Letter from the chair

The Honourable Raymond Cho
Minister for Seniors and Accessibility
777 Bay Street
5th Floor, Toronto, Ontario
M7A 1S5

Dear Minister,

The Customer Service Standards Development Committee has concluded our review of the customer service standards and general requirements in the Integrated Accessibility Standards Regulation (IASR) Ontario Regulation 191/11, under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). On behalf of the committee, I am pleased to submit our Improving accessible customer service standards – 2025 final recommendations report.

The customer service standards are unique within the standards under the AODA in their wide-ranging impact on organizations and the public. They touch many facets of everyday life and apply to all organizations that provide goods, services or facilities, whether they serve the public or other businesses or organizations.

The committee dedicated the final phase of our work to considering the thoughtful input received from the public consultation on our initial recommendations report. Ontarians with disabilities and their support persons shared examples of barriers to accessibility that make it challenging to get the products and services they want. Organizations shared potential implications that the recommendations could have on staffing and financial resources and expressed the need for enhanced training tools and clearer guidance on current requirements. The committee carefully considered members’ lived experience and input from disability organizations, municipalities, businesses and various sectors to address as many barriers as possible and inform our proposed revisions to the AODA.

During the latter stage of the review, the committee had robust discussions about service animals — a complex topic on which the public and disability organizations provided feedback. We recognized that there is ongoing uncertainty amongst people with disabilities and organizations about the definition of a service animal. After thorough discussion on different types of animals and the support they provide, training, behaviour and other relevant laws, we recommended amending the definition of “service animal” under the IASR with the intent of improving clarity. The area of service animals was also discussed during a presentation by Uber Canada on its improvements for riders with service animals.

There is no one-size-fits-all solution to accessibility. Throughout our review, the committee focused on the diverse range of disabilities and considered the intended outcome of our recommendations and ability to implement them across different types of organizations, as well as measure and enforce them. We also built flexibility into the recommendations to account for future technological advancements.

We deliberated on how our recommendations correlate with existing AODA and other standards. Members flagged instances in which existing Ontario standards require a higher level of accessibility than proposed federal accessibility standards. Where organizations are subject to different jurisdictional laws, the committee encourages them to pursue the highest level of accessibility possible.

Advancing awareness and education is essential to driving meaningful change. Employers, municipalities and organizations need to understand which AODA requirements apply to them and how to implement them. Many of the committee’s recommendations emphasize the importance of government support through resources and better guidance to help strengthen and promote compliance.

As the Ontario government works to advance accessibility, identifying and removing barriers is a shared responsibility across communities, businesses, organizations and all levels of government. It will take true collaboration to remove barriers to accessible customer service that people with disabilities continue to face.

It has been a privilege to chair this committee. I wish to express my gratitude to the members for their ongoing commitment. I was impressed by the depth and variety of feedback and expertise they shared. We are confident that our recommendations are as clear and practical as possible. Our final recommendations are intended to help government make customer service — a pivotal part of Ontarians’ everyday experiences — more inclusive for all.

Sincerely,
Jeff Adams
Chair of the Customer Service Standards Development Committee

Background

Standards development and the law

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) is about identifying, removing and preventing barriers for people with disabilities. The AODA sets out accessibility standards in key areas of daily life, including customer service, to help create a more accessible and inclusive Ontario.

The AODA contains general requirements in Ontario Regulation 191/11 under the IASR. In 2008, the customer service standards became the first accessibility standards to be made into regulation under the AODA. Under these standards, public, private and not-for-profit organizations with more than one employee in Ontario must provide accessible customer service to people with disabilities. Accessible customer service is about understanding that customers with disabilities may have different needs and finding the best way to help them access goods, services and facilities. This way all Ontarians can have independence and dignity when receiving customer service.

Public sector organizations were required to comply with the customer service standards as of January 1, 2010. Private and not-for-profit sector organizations were required to comply with these standards as of January 1, 2012.

The first customer service standards review

Standards development committees are responsible for reviewing existing accessibility standards in Ontario, proposing amendments to the existing standards and creating new ones.

The first Customer Service Standards Development Committee began its review of existing customer service standards in 2013. The committee included representatives from various sectors, including business, municipalities and people with disabilities. The committee submitted its proposed initial and final changes in 2014. These recommendations led to amendments to the standards in 2016 to address harmonization with other standards, as well as gaps with training, support persons and the definition of service animals.  

The second customer service standards review

In summer 2023, the Minister for Seniors and Accessibility established the most recent Customer Service Standards Development Committee and requested that it undertake an evidence-based review of the customer service standards, with a focus on requirements that were amended or created in 2016, as well as assess whether changes are needed to the general requirements under the IASR (Part I). This committee began its work in fall 2023.

Scope and timelines

The Standards Development Committee was tasked to review the customer service standards, as prescribed in Section 9 of the AODA and summarized as follows:

  1. Re-examine the long-range objectives of the standards.
  2. If required, revise the measures, policies, practices, and requirements to be implemented on or before January 1, 2025, and the timeframe for their implementation.
  3. Develop initial recommendations for public comment on changes to the standards.
  4. Consider public feedback and make final recommendations to the minister for proposed accessibility standards.

An overview of the initial report

In developing its initial recommendations, the committee held 10 meetings over 6 months. The committee considered the evolution of the customer service landscape since the time of the first review, and the resulting issues and potential gaps that have arisen since then.

As it developed its recommendations, the committee used a multifaceted lens to reflect equity and inclusion. Members discussed the range of disabilities and barriers that exist, while also considering the technical and fiscal impacts that implementation may have on various sectors. The committee also gave substantial thought to the existing legislative and regulatory frameworks. In particular, the committee considered the procedural duty to accommodate under Ontario's Human Rights Code (the Code) in its deliberation of proposed recommendations for customer service. Beyond this, the committee recognized the need for clear guidance, support and education for obligated organizations in understanding their requirements under the AODA, the IASR and the Code.

External legal experts and disability rights advocates delivered presentations and provided perspectives that were informative to the committee as it developed its recommendations.

The director of the AODA Compliance Assurance Branch from the Ministry for Seniors and Accessibility presented on data gathered by the ministry and provided examples of areas where more clarity was needed to support organizations in understanding their requirements under the customer service standards. Ministry staff also presented on broader accessibility data and best practices from a variety of jurisdictions. This helped the committee consider both the current state of accessibility challenges, as well as desired future outcomes.

These learnings and considerations were all used to inform the initial recommendations report that was submitted to the Minister for Seniors and Accessibility in 2024.

Public consultation

The initial recommendations report was published on Ontario.ca and a public consultation on the report was held from October 10, 2024 to February 6, 2025, providing an important opportunity for individuals and organizations to share feedback on the committee’s initial recommendations.

Individuals, municipalities and organizations representing people with disabilities, municipalities, educational institutions and the transportation and banking industries provided feedback via the public consultation. The committee values the thorough and thoughtful feedback received. A large majority of the respondents that provided feedback via the online survey — 87% — were supportive of the overall initial recommendations.

The chair also held a consultation with the Accessibility Standards Advisory Council, a council that advises the Minister for Seniors and Accessibility and other ministries across the Government of Ontario on accessibility-related matters, policies and programs. Council members provided valuable comments highlighting the need to enhance accessibility awareness amongst employers. Members also addressed the multifaceted nature of issues involving service animals and the importance of providing clarity for customer service providers around how to identify them.

The committee carefully considered the feedback provided through all consultations and had substantial discussion and debate as it finalized its recommendations.

An overview of the final report

After the public consultation period closed, the committee reconvened for 6 final meetings to review and consider the resulting feedback. These deliberations raised important questions and prompted meaningful discussion, with significant focus on the key areas of harmonization of accessibility requirements and definitions of service animals and customer service. As a result, several revisions were made throughout the initial recommendations.

Vision and long-term objective

Committee discussion

Under section 9 (2) of the AODA, standards development committees are required to determine the long-term accessibility objectives for the industry, sector of the economy or class of persons or organizations in relation to which the committee has responsibilities.

The committee deliberated whether the existing long-term objective of the customer service standards summarized the purpose, vision and intended outcomes of the standards.

The committee applied a forward-looking approach to its long-term objective from both an aspirational and practical point of view, aiming to capture the spirit and vision of the intended outcome of the customer service standards in a flexible way.

Proposed long-term objective of the customer service standards

The committee recommends adoption of the following as the long-term objective: “The long-term objective of the customer service standards is that persons or organizations providing goods, services (including programs), and facilities understand their obligations to design and deliver barrier-free customer service that is accessible and equitable to persons with disabilities in the province of Ontario. The standards specify requirements for achieving the long-term objective.”

Implementation timelines

Throughout its discussions, the committee acknowledged the importance of allowing time and flexibility for government to consider and implement the recommendations. The committee carefully considered the need for change while recognizing that organizations would require adequate time to prepare to implement potential changes that come into effect.

Given this, the committee recommends that all non-regulatory recommendations, such as those related to guidance materials, tools and resources, be implemented within 18 months, while all recommendations that are regulatory in nature be implemented within 3 years.

Recommendation 1: establishment of accessibility policies

The requirements for the establishment of accessibility policies are stated in both the general requirements (section 3) and the customer service standards (section 80.46) of the IASR.

In finalizing its recommendation, the committee considered the following issues:

  • the general requirements and the customer service standards include duplicative requirements for the establishment of accessibility policies
  • there is currently no requirement for organizations to review or update their existing policies, which can leave them inconsistent or outdated over time
  • people access goods and services in diverse ways, which was reiterated through the public consultations

Overall, feedback from the public consultation on the committee’s initial recommendations supported providing guidance materials to help organizations in developing their accessibility policies. Some respondents felt that policies do not change frequently enough to justify annual updates.

The committee recommends:

  1. Government, Ontario Legislative Assembly, broader public sector and small private organizations’ policies should be reviewed, updated and renewed in line with their existing compliance reporting periods:
    1. Large organizations, specifically, should review their policies yearly.
    2. All organizations should write their policies in plain language with templates or best practices provided by government in collaboration with umbrella organizations.
  2. When creating or reviewing their accessibility policies, organizations should review their other existing by-laws and policies to reflect the IASR requirements, where applicable.
  3. Government should provide guidance on key areas that can be looked at from an accessibility lens when organizations are reviewing their policies (for example, the Smart Serve template).
  4. Streamline existing requirements for making information available to the public:
    1. Create a checklist document that highlights all the requirements that need to be publicly posted (for example, feedback process, policies).
    2. Amend the IASR to require information to be included in an organization’s publicly posted accessibility policies.
  5. Update the language in the customer service standards from “equal” to “equitable” to reflect the different needs of people with disabilities.
  6. The Customer Service Standards Development Committee is in agreement with the Information and Communications Standards Development Committee recommendation 6 and, for clarity, proposes amending “in a timely manner” to “in a mutually agreed upon timely manner which considers the circumstances of the requester, and the urgency of his or her request.”
  7. Organizations’ policies to include a statement of commitment affirming they fully comply with the provisions of the customer service standards to ensure their goods, services or facilities are barrier-free and provide full and equitable opportunities for persons with disabilities to freely access them, based on the aforementioned checklist.

Recommendation 2: accessible training

The requirements for accessible training are stated in both the general requirements (section 7) and the customer service standards (section 80.49) of the IASR.

In finalizing its recommendation, the committee considered the following issues:

  • both the general requirements and the customer service standards include training requirements, which may lead to confusion for organizations about their obligations around accessible customer service as it relates to training their staff
  • under the IASR, training is not required to be renewed, which may lead staff to forget about their responsibilities
  • lack of accessibility education amongst Kindergarten to Grade 12 (K-12) and postsecondary students can leave them unprepared to support accessible and inclusive workplaces

Feedback from the public consultation included suggestions for enhancing training materials, including developing industry-specific training modules. With respect to increasing the frequency of mandatory accessibility training, organizations raised concerns due to capacity and resource limitations. Respondents also agreed that accessibility training courses be included in K-12 and postsecondary education.

The committee recommends:

  1. Disseminate accessibility considerations and compliance information for businesses at the point of the licensing/registration process (for example, Ministry of Public and Business Service Delivery and Procurement single window for business). For example, create a checklist of accessibility considerations of which new organizations should be aware.
  2. Government to create guidance templates, training modules and resources for employers and businesses that include industry-specific information:
    1. Training modules targeted at the use of service animal accommodation.
    2. Templates that reflect the size of the organization and the requirements applicable to them.
    3. Government to work with umbrella organizations to develop sector-specific training modules and resources.
    4. Templates, training modules and resources to include how attention to accessibility in general and customer service accessibility in particular benefits organizations and businesses.
  3. Training is mandatory for all employees, volunteers and contractors and has to be reviewed, updated and delivered as required, every 2 to 3 years or sooner to keep up with best practices and as regulations/legislation change.
  4. All provincially regulated K-12 schools and postsecondary education institutions should provide a mandatory accessibility course for students.

Recommendation 3: accessibility plans

The requirements for accessibility plans are stated in the general requirements (section 4) of the IASR.

In finalizing its recommendation, the committee considered the following issues:

  • the frequency required to update and revise Multi-Year Accessibility Plans (MYAPs)
  • how to build additional accountability and transparency into accessibility plans
  • the need for guidance and resources to support obligated organizations in developing their MYAPs
  • potential confusion between MYAP requirements and requirements for establishing accessibility policies (section 3)
  • lack of information about accountability measures required to track against MYAP commitments

Feedback from the public consultation was supportive of guidance tools to help organizations develop their MYAPs. Respondents requested further clarity on the types of information to be included in MYAP progress reports.

The committee recommends:

  1. Require updates to the MYAP every 4 years (instead of 5 years).
  2. Large organizations should develop and publish progress reports of measures taken to implement the strategy referenced in the MYAP (for example, show achievements, approved budgets) every 2 years. Organizations with less than 50 employees are exempt.
  3. The organizations’ plans/policies should include how they will respond to feedback, how they will advise the public about notices of service disruptions and how they will respond to requests for accessible formats and communication supports.
  4. The MYAPs should include information on how an organization will measure and track against its MYAP commitments with reference to specific key performance indicators.
  5. Government to promote and improve on existing guidance templates and tools that assist organizations in developing MYAPs.

Recommendation 4: feedback process required

The requirements for providing an accessible public feedback process are stated in the customer service standards (section 80.50) of the IASR.

In finalizing its recommendation, the committee considered the following issues:

  • duplication between this requirement and the feedback requirements under the information and communications standards (section 11 of the IASR)
  • key differences between Ontario’s accessible public feedback requirements and those of other jurisdictions
  • organizational approaches to prioritizing and addressing customer feedback, and using feedback to strengthen revised plans
  • guidance materials to assist organizations in establishing an accessible public feedback process

Feedback from the public consultation called for more accountability from organizations to provide a response, including setting guidance on prioritization based on severity of the complaint. Some respondents recommended adding a follow-up mechanism to feedback processes, allowing submitters to confirm with the organization whether their feedback was addressed, and requiring organizations to consider feedback in their accessibility plans.

The committee recommends:

  1. Government should reorganize the feedback process requirements across the IASR (for example, section 11) under general requirements for its broad application.
  2. Organizations should be required to prioritize a response based on severity (for example, feedback or complaint related to surgery or urgent care).
  3. Organizations should be required to:
    • specify more clarity around their feedback process – timeframe for providing a response and outlining what a member of the public can expect as feedback moves through an organization’s internal process (this needs to be included and described in their policies or plans)
    • provide an overview of how they determine and prioritize feedback based on severity of input
    • better advertise their feedback process, make it known there is one in place and accept feedback through multiple avenues as available (for example, social media messages, emails, phone calls)
    • have an accessible feedback process that considers the needs and intersectionality of their customers (for example, type of disability/digital literacy) and consider the feedback when developing revised plans
  1. Government to develop more tools and guidance to assist organizations in setting up an accessible feedback process and responding to feedback.

Recommendation 5: format of documents

The requirements for the format of documents are stated in the customer service standards (section 80.51) of the IASR.

In finalizing its recommendation, the committee considered the following issues:

  • duplication between this requirement and requirements for accessible formats and communication supports, and accessible websites and web content, under the information and communications standards of the IASR
  • the opportunity to endorse and build upon existing recommendations from the Information and Communications Standards Development Committee
  • the need to build in “timeliness” in meeting requests for accessible formats
  • educational supports, such as training and awareness tools

Public feedback on the initial report noted potential challenges with providing American Sign Language (ASL) and Langue des signes québécoise (LSQ) during emergencies due to limited staff, budget and available qualified ASL/LSQ interpreters. Respondents supported training, resources and tools to help organizations create accessible digital documents.

The committee recommends:

  1. Streamline the requirements for accessible formats across the IASR (for example, from section 12) into one place, that is the general requirements section, to make it clear that section 14 (accessible websites and web content) under the information and communications standards is a baseline for websites and that the public can request alternate formats of anything based on section 12, including information on the website over and above Web Content Accessibility Guidelines (WCAG).
  2. Public sector organizations to proactively provide American Sign Language and Langue des signes québécoise (ASL/LSQ) when delivering emergency-related information.
  3. Further to the Information and Communications Standards Development Committee’s recommendation, public sector organizations and large organizations should have conversion-ready digital formats available to make response to requests faster.
  4. Government, in collaboration with large umbrella organizations, to support small business to comply with the requirement outlined in the recommendation above, by:
    • developing educational supports (videos, guidebooks, training)
    • exploring grant and funding opportunities to assist small business in being compliant
  1. Further to the Information and Communications Standards Development Committee’s recommendation, timelines for provision of formats should be reasonable and agreed upon by both parties and government should publish guidance for reasonable timelines of various types of formats. In addition, the Customer Service Standards Development Committee agrees with the Information and Communications Standards Development Committee’s recommendation that a process/Ombudsman/mediator should be created to resolve minor disagreements under the AODA that do not necessarily rise to the level of a Human Rights complaint.
  2. Organizations to identify in their MYAP, their plans and processes for requesting alternate formats and the expected timelines (aligned with guidance from government where it exists). Their MYAP should report in aggregate requests that were made and responded to.

Recommendation 6: procuring or acquiring goods, services or facilities

The requirements for procuring or acquiring goods, services or facilities are stated in the general requirements (section 5) of the IASR.

In finalizing its recommendation, the committee considered the following issues:

  • in addition to procurement-related requirements spread across the general requirements, there are also procurement requirements in the information and communications standards (sections 15 and 18)
  • recommendations from the past legislative reviewers and standards development committees around accessible procurement
  • the development of federal accessibility standards for procurement and the opportunity for alignment
  • the need to expand procurement-related requirements beyond the Government of Ontario, Legislative Assembly and designated public sector organizations to the private sector to ensure broader accessibility

Feedback from the public consultation called for clear guidance on how accessibility requirements apply to procurement processes.

The committee recommends:

  1. The Ontario government to align all procurement-related recommendations across IASR (particularly in information and communications standards) and in one section under general requirements.
    1. Specific to information communication technology, leverage existing mechanisms (for example, Voluntary Product Accessibility Template (VPAT)) to meet accessibility requirements.
    2. Align with the Information and Communications Standards Development Committee’s recommendation 14 and include VPAT in that list.
  2. The Ministry for Seniors and Accessibility to consider expanding section 5 (1) of the IASR to the private sector with regard to procurement or acquisition of goods, services or facilities.
  3. The Ministry for Seniors and Accessibility to create more definitions, templates, guidelines, checklists, frequently asked questions documents, videos, training modules and other tools to help organizations implement accessible procurement requirements and ensure organizations incorporate Inclusion, Diversity, Equity and Accessibility (IDEA) principles.
  4. The Ontario government to monitor Accessibility Standards Canada (ASC) and the Accessible Procurement Resource Centre (APRC) projects underway to evaluate changes to procurement standards and leverage opportunities to inform procurement standards, emphasizing the importance of Federal-Provincial-Territorial collaboration.
  5. The government should establish a strategy and process to ensure that its funding does not erect new barriers or perpetuate old ones. This monitoring process should cover capital or infrastructure spending, procurement of goods, services or facilities, transfer payments to public sector partners, business development grants or loans and research grants. All organizations, projects and purchases should be screened for compliance and accessibility before funding is approved.
  6. The Ontario government to study the utilization of artificial intelligence and its implications for accessibility standards.
  7. Encourage universal accessibility/design in procurement programs.
  8. Small organizations should consider accessibility in their procurement processes.
  9. Define practicability similarly to section 14 (6) from the information and communications standards and make it clear how it works alongside undue hardship in Ontario’s Human Rights Code. For example:
    1. An organization with significant resources may be required to fund the creation of a new product or service that does not currently exist up to the point of undue hardship.
    2. An organization cannot use cost to avoid procuring a product or service that exists.
  10. Require details of procurement processes within MYAPs and Annual Status Reports.

Recommendation 7: notice of temporary disruptions

The requirements for notice of temporary disruptions are stated in the customer service standards (section 80.48) of the IASR.

In finalizing its recommendation, the committee considered the following issues:

  • the impact of changing technology on how organizations can most effectively communicate temporary disruptions
  • planned versus unplanned disruptions, how they are communicated, the formats in which they are available to the public, and their respective impacts on people with disabilities
  • challenges for verifying compliance with these requirements
  • the need for accessible methods through which the public can contact organizations to seek additional information

Public feedback on the initial report recommended using traditional communication methods, such as hard copy notices on-site, to notify of temporary service disruptions. In terms of organizations providing information based on requests, respondents suggested that the information be provided in multiple formats.

The committee recommends:

  1. Large organizations should keep a record of the various ways notices of disruptions are communicated and include it in their status report every 2 years.
  2. Obligated organizations should publicize their notices of temporary disruptions through all appropriate means and in multiple formats, such as websites, social media, emails, or more traditional methods. All notices should include a means by which the public may obtain additional information (the committee recommends amending Section 80.48 (2) of the IASR).
  3. Organizations to describe in their plan or policy how they will be achieving compliance with current and future requirements related to notices of disruptions.
  4. When organizations receive information requests, the information is to be available in multiple formats and provided in the format that is appropriate to the individual’s disability.
  5. For planned disruptions, organizations should have in place alternative facilities or services prior to the planned disruption and communicate them publicly as far in advance as possible. For unplanned disruptions, organizations should comply with these requirements as soon as possible.
  6. Government, in collaboration with organizations, to develop and/or share across all sectors best practice documents on notices of disruptions.

Recommendation 8: self-service kiosks

The requirements for self-serve kiosks are found in section 6 of the general requirements section of the IASR. Since the IASR was enacted in 2011, self-service kiosks have become a much more significant part of everyday life with emerging technologies such as self-check outs, automated point-of-sale terminals and public transit ticketing terminals, to name a few.

In finalizing its recommendation, the committee considered the following issues:

The committee recommends:

  1. Government to adopt CSA B651.2 Accessible design for self-service interactive devices including automated banking machines into the IASR.
  2. The private sector shall comply with accessibility requirements relating to providing accessible kiosks under section 6 (1). These are to be implemented in the same way as the design of public spaces standards and Building Code changes (that is, on a go-forward basis on major renovations and new builds).
  3. Refer issue to the Design of Public Spaces Standards Development Committee to consider the design and definition of kiosks beyond the issue of counter height, to include the physical environment of the kiosk (for example, gas pumps, ticket machines, room size, space for a wheelchair).

Recommendation 9: the use of service animals

The requirements for the use of service animals are stated in the customer service standards (section 80.47) of the IASR. These requirements were updated and expanded during the first review of the customer service standards in 2016. Since that time, service animals have been a growing area of interest to the public, businesses and people with disabilities.

The topic of service animals and recommendations for how to amend or create clearer IASR requirements related to them was a main topic of discussion for the committee during the second review of the customer service standards.

In finalizing its recommendation, the committee focused on amending the current definition of a service animal under the IASR (included in recommendation 11). The committee also considered the following issues:

  • the continued barriers experienced by people with disabilities when accessing establishments and services with a service animal
  • challenges experienced by organizations in understanding their obligations and when it’s appropriate to ask for proof of documentation
  • competing rights and obligations under the Ontario Human Rights Code as it relates to the duty to accommodate and the right to refusal of a service animal (for example, ride sharing)
  • confusion between requirements for guide dogs under the Blind Persons’ Rights Act, 1990 and service animal requirements under the AODA
  • lack of consistency in the information provided in the documentation written by a regulated health professional
  • stakeholder feedback from other standards development committees’ recommendations (for example, education and health)

This topic also received a substantial amount of feedback through the public consultation. Much of that feedback supported service animal certification, while some respondents flagged concerns that obtaining it is cost prohibitive.

Some feedback also supported adding training requirements for service animals, with multiple respondents raising concerns about animal behaviour and related safety risks for the public and other animals. However, concerns about the potential financial barrier of training costs were also raised. Municipalities raised concerns about distinguishing legitimate service animals from pets falsely presented as such.

Respondents were in favour of government guidelines and training tools about service animals and recommendations were made to include guidance on which types of animals are permitted as a service animal. Most respondents supported a standardized template to be used by regulated health professionals and requested that documentation fees be waived.

The committee recommends:

  1. Government to develop training tools or a toolkit for organizations to train their staff when interacting with people using service animals:
    • These are to include education supports, resources templates, checklists and adaptable resources. Government to work with umbrella organizations when developing these resources.
    • Greater understanding to be provided for why this training is needed, all possible and potential circumstances for why an animal might not be allowed on premises (due to religion, allergies, infection control) or excluded (due to provincial laws or municipal by-laws).
      • Government should partner with stakeholders to create specific educational material for that sector, including stakeholders whose operations prohibit animals on their premises.
    • Create educational resources around the interplay of the AODA with other laws regarding service animals (for example, municipal by-laws), on Ontario’s Human Rights Code guidelines, as well as share best practices.
    • The training should make it clear on how and when staff can ask patrons for the appropriate documentation in order to then provide them with the appropriate supports.

  1. Government to develop a template to be completed by a regulated health professional to document an individual’s need for a service animal (similar to an accessible parking permit). This form is to be accompanied by an information sheet of instructions on signatures, to clarify the purpose of this form.

    The template should include:

    1. Formal letterhead or provincial government logo.
    2. Space for confirmation from the regulated health professional who completes the form, along with their college identification, credentials, if relevant.
    3. Emergency contact for the person and for the service animal.
  1. Work with the healthcare industry, hospitals, paramedics on protocols on how to deal with service animals being transported or received with their incapacitated owners.
  2. This Customer Service Standards Development Committee supports and endorses the Health Care Standards Development Committee’s recommendation that states that there should be no restrictions or barriers for persons with disabilities requiring the accompaniment of a support person or service animal when accessing health care, especially during emergency situations.
  3. Government will work with the 9 regulated health colleges to better understand the code of practice and standards in order to achieve clearer and harmonized understanding for all the regulated health professions, definition and role they have in offering a letter for support for service animals.
  4. Government to add the following sentence in the IASR to empower organizations: “If it is not objectively apparent to a business or organization whether an animal is a service animal (for example, endangering the health of other people or due to its behaviour), the business or organization can ask the handler to provide documentation as required at law.”
  5. Ensure alignment with federal government standards as they are released in order to reduce confusion and work towards a seamless experience across jurisdictions.
  6. Ride share service providers, such as taxi drivers and vehicle-for-hire service drivers, are to inform and provide proof to the businesses for which they work of any limitations to providing rides to service animal owners based on code-protected grounds.
    • Note: this may entail extending requirements to sole proprietors depending on how a ride share company is structured, which should be possible under the application of the AODA’s provision of ‘persons providing goods, service, or facilities.’
  7. Ride share companies must ensure that the process for onboarding drivers requires them to identify in advance any code-protected grounds they would have to not transport one or all types of service animal. They must then ensure trips with those animals are not assigned to those drivers.
  8. Ride share companies must provide the opportunity for individuals who use service animals to identify themselves in advance (for example, as part of signing up or developing a customer profile). Only those drivers protected under the Ontario Human Rights Code should be exempt from having to pick up individuals who use service animals.
  9. Government to conduct a refreshed outreach and education campaign to communicate all changes above if and when they become effective.

Recommendation 10: the use of support persons

The requirements for the use of support persons are stated in the customer service standards (section 80.47) of the IASR. The requirements are intended to ensure that organizations permit a person with a disability who is accompanied by a support person on their premises without adding any additional barriers.

The topic of support persons was another key area of discussion for the committee.

In finalizing its recommendation, the committee considered the following issues:

  • understanding obligations under the Ontario Human Rights Code, particularly as it relates to undue hardship on the part of the organization
  • lack of guidance for organizations on how to work with individuals to determine whether they can be accommodated without the use of a support person and the importance of protecting the agency of individuals to make such determinations
  • consideration of whether organizations should bear the cost (wages and other fees) of the support person if the requirement was determined by the organization
  • the need for organizations to provide more types of sign language up to the point of undue hardship to people requesting the accommodation

Some of the feedback from the public consultation noted that ASL/LSQ interpretation may not be feasible due to a lack of able interpreters.

The committee recommends:

  1. The Ontario government to continue working with the federal government (for example, through the existing Memorandum of Understanding agreement with Accessibility Standards Canada) to support consistent requirements for support persons regardless of jurisdiction.
  2. Upon receipt of a reasonable request, organizations must provide ASL/LSQ/Indigenous Sign Languages interpretation up to the point of undue hardship when other methods of communication do not meet the needs of the person requesting the accommodation. It must be clarified that ASL/LSQ is a “communication support” as defined in the legislation.
  3. A support person accompanying a person with a disability who is accessing provincially owned goods, services or facilities should not be charged an admission fee or fare.
  4. Organizations must make best efforts to explore alternative measures for accommodation before imposing the requirement of a support person and be required to consult with the person with a disability.
  5. An organization may only require a person with a disability to be accompanied by a support person where it is determined that no other reasonable accommodation measures will allow the individual to access the goods, services or facilities provided by the organization. Where that is the case, the organization must pay the fees and wages for the support person to the point of undue hardship.
  6. The Ontario government should partner with the Ontario Human Rights Commission (OHRC) to produce plain language training materials on the procedural duty to accommodate the need for a support person under both the AODA and OHRC and include this as mandatory training under the IASR, with a view to protect the agency of people to determine the need for a support person.

Recommendation 11: purpose, application and definitions; scope and interpretation

The customer service standards became the first accessibility standards in regulation under the AODA in 2008, which predated the creation of IASR in 2011 as a stand-alone regulation. Following the 2016 review of the accessible customer service standards, these requirements, (i.e. including its scope, interpretation and definitions sections) were merged into the IASR. This integration led to some redundancies within the regulation. As a result, the committee dedicated significant time to reviewing these sections for duplication and gaps, with the goal of clarifying requirements. In addition, the committee thoroughly reviewed a variety of additional perspectives and feedback from the public and organizations to inform its proposed changes to definitions. As noted previously, service animals were a main topic of discussion for the committee as members considered how to amend or create clearer IASR requirements related to them.

In finalizing its recommendation, the committee considered the following issues:

  • the need for a definition of customer service in the IASR to ensure it captures not only elements of inclusive program and service design but also inclusive delivery, encouraging organizations to adopt a broader approach to customer service
  • the need to revise the current definition of a service animal in the IASR to clarify the committee’s proposed requirements related to training, visual indicators and documentation requirements
  • the need to maintain a distinction between the definition and requirements of “guide dogs” and “service animals”
  • challenges encountered in the service industry related to the behaviour of animals
  • complexities around ensuring animals are appropriately trained to assist people with disabilities

Public feedback indicated that aligning the name of Ontario’s customer service standards with the related federal standard could cause confusion. In terms of revising the current IASR definition of a service animal, respondents shared concerns that including emotional support animals in the definition could complicate enforcement and also that untrained emotional support animals may pose safety risks to people in public spaces. Many respondents recommended that all service animals and emotional support animals should be trained, certified and have identification, noting that emotional support animals should have the same training and documentation as service animals. 

The committee recommends:

  1. A definition of “customer service” should be added in the IASR, where appropriate (the committee recommends under “Definitions” in section 2 under general requirements) in order to consider inclusive program and service design in addition to delivery, where applicable.
  2. Definitions under customer service standards section 1 (scope and interpretation) are to be moved and merged with definitions under general requirements.

  3. The definition of a service animal under the IASR should be amended to the following:

    A service animal is an animal that:

    1. is not a guide dog and
    2. meets the following:
      1. not otherwise prohibited by law (for example, by-laws); and
      2. individually trained by an organization or person specialized in service animal training to assist a person, with a need related to their disability; and
      3. readily identifiable by visual indicators, such as a vest or harness, as a service animal required for a disability-related service; and
      4. the person requiring the animal for reasons relating to the disability holds documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons relating to the disability:
        1. A member of the College of Audiologists and Speech-Language Pathologists of Ontario.
        2. A member of the College of Chiropractors of Ontario.
        3. A member of the College of Nurses of Ontario.
        4. A member of the College of Occupational Therapists of Ontario.
        5. A member of the College of Optometrists of Ontario.
        6. A member of the College of Physicians and Surgeons of Ontario.
        7. A member of the College of Physiotherapists of Ontario.
        8. A member of the College of Psychologists of Ontario.
        9. A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

    Conclusion

    As required under the AODA, the committee is submitting its final recommendations report. The committee valued the feedback provided through the public and additional consultations and carefully considered it as the recommendations were finalized. The recommendations are intended to provide a path forward to help prevent barriers and make it easier for Ontarians with disabilities to access goods, services and facilities. The submission of this report marks the completion of the committee’s mandate to the Minister for Seniors and Accessibility.

    Committee members

    Voting members:

    • Jeff Adams (Chair), lawyer and disability advocate
    • Doug Earle, West Park Healthcare Centre Foundation
    • Raj Chopra, disability community representative
    • Lois Davies, Association of Municipalities of Ontario
    • Julia Hudson, Canadian Hearing Services (CHS)
    • Tracey McKenzie, Rural Ontario Municipal Association
    • Fatima Finnegan, Ontario Restaurant Hotel & Motel Association
    • Maryann Istiloglu, Ontario Association of Mental Health Professionals
    • Lucille Berlinguette-Saumure, LBSAccessibility Inc.
    • Peter Athanasopoulos, Spinal Cord Injury Ontario
    • Chris O’Brien, OLG
    • Jennifer Cowan, disability community representative
    • Don Halpert, disability community representative
    • Jacqueline Silvera, University Health Network (UHN)
    • Jason Mitschele, Public Prosecution Service of Canada
    • Azhar Karim, DEEN Support Services

    Non-voting members:

    • Amanda McHugh, Ministry of Economic Development, Job Creation and Trade
    • Heather Peters, Ministry of Public and Business Service Delivery and Procurement
    • Glenn Brunetti, Ministry of Public and Business Service Delivery and Procurement
    • Tom Kaszas, Ministry of Red Tape Reduction

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