AODA employee count: 1–19, 20–49 and 50-plus employers

Start with the correct organization and Ontario workforce

Ontario’s industry guide describes the count as the organization’s peak number of employees at any one time during the preceding twelve months. Count Ontario full-time, part-time and seasonal employees, and employees working on employment contracts. Employees outside Ontario are not included in this Ontario count.

Do not automatically count every supplier as an employee. An employee on a contract and an independent contractor are not the same thing. If the relationship is uncertain, leave the headcount unconfirmed and obtain appropriate advice rather than using a convenient label.

A simple counting example

At its highest simultaneous count, a fictional organization has 12 full-time and 10 part-time Ontario employees. Its count is 22, not a smaller number calculated from their weekly hours. That meets the ordinary business/non-profit reporting threshold.

For a multi-location organization, identify the simultaneous organization-wide Ontario count. Do not add one store’s summer maximum to another store’s December maximum unless those employees were employed at the same time. Similarly, a current count below 20 does not settle whether the relevant peak crossed a threshold.

What changes at 20 and at 50

For an ordinary covered business or non-profit, 1–19 employees means no routine accessibility compliance report, but applicable accessibility requirements continue. At 20–49, the 2026 reporting requirement applies.

At 50 or more Ontario employees, additional large-organization requirements apply, including written policies and a multi-year plan. Certain training records, documented employment processes and public-website requirements also need review. These are not a claim that every possible duty applies to every organization.

How to use the tool when the number is uncertain

Enter the best known peak count, but do not select the confirmation box until the underlying organization and worker classification have been checked. The tool keeps that uncertainty in the result instead of presenting the number as an established fact.

Public-sector and federal coverage cannot be resolved solely by employee count. Use the separate coverage route where relevant. If the organization has changed size or status, check Ontario’s reporting guidance about updating its profile and seek help for any unclear transition.

Official sources and scope

• Ontario: counting employees
• Ontario: reporting thresholds and organization updates
• Ontario: policies and plans by size

General information, not legal advice or a compliance certificate. Check coverage, governing requirements and actual implementation. A report-preparation pack is not an official filing. Individual circumstances and specialist standards may require qualified advice.