AMO advised the Minister of Community and Social Services to consider the impact of the proposed Information and Communications standard on municipal property taxes and local economies.

AMO has consistently expressed support for the principles espoused by the Accessibility for Ontarians with Disabilities Act (AODA) recognizing that Ontario’s municipal sector has led the move toward improved accessibility in the province. However, AMO is concerned that the timelines, the scope and the cost of implementing the proposed standard as drafted will have detrimental impacts on municipal budgets and Ontario’s economic competitiveness. 

According to a KPMG report commissioned by the province, the anticipated cost of implementing the proposed standard, as drafted, for a sample, small municipality would be an increase of from 1% to 3% of its operating budget. Extrapolated province-wide, the implication for municipalities across the province could be an increase in operating costs of between $300,000,000 and $900,000,000 a year. Generating this additional revenue through municipal property taxes alone would require an increase in property tax revenue of 2%-6%. AMO is urging the province to consider all standards in the context of practicality and affordability.

AMO addressed and provided recommendations on the following areas of the draft standard:

Upgrade of business enterprise systems

AMO is recommending that Section 4.0 be removed from the I & C draft standard and considered under the Employment Standard which is currently under development. We are also recommending that given the significant cost impact associated with business enterprise systems, future recommendations for business enterprise system upgrades be carried out on a go forward basis with a compliance date of 2025, allowing new and emerging technology to be adopted through normal replacement cycles.

Accessible formats and methods 

AMO is recommending that a further costing analysis be conducted that is reflective of size and capacity of organizations to comply with the requirements under the proposed standard. Further, that section 5 be revised to state that “upon request” should be interpreted as having capacity under reasonable time-lines to provide alternative formats on an as needed and individualized basis.

Training of all municipal staff in requirements of the standard

AMO is recommending to the province that in the absence of a harmonized approach to the implementation of all standards, the province should undertake to organize and support standardized training for public sector organizations.

Staggered compliance dates across sectors

AMO is recommending that the compliance dates be revised to reflect a reasonable and fiscally sustainable implementation process. In addition, the compliance dates for the application of the Information and Communications standard should be streamlined across all sectors and that, a more realistic timeline for compliance be developed. This should include consideration of a phased approach up until 2025.

Accessible municipal and provincial elections

AMO recommends that if section 7 remains in the standard, the Provincial Government should create a program to fund accessibility enhancements for municipal elections. AMO strongly opposes the inclusion in the standards of requirement for individuals running for municipal election as they cannot be considered to be part an organization that is intended to be covered by the Act.


AMO will continue to work with the government and municipalities to ensure the implementation of the AODA is fiscally responsible and manageable and to ensure the intent and objectives of the Act are achieved by 2025.