easy to understand. Consider starting with your statement of commitment and then adding your other accessibility policies. Your policies must be consistent with the principles of dignity, independence, integration and equal opportunity. You can choose how to format your policies, but they must be documented.
Note: Organizations with fewer than 50 employees are not required to document these policies though doing so may help with other requirements, including training employees.
Example
[Name of organization] will provide, on request, information in an accessible format or with communication supports to people with disabilities, in a manner that takes into account their disability.
Best practice
In your office software, use a structured electronic file to prepare your policies and multi-year plan so it can be easily shared in a variety of accessible formats on request.
A structured electronic file includes information about the format of the document such as titles, section headings, font size and colours. This makes it easy to produce the same document in an alternate accessible format such as a web page, large print, braille or audio version.
Publish your policies
You must make your policies available to the public. As an example, you could post information about the policies on your website, or in your reception area. If asked, you must also provide a copy of the policies in an accessible format.
You may also want to share your policies with your employees so they can see your commitment to accessibility. Consider sending out a memo or posting it on your organization’s intranet, if you have one.
Learn more about how to make information accessible.
Step two: Create your multi-year accessibility plan
Who must comply
Businesses and non-profit organizations with 50 or more employees and designated public sector organizations must develop a written multi-year accessibility plan.
A multi-year accessibility plan can help your organization meet its policy commitments under the AODA and improve overall accessibility. It is a road map to help you remove the accessibility barriers you have identified.
Approaches to consider
Consult the experts: Consult people with disabilities throughout this process. People with disabilities are often knowledgeable about removing the barriers that affect them.
Allocate resources: Estimate the human, financial, and technical resources needed and available.
Assign responsibility: Decide which employee or department will lead your efforts to meet each commitment.
Decide on a timeline: Develop a work schedule that aligns with compliance deadlines for Ontario’s accessibility laws and your organization’s priorities.
Create your public accessibility plan
It’s up to you to decide how much detail to include in your plan. It should outline how you plan to remove accessibility barriers and meet Ontario’s accessibility laws.
See examples of common accessibility barriers and solutions.
This sample multi-year plan template provides guidance for business and non-profit organizations with 50 or more employees.
Your accessibility plan is public. It should use plain language in short sentences, avoiding jargon or acronyms, using the active voice.
Invite people with disabilities, those who have experience with people with disabilities, and others who were part of the consultation process, to comment on your plan.
Designated public sector organizations: You must consult with people with disabilities when creating your plans. If you have an accessibility advisory committee, the committee must be included in the consultation process.
Download the designated public sector accessibility plan template for guidance on how to establish and review your multi-year plans.
Publish your accessibility plan
Post your plan
Get corporate approval and then distribute the plan throughout the organization.
The law says you must post the plan on your organization’s website. If your organization does not have a website, consider telling the public about your multi-year accessibility plan and how they can access it. For example, you could post a message:
- on a bulletin board
- in a newsletter
- through social media
Provide the plan in an accessible format on request
You must also provide your plan in an accessible format when asked. Accessible formats include HTML, Microsoft Word, braille, accessible audio formats and large print.
Learn more about how to make information accessible.
Consider setting up a process to respond to comments and questions from the public. Include contact information in the "For More Information" section of the accessibility plan.
Step three: Review and update your policies and plan
Who must comply
Businesses and non-profit organizations with 50 or more employees and designated public sector organizations must update their accessibility plan at least once every five years and post it on their website (if they have one).
Review and update your policies
A policy is a living document and should be reviewed and updated whenever your organization’s practices or procedures change. As you move forward with implementing your multi-year accessibility plan, you may need to update the policies you have written, or draft new ones.
Review and update your plan
You are required to review and update your accessibility plan at least once every five years and post it on your website, if you have one.
When updating your plan, note the achievements your organization has made and adjust your strategies where necessary.
Best practices
- Build accessibility planning into the existing corporate and strategic business cycles as well as other planning processes.
- Make sure your accessibility policies remain in line with your accessibility plans.
Designated public sector organizations
Consultation
When developing, reviewing and updating your accessibility plans, you must consult with your organizations’ accessibility advisory committee (if you have one), as well as with staff with disabilities. Consultations will provide people with disabilities an opportunity to provide feedback and help you stay aware of the needs of people with disabilities.
Annual status update
You must also prepare an annual report that contains updates on what your organization has done to achieve its accessibility plan. These updates could include information about meeting your accessibility legal requirements as well as other accessibility achievements. Annual status reports must be posted on your organization’s website if it has one. Your annual status report must be provided in an accessible format on request.
Download the designated public sector accessibility plan guidance which includes a template for the annual status report.
Common barriers and solutions
Some people see disabilities as the barrier. But that’s not the case. For example, Sarah has low vision and has a hard time reading some restaurant menus. Her low vision is not the barrier. The barrier is the small print on the menus. When a restaurant gives Sarah a large print menu, she can read it and place her order easily on her own.
The tables below illustrate the various types of barriers that exist and some possible solutions for their removal.
Attitudinal barriers
These may result in people with disabilities being treated differently than people without disabilities.
| Attitudinal Barriers | Possible Solutions |
|---|---|
| Thinking that people with intellectual disabilities are not able to make decisions. | Do not assume what employees or customers with disabilities can or cannot do. Ask them. |
| Assuming that a person who has a speech impairment cannot understand you. | Train staff to interact and communicate with people with different types of disabilities. |
| Believing a person who has a mental health disability or someone who uses a wheelchair would not be a good employee. | Learn about ways you can accommodate employees with disabilities. |
| Assuming that a person with vision loss cannot enjoy movies, TV or concerts. | Learn about the different ways and available technologies that help people with vision loss enjoy movies, TV and concerts. |
| Avoiding a person with a disability in fear of saying the wrong word or offending them. | Train staff to interact and communicate with people with different types of disabilities. |
| Thinking that every person with a disability will need costly accommodation. | Learn about the types of accommodations for people with disabilities. Many are low cost. |
Informational and communication barriers
These barriers arise when a person with a disability cannot easily receive and/or understand information that is available to others.
| Informational and Communication Barriers | Possible Solutions |
|---|---|
| Print that is too small to read. | Make everyday documents, like signs and menus, easy to read by making sure that the print is legible for most people. |
| Presentation materials for meetings, such as slide decks and videos, are not accessible to employees with low vision or who have hearing loss. | Develop a template for slide decks using large fonts, high contrast colours and clean layout. Provide a visual description of the slides when making a presentation. |
| Videos don’t have captions and are not accessible to people who have hearing loss. | Provide captions for videos and, when this is not possible, provide a text transcript of the video. |
| Brochures, guides and advertisements are not clear or easily understood. | Use plain language, symbols and pictures to get your message across. |
| Website pictures are not described and are not accessible to people who rely on assistive technology. | Provide descriptions or alt tags for pictures for people who rely on assistive technology. |
| Complicated, busy or confusing signs. | Keep signs clean and clear. Make information available in another form, such as a chart or pictogram. |
| Seating arrangements make it difficult for people who have hearing loss to fully participate in meetings. | Arrange seating at a round table to facilitate lip reading. Use assistive listening or amplification devices as appropriate. |
| Marketing and communications are not inclusive, either in depicting people with disabilities, including them as a potential target audience, or in considering them. | Check that your marketing and communications efforts reach people with disabilities. Include people with disabilities of all generations in photos, testimonials and other communications. Ensure marketing collateral such as flyers, brochures, podcasts and YouTube videos, are accessible. |
Technological barriers
These occur when technology or the way it is used does not meet the needs of people with disabilities.
| Technological Barriers | Possible Solutions |
|---|---|
| Emails or other electronic communications are not accessible to people who use screen readers. | Make sure every email is accessible to people who use screen readers and offer alternative methods of communication. |
| Having only one way for your customers to reach you, for example, by telephone only. | Allow customers to contact you in a variety of ways including telephone, email, TTY or train your staff on using the relay service over the phone. |
| Accepting only online job applications. | Welcome job applications in a number of formats. |
Systemic barriers
These are aspects of policies, practices and procedures that result in people with disabilities being treated differently than others or sometimes excluded altogether.
| Systemic Barriers | Possible Solutions |
|---|---|
| People with disabilities are excluded from events, or included as an after-thought when planning events. | Make sure that accessibility is considered when making plans for events and invite attendees to tell you if they have different needs. Consider using an accessibility checklist for events. |
| Not knowing about the different types of accommodations an employee might need to return to work after an absence due to a disability. | Learn about the types of accommodations employees might need. Talking with employees about their specific needs is a good first step. |
| There is no leadership or accountability for issues related to accessibility for people with disabilities. | Designate a point person to implement accessibility policies and procedures. |
| Hiring policies do not encourage applications from people with disabilities. | Review current hiring processes to identify and remove barriers, such as inaccessible locations for interviews. |
| Procedures may exclude some employees, such as directing maintenance/housekeeping staff to only use certain cleaning products that can cause allergic reactions. | Implement a "fragrance-free" policy. |
Physical and architectural barriers
These barriers in the environment prevent access for people with disabilities.
| Physical/Architectural Barriers | Possible Solutions |
|---|---|
| Aisles are blocked by displays or merchandise making them too narrow for a person using a wheelchair or walker. | Consider the paths that your employees and customers take when creating displays or storing merchandise. |
| Event or meeting spaces are inaccessible. | Think about potential barriers when selecting a venue. Do not just look for a ramp. Consider the washrooms, lighting and signage. |
| Accessibility features such as power-operated doors are broken and not fixed promptly. | Develop a maintenance plan and ensure prompt response times when equipment is broken. |
Disclaimer
The aim and purpose of this webpage is to help individuals and businesses with information related to the Accessibility for Ontarians with Disabilities Act, 2005 and its associated regulation OReg 191/11. While we aim to provide relevant and timely information, no guarantee can be given as to the accuracy or completeness of any information provided. This guidance is not intended to nor does it provide legal advice and should not be relied upon or treated as legal advice. Those seeking legal advice should consult with a qualified legal professional.
In case of discrepancy between website content and relevant Ontario legislation and regulations, the official version of Ontario Acts and Regulations as published by the King's Printer for Ontario will prevail.
The Ministry for Seniors and Accessibility and the Government of Ontario do not endorse or recommend any accessibility consultant(s), their advice, opinions or recommendations.