Introduction
As January 1 2026 approaches many construction companies across Ontario are trying to understand what the province’s new AED requirements actually mean for their worksites. The volume of partial information circulating online has led to confusion particularly around compliance timelines, funding expectations and operational responsibility.
What is certain is that a new regulation under Ontario’s Occupational Health and Safety Act will soon require AEDs on specific construction projects. What remains uncertain is how those devices must be managed, trained for and maintained once they arrive on site.
Understanding this distinction is critical. Regulation 157 25 is not simply about purchasing equipment. It introduces a new layer of responsibility that construction employers must be prepared to manage thoughtfully and carefully.
What Regulation 157 25 Requires
Beginning January 1 2026 Regulation 157 25 under the Occupational Health and Safety Act will require that certain construction projects in Ontario have an automated external defibrillator available on site.
The requirement applies to construction projects that have twenty or more workers and that are expected to last three months or longer. These thresholds are fixed within the regulation and are not optional. If a project meets both criteria an AED must be present.
At this stage the regulation clearly establishes the requirement for the device itself. It does not yet provide detailed direction on how that device must be stored, maintained or integrated into existing emergency response programs.
Clearing Up Confusion About Bill 30 and Reimbursement
One of the most common misunderstandings surrounding the new AED requirement is the assumption that purchasing a device will automatically qualify a business for reimbursement.
This assumption is incorrect.
Bill 30 which references AED reimbursement is separate from Regulation 157 25. At the time of writing there is no active reimbursement program, no confirmed WSIB process and no published criteria outlining eligibility limits or conditions.
This means that businesses should not make purchasing decisions based on the expectation of funding. There is also no guarantee that early purchases, bulk purchases or specific models will qualify once a program is announced.
Until formal guidance is released any claims about guaranteed reimbursement would be speculative.
The Operational Details That Still Need Clarity
While the device requirement itself is established many practical questions remain unanswered. These unanswered questions are where employers face the greatest risk if they treat AED compliance as a simple equipment purchase.
On multi employer construction sites responsibility is not yet clearly defined. It is still unclear who will ultimately be accountable for providing, maintaining and overseeing the AED when multiple contractors are present. Without clear internal agreements this can create confusion during inspections or emergencies.
Workplace safety policies will also need to evolve. Most construction safety programs do not currently include AED procedures. Employers will need to determine how AED use fits within emergency response plans, who is authorized to manage the program and how responsibilities are documented.
Environmental conditions present another challenge. Canadian construction sites often operate in sub zero temperatures. AEDs are sensitive electronic devices and freezing conditions can compromise their functionality. Employers will need to think carefully about storage accessibility and protection even before formal rules are published.
Maintenance expectations are also still emerging. AEDs require regular checks, battery monitoring and pad replacement. While the regulation does not yet specify inspection intervals or documentation requirements the expectation of readiness will remain.
Training is perhaps the most critical component. Although Regulation 157 25 requires AED availability it does not yet specify how many workers must be trained or what level of training is required. Despite this lack of specificity employers should expect that training competency will be a key focus during enforcement.
Why Compliance Alone Is Not Enough
Many companies are approaching Regulation 157 25 with a compliance only mindset. The focus is on having an AED on site by the deadline.
This approach carries risk.
An AED is not a passive safety sign or a piece of personal protective equipment. It is a medical device intended to be used in a life threatening emergency. Once it is present on site there is an expectation that it can be accessed quickly and used correctly.
Readiness involves more than ownership. It includes training, clear procedures, routine checks and defined responsibility. Without these elements the presence of an AED may provide a false sense of security rather than meaningful protection.
Preparing Responsibly Before 2026
Even with unanswered questions there are practical steps construction companies can take now. Reviewing project timelines, workforce size and site conditions will help determine where the regulation will apply. Integrating AEDs into existing emergency response planning ensures they are treated as part of a system rather than a standalone device.
Establishing internal ownership for AED oversight is equally important. Someone must be responsible for training coordination, maintenance planning and policy updates. Taking these steps early reduces uncertainty and avoids rushed decisions as the enforcement date approaches.
How First Aid Canada Supports Canadian Worksites
First Aid Canada helps employers navigate AED readiness with a practical and compliant approach. This includes supporting appropriate device selection training planning policy development and long term maintenance considerations.
The goal is not simply to meet a regulatory requirement but to ensure worksites are genuinely prepared to respond when an emergency occurs.
Conclusion
Ontario’s new AED requirements under Regulation 157 25 represent an important shift in construction site safety. While the regulation mandates the presence of a device the responsibility that comes with that device should not be underestimated.
This is not just about compliance. It is about readiness, accountability and preparation.
Construction companies that take a thoughtful approach now will be better positioned to meet expectations with confidence when January 1 2026 arrives.
If your team needs clarity or guidance on preparing for Ontario’s AED requirements First Aid Canada is here to help. Reach out to speak with a knowledgeable partner who understands Canadian worksites and compliance responsibilities.