As noted in our October 2012
Blakes Bulletin on the Accessibility for Ontarians
with Disabilities Act, 2005 (AODA), the Ministry of Community
and Social Services (MCSS) required most companies and
organizations to file compliance reports in relation to the
Accessibility Standards for Customer Service (the Customer Service
Standard) on or before December 31, 2012.
As most companies and organizations have completed the
implementation of the Customer Service Standard, they must now turn
to implementing the Integrated Accessibility Standards (the
Integrated Standards) within the various compliance deadlines. The
Integrated Standards include standards relating to employment,
information and communications, and transportation, along with
standards with respect to the design of public spaces and the built
environment, which were recently finalized. The Integrated
Standards also contain certain general obligations regarding
accessibility policies and plans and further employee training.
Since our October 2012 AODA Blakes Bulletin, MCSS has
published on its website various policies and implementation
resources relating to the Integrated Standards. Companies and
organizations can also use the "AODA Compliance Wizard"
on the MCSS website to obtain a snapshot of their specific
Integrated Standards obligations. The AODA Compliance Wizard can be
accessed here.
Set out below is a summary of the key upcoming compliance
requirements and deadlines for most "large
organizations", being those
private-sector companies and organizations with 50 or more
employees in Ontario. Private-sector companies and organizations
with less than 50 employees in Ontario often have more time to come
into compliance with the Integrated Standards or, in some cases,
have less stringent obligations.
Accessibility Policies/Multi-Year Accessibility
Plan. By January 1, 2014, large organizations must have
developed and implemented accessibility policies and a multi-year
accessibility plan describing how the organization will achieve
accessibility and compliance with the Integrated Standards. The
document must include a statement of commitment, and be posted on
the organization's website.
Self-Service Kiosks. By January 1, 2014, large
organizations must have regard to accessibility issues when
designing, procuring or acquiring self-service kiosks.
Training. By January 1, 2015, all employees and
others providing services on behalf of a large organization must
receive training on the Human Rights Code as it pertains
to persons with disabilities and the Integrated Standards.
Feedback. By January 1, 2015, large
organizations must ensure that their feedback processes can be
administered in accessible formats and with communication supports,
upon request.
Accessible Format and Communication Supports.
By January 1, 2016, large organizations must provide information
and communications in accessible formats and with communication
supports to individuals with disabilities (in a timely manner and
at a cost equal to the regular cost charged to others), upon
request.
Accessible Websites. By January 1, 2014, large
organizations' Internet websites must generally meet the
specifications of WCAG 2.0 Level A, but only if the website was
created or underwent a significant refresh after January 1, 2012.
By January 1, 2021, all Internet websites must meet the
specifications of WCAG 2.0 Level AA (with certain limited
exceptions).
Employment. By January 1, 2016, companies must
come into compliance with the AODA employment standards, which will
involve various document and process changes relating to, for
example, recruitment, accommodation and return-to-work processes.
For further information on the employment standards, see our June
2011
Blakes Bulletin: AODA – New Employment Standards for
Access.
Companies and organizations should consider accessibility issues
in respect of all areas covered by the Integrated Standards well in
advance in order to ensure compliance is achieved by the various
deadlines.
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