Ontario HR Compliance · Accessible Canada Act
Accessible Canada Act: Employer-Size Thresholds and Deadlines
First-plan deadlines under the Accessible Canada Act were phased by employer size — June 1, 2023 for 100 or more employees and June 1, 2024 for 10 to 99 — and organizations with 9 or fewer employees have no plan or reporting obligation at all.
The Accessible Canada Act phased in its first-plan deadline by organization size, based on 2021 average employee counts:
- Federal government, Crown corporations, the RCMP, and the Canadian Armed Forces: first plan due December 31, 2022.
- Large private-sector organizations (100 or more employees): first plan due June 1, 2023.
- Small private-sector organizations (10 to 99 employees): first plan due June 1, 2024.
Organizations with 9 or fewer employees do not have to publish a plan, a progress report, or a feedback-process description at all. First Nations band councils are exempt until December 31, 2033.
For a federally regulated private employer in the 20-to-200 range, that means the first plan was already due — June 1, 2024 for the 10-to-99 band, or June 1, 2023 for 100 or more — with progress reports following on the plan’s anniversaries. See Accessible Canada Act: Applicability and the Planning/Reporting Cycle for what each stage of that cycle requires.
Digital and ICT conformity requirements are still being phased in under a separate technical standard, with deadlines extending into 2027 and 2028 for federally regulated employers. Treat the exact digital-conformity obligations as unsettled and confirm them at the source rather than the planning/reporting deadlines above, which are fixed. Enforcement runs through administrative monetary penalties ranging from $250 to $75,000 depending on severity.
This is general information, not legal advice; confirm current deadlines and thresholds at the source before relying on them.
Source: Government of Canada — Accessible Canada Regulations: Summary of the Act ·
Also: Government of Canada — Accessible Canada Regulations guidance: progress reports
Last reviewed .
Confidence: Verified
Related notes
- Accessible Canada Act: Applicability and the Planning/Reporting Cycle — The Accessible Canada Act governs accessibility for federally regulated organizations in place of Ontario's AODA, and runs on a repeating 3-year cycle of an accessibility plan, two progress reports, and an updated plan.
- Employment Equity Act: The 100-Employee Threshold and Annual Report — Federally regulated private-sector employers and Crown corporations with 100 or more employees must analyze their workforce against four designated groups, maintain an employment equity plan, and file an annual report by June 1 — an obligation that doesn't apply at all below 100 employees.
- Federal Pay Equity Act: Applicability and the 10-Employee Threshold — The federal Pay Equity Act applies to all federally regulated employers, public and private, with 10 or more employees, and requires them to proactively identify and close gender-based pay gaps rather than wait for a complaint — a different statute from Ontario's Pay Equity Act, with different mechanics.
- Administrative Monetary Penalties (Part IV): Framework and Baseline Schedule — Part IV of the Canada Labour Code sets administrative monetary penalties for designated violations, classified Type A through Type E and scaled by employer size, with a repeat-violation multiplier and a $250,000 statutory cap per penalty.