Multi-Year Accessibility Plans Under AODA: What Ontario Businesses Must Include

A multi-year accessibility plan is one of the more substantive documents Ontario's accessibility law asks certain organizations to produce — not a one-page policy, but a forward-looking strategy for identifying and removing barriers over time. If your organization falls into scope, a generic template copied from another business generally will not hold up as a genuine plan.

Here's what the AODA multi-year accessibility plan requirement generally involves, and how to approach building one properly.

What a Multi-Year Accessibility Plan Is

Under Ontario's accessibility framework, organizations that meet the applicable size and sector criteria are generally expected to establish, implement, and maintain a multi-year accessibility plan — a document outlining the organization's strategy for identifying, removing, and preventing barriers for people with disabilities.

It's meant to be a living planning document, not a one-time compliance exercise you file away.

What It Must Generally Include

A multi-year accessibility plan is typically expected to address, at a general level:

• Past and planned actions the organization has taken or intends to take to identify and remove barriers.
• How barriers are identified, including within policies, practices, and procedures.
• Steps taken across the applicable AODA standards relevant to that organization — for example, customer service, information and communications, and employment.
• A timeline or framework for future action, not just a static list of past accomplishments.

Because the specific content requirements are set out in regulation and can be updated, treat this as a general outline of the kind of content expected — confirm the current requirements before finalizing your plan.

Who Generally Has to Have One

As with other parts of AODA, this obligation is generally tiered by organization size and sector, with public-sector bodies and larger private-sector or non-profit organizations more likely to be required to have a formal multi-year plan, while smaller organizations may have a lighter obligation. Confirm your organization's current classification before assuming either way.

Reviewing and Updating Your Plan

A multi-year accessibility plan isn't meant to be written once and forgotten. Organizations subject to the requirement are generally expected to review and update their plan periodically, on a schedule set out in the applicable regulation, and to track their progress against it in between.

A plan that hasn't been touched in years, or that no longer reflects what the organization is actually doing, defeats the purpose of the exercise even if the original document technically still exists.

Posting and Communicating Your Plan

Organizations required to have a multi-year accessibility plan are generally expected to make it available to the public, often by posting it on their website, and to provide it in an accessible format on request. This ties the plan back to the same accessibility standards it's meant to help the organization meet.

If your organization is also subject to the website accessibility requirements discussed elsewhere in AODA, the document containing your plan should itself meet that same accessibility standard — an inaccessible accessibility plan undermines the point of publishing it at all.

A Practical Process for Building Your Plan

1. Confirm whether your organization is required to have a formal multi-year plan under the current rules.
2. Review what accessibility steps you've already taken across each applicable standard.
3. Identify realistic barriers you haven't yet addressed, and set a genuine timeline for tackling them.
4. Draft the plan in plain language, and have it reviewed internally before publishing it.
5. Post it in an accessible format, and calendar a review date rather than letting it go stale.

Frequently asked questions