A Doctor’s Note for Workplace Accommodations
Workplace accommodations are essential for building inclusive workplaces and helping employees with disabilities succeed. In Ontario, employers have a legal duty to accommodate employees with disabilities under the Ontario Human Rights Code, up to the point of undue hardship.
A key part of this process often involves providing medical information, but recent changes to Ontario’s employment laws mean that the way doctors’ notes are requested and used is evolving.
This article explains the updated rules around medical notes in Ontario, when employers can (and cannot) request them, and how they support the accommodation process under Ontario law.
Understanding Workplace Accommodation and Disability in Ontario
The Ontario Human Rights Code prohibits discrimination based on disability. It also places a positive duty on employers to accommodate employees so they can participate fully in the workplace.
Workplace accommodation might involve:
- Modifying job duties
- Adjusting schedules or work hours
- Providing assistive devices or remote work options
- Offering leaves of absence or gradual return-to-work plans
The Code defines “disability” broadly. It includes physical, mental, developmental, and learning disabilities, as well as chronic conditions and temporary injuries that limit an employee’s ability to perform their job.
Failing to accommodate an employee appropriately can result in human rights complaints, constructive dismissal claims, or orders for compensation from the Human Rights Tribunal of Ontario (HRTO).
As Christopher Achkar, employment lawyer and founder of Achkar Law, explains:
“Whether you’re an employee seeking fair accommodations or an employer fulfilling your duty to accommodate, understanding what a doctor’s note requires under Ontario law is critical.
At Achkar Law, we help both parties ensure compliance and clarity before small issues become major disputes.”
The Evolving Role of Doctor’s Notes in Ontario
Doctor’s notes have traditionally been part of the accommodation process, but recent legal updates, including changes introduced under the Working for Workers Acts (2021–2023), have placed clearer limits on when and how they can be requested.
Key points under current Ontario law:
- Employers can request medical documentation that is reasonable and necessary to support an accommodation request.
- They cannot demand a diagnosis or unrelated medical details.
- Requests must be proportionate if the accommodation need is obvious, a note may not be required.
- Employers should generally seek functional limitations (what tasks an employee can or cannot do) rather than detailed medical records.
📌 2025–2026 update: Ontario continues to emphasize that requests for medical documentation must be justified and not create unnecessary barriers for employees. Employers are encouraged to rely on functional abilities information over detailed medical history, and to avoid routine doctor’s note demands for short-term illnesses or minor accommodation needs.
Benefits of Medical Documentation in the Accommodation Process
For both employers and employees, a properly drafted doctor’s note or functional abilities form can provide critical clarity:
- For employees: It validates the need for accommodation and helps ensure their rights are respected.
- For employers: It offers objective information about the employee’s abilities and limitations, helping them design effective accommodations while meeting their legal duty.
This documentation is particularly important when a disability is not visible or when the accommodation required is complex.
Best Practices for Employers: Requesting and Handling Medical Information
Employers should approach medical documentation with caution and care.
Here’s how to stay compliant:
- Limit information requests – Ask only for details necessary to understand restrictions and needed accommodations.
- Avoid diagnosis requests – Focus on the employee’s functional abilities, expected duration of limitations, and whether duties need modification.
- Engage in an interactive process – Accommodation is a shared responsibility. Employers should discuss possible options with the employee and adjust as circumstances change.
- Protect privacy – Medical information must be stored securely and shared only with those directly involved in the accommodation process.
- Review accommodations regularly – Needs can evolve. Periodically reassessing accommodations helps ensure ongoing compliance.
If clarification is needed, employers can request additional documentation, but they must justify why it’s necessary and ensure the request is proportionate to the situation.
When Employers Go Too Far
Overly aggressive requests for medical details or repeated demands for doctor’s notes can cross the line into discrimination or constructive dismissal.
Examples include:
- Requiring a diagnosis when functional information would suffice
- Refusing accommodation until highly specific medical records are provided
- Disciplining or terminating an employee for not providing unnecessary details
Such actions can expose employers to significant liability before the HRTO or in wrongful dismissal claims.
Why Medical Documentation Still Matters
While Ontario is moving toward limiting unnecessary requests for medical information, doctor’s notes remain an important tool for ensuring proper accommodation.
- For employers, they help manage health and safety obligations and minimize legal risk.
- For employees, they support fair treatment and protect their rights.
Employers who fail to accommodate to the point of undue hardship or who mishandle the accommodation process may face legal consequences, including financial damages, reinstatement orders, or human rights penalties.
How a Human Rights Lawyer Can Help
Whether you’re an employer managing accommodation requests or an employee struggling to have your needs met, legal advice can make a significant difference.
A human rights lawyer can:
- Review and advise on medical documentation policies
- Assess whether a request for a doctor’s note is reasonable
- Assist with accommodation negotiations and dispute resolution
- Represent you before the Human Rights Tribunal of Ontario
In Summary
Doctor’s notes and functional ability information remain a critical part of workplace accommodation in Ontario, but the rules around requesting them are changing.
Employers must ensure that requests are reasonable, limited, and necessary, while employees should understand their right to accommodation without invasive disclosure.
Staying compliant with the Ontario Human Rights Code and evolving best practices isn’t just about avoiding liability, it’s about creating a workplace where everyone can succeed.
Need Help with Workplace Accommodations in Ontario?
At Achkar Law, we help employees secure the accommodations they’re entitled to and guide employers in meeting their legal obligations under the Ontario Human Rights Code.
Whether you’re unsure how much medical information to share, dealing with an unreasonable request, or managing a complex accommodation process, we’re here to help.
Contact us today for a confidential consultation and practical guidance tailored to your situation.
The article in this client update provides general information and should not be relied on as legal advice or opinion. This publication is copyrighted by Achkar Law Professional Corporation and may not be photocopied or reproduced in any form, in whole or in part, without the express permission of Achkar Law Professional Corporation. ©