Guide · Last reviewed October 7, 2026
How to count employees for AODA reporting.
The direct answer: count everyone who works for you in Ontario — full-time, part-time, seasonal, and contract workers — at your peak headcount over the previous 12 months. Don't count volunteers, genuine independent contractors, or staff outside Ontario. Hit 20 at your peak and you file.
Who counts, who doesn't
Count these
- Full-time employees in Ontario
- Part-time employees in Ontario
- Seasonal employees in Ontario
- Contract workers in Ontario (where you control the work)
Don't count these
- Volunteers (including volunteer board members)
- Genuine independent contractors
- Employees outside Ontario
The tricky one is contractors vs. independent contractors. Ontario's guidance looks at whether you pay wages or salary, control the work assigned, and control how the work is done. If you're unsure about someone's status, that's exactly the kind of question to ask us about — or raise with your lawyer.
The peak-12-month rule
The threshold isn't your headcount today — it's the highest number at any one time during the previous 12 months. A retailer that hits 24 staff over the holidays but runs at 16 the rest of the year still counts as 24. Seasonal spikes count.
What changes at 20 — and at 50
| Ontario headcount (peak, 12 mo.) | File a report? | What the report covers |
|---|---|---|
| Fewer than 20 | No | No filing — but accessibility requirements still apply to you. |
| 20–49 | Yes | A shorter report: your accessible customer-service standards. |
| 50 or more | Yes | The full report: documented policies, multi-year accessibility plan, training records, employment practices, and more. |
At 50+, the underlying obligations also expand — documented (not just informal) policies, a written multi-year plan posted publicly and reviewed at least every five years, written training records, and documented accommodation processes. That's why the 50+ report asks about more.
Common counting mistakes
- "We only have 14 full-timers." — plus 6 part-timers and 2 seasonal staff = 22. You file.
- "Our contractors don't count." — contract workers you direct and pay generally do. True independent contractors don't.
- "We have 30 staff across Canada." — only the Ontario ones count. 18 in Ontario = no filing, even if the company is bigger nationally.
- "We dropped to 17 this year." — peak over the previous 12 months is what matters, not today's number.
Sources
- Guide to accessibility compliance for industry — Ontario.ca (counting rules)
- Accessibility rules for businesses and non-profits — Ontario.ca
- Integrated Accessibility Standards Regulation (O. Reg. 191/11) — ss.2, 86.1 (definitions, filing bands)
Regulatory information is current as of the review date above. Legislation prevails over any summary — this guide is not legal advice.
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