This study focused on the attainment of Theory of Mind (ToM) in children (aged 6 to 13) with complex communication needs who used augmentative and alternative communication (AAC). The AAC group (n = 14) was matched to a younger group, without disabilities, vis-a-vis nonverbal mental age. A second comparison group consisting of children with mild intellectual disabilities and matched nonverbal mental age and chronological age was also included. A test battery that included tests of cognitive and language development and tests of first- and second-order ToM understanding and understanding of more advanced ToM was used. Nonverbal intelligence proved to be a good indicator of ToM ability. Contrary to previous research, the AAC group did not differ significantly from the comparison groups on the test results. The results are discussed in terms of the necessary cognitive capacity underpinning ToM development. (Contains 5 tables.)