AODA website compliance for Ontario organizations

Smaller organizations are not required to meet WCAG on their websites. They still have other duties under the AODA, and an accessible website helps them meet those duties and reach more customers.

What the AODA requires for websites

Section 14 of the regulation says designated public sector organizations and large organizations must make their internet websites and web content conform with WCAG 2.0. The rule was phased in over two steps.

Two WCAG success criteria are exempt from the 2021 requirement:

• 1.2.4 Captions (Live)
• 1.2.5 Audio Descriptions (Pre-recorded)

Captions for pre-recorded video (success criterion 1.2.2) are still required.

The regulation defines a “new internet website” as a site with a new domain name, or a site on an existing domain that goes through a significant refresh. That definition mattered for the 2014 step. Since 2021, the Level AA rule applies to all public websites of covered organizations, new or old.

Who must comply

The regulation calls a business or non-profit with 50 or more employees in Ontario a “large organization”. Ontario’s page on accessibility rules for businesses and non-profits sets out the duties by size.

The Government of Ontario and the Legislative Assembly must also meet WCAG 2.0 Level AA, for their intranets as well as their public sites. Designated public sector organizations include every municipality, school board, hospital, college, university that receives operating grants from Ontario, and public transit organization. The full list is in the regulation’s definitions and Schedule 1.

How to count your employees

Ontario’s business rules page says to count:

• full-time employees
• part-time employees
• seasonal employees
• contract workers

Do not count employees outside Ontario, volunteers or independent contractors. This matters for non-profits that rely on volunteers. A non-profit with 30 staff and 200 volunteers has 30 employees for AODA purposes.

Which content is covered

Section 14 applies to:

• public websites and web content, including web-based applications, that you control directly or through a contract that allows you to change the product
• web content published on a website after January 1, 2012

The regulation defines an “internet website” as a collection of related web pages, images, videos or other digital assets under a common address that the public can reach. Internal sites (intranets and extranets) are not covered, except for the Government of Ontario and the Legislative Assembly.

The rule applies “except where meeting the requirement is not practicable”. When deciding what is not practicable, the regulation lets organizations consider whether commercial software or tools are available.

If some information cannot be converted into an accessible form, section 9 says you must give the person who asks for it an explanation of why, plus a summary of the information. Ontario’s website accessibility page gives a complex online map as an example.

Which WCAG version applies

The AODA requires WCAG 2.0 Level AA. The regulation names the WCAG 2.0 recommendation dated December 2008. Some online guides say the AODA requires WCAG 2.1 or 2.2. The regulation text in force in September 2026 does not say that.

WCAG 2.2 is the newest version. The W3C says content that meets WCAG 2.2 also meets 2.0 and 2.1. The one exception is success criterion 4.1.1 Parsing, which 2.2 removed. If you build a new site to WCAG 2.2 Level AA and also check 4.1.1, you meet the AODA standard and the newer one at the same time.

Compliance reports and deadlines

Ontario’s page on completing your accessibility compliance report sets these deadlines:

Businesses and non-profits file through the Accessibility Compliance Reporting Portal. Ontario says an organization that does not file could face enforcement measures, including financial penalties.

Fines and enforcement

The AODA has two kinds of money penalty.

Administrative penalties

A director can order an administrative penalty under section 83 of the regulation. The amount depends on how serious the contravention is and how many contraventions the organization had in the last two reporting cycles.

When both the impact and the history are rated major, the director can treat the penalty as a daily penalty. The maximum is $100,000 for a corporation and $50,000 for an individual or unincorporated organization.

Offences under the Act

Section 37 of the Accessibility for Ontarians with Disabilities Act, 2005 makes it an offence to give false information in an accessibility report or to ignore an order from a director. On conviction, the fine is up to $50,000 a day for a person and up to $100,000 a day for a corporation. Directors and officers of a corporation have a duty to take reasonable care to prevent the offence.

Changes in 2025 and 2026

• The regulation was last amended in March 2026 by O. Reg. 69/26. That amendment changed definitions in the public spaces rules. It did not change the website rule.
• Ontario says on its accessibility laws page that the guidelines for the regulation will be reviewed, and that current standards and reporting deadlines still apply during the review.
• At the federal level, new digital accessibility rules under the Accessible Canada Act were registered on December 17, 2025. They are covered in the next section.

The federal Accessible Canada Act

The Accessible Canada Act applies to organizations under federal responsibility. These include the Government of Canada, Crown corporations and federally regulated private companies in banking, telecommunications, broadcasting, air travel, and rail, road and marine transport between provinces or countries. It does not apply to provincially regulated businesses, which includes most small businesses in Ontario.

Regulated organizations must publish accessibility plans, set up a feedback process and publish progress reports. Penalties can reach $250,000 per violation.

The December 2025 amendments add rules for web pages:

• They apply to the federal public sector and to federally regulated private businesses with 100 or more employees. Businesses with 99 or fewer employees are excluded.
• Web pages must follow CAN/ASC-EN 301 549, a national standard that requires WCAG 2.1 Level AA for web pages.
• Deadlines are December 5, 2027 for the federal public sector and December 5, 2028 for large and medium businesses.

What small businesses under 50 employees should still do

A business with 1 to 49 employees does not have to make its website meet WCAG. It does have these AODA duties, according to Ontario’s rules page:

• Provide information in accessible formats when someone asks, in a timely way and at no extra cost.
• Tell the public that accessible formats are available.
• Make your feedback process accessible.
• Follow the customer service standard and train staff on it.

Your website is a good place to publish that information. Add a short accessibility statement that says how to ask for information in another format and how to give feedback.

There are also good reasons to go further:

• More customers can use your site. Statistics Canada found that 27% of Canadians aged 15 and older had at least one disability in 2022.
• The Ontario Human Rights Code is a separate law from the AODA. The Ontario Human Rights Commission says service providers must accommodate people with disabilities to the point of undue hardship.
• If you grow to 50 employees, the WCAG rule applies to your site from that point. A site built to the standard now will not need a second project later.
• Better contrast and clear labels also help people who use a phone outdoors.

The most common accessibility failures and how to fix them

WebAIM tests the home pages of the top one million websites each year. In its 2026 report, 95.9% of home pages had detectable WCAG failures. These were the six most common:

Checklist for the rest of your site

Automated tools find the failures above. You have to check these by hand.

• You can reach and use every link, menu, button and form with the Tab, Enter and arrow keys alone.
• You can always see where the keyboard focus is.
• There is a “skip to content” link or a similar way to skip the menu.
• Each page has one H1 and headings in a logical order.
• Each page has a unique, clear title.
• Link text makes sense on its own. “Read more” repeated ten times does not.
• Colour is not the only way you show information, such as required fields or errors.
• Text can be enlarged to 200% without breaking the layout.
• Form errors say what went wrong and how to fix it.
• Pre-recorded videos have captions.
• Audio that plays by itself for more than 3 seconds can be paused or stopped.
• Nothing flashes more than 3 times a second.
• Time limits, such as on a booking form, can be turned off or extended.
• PDFs are tagged and readable, or the same content is also on a normal web page.

Free tools to test your website

Automated tools do not find everything. In a 2021 study of about 13,000 pages, Deque found that automated tests caught 57% of the accessibility issues. Ontario’s website accessibility page also recommends testing with assistive technology and with people with disabilities.

A Lighthouse score of 100 does not mean the site meets WCAG. It means the automated checks passed. Use the keyboard checklist above as well.

Why overlay widgets do not make a site compliant

An overlay is a script that adds an accessibility button or toolbar to your site. Some vendors say it makes a site compliant in minutes.

In January 2025, the US Federal Trade Commission ordered accessiBe to pay $1 million. The FTC found that the company’s claims that its AI tool could make any website WCAG compliant were false, misleading or unsubstantiated. The order became final in April 2025.

The AODA requires the website and its content to conform to WCAG. An overlay leaves the missing labels, poor contrast and keyboard traps in your site’s code. Fixing the site itself is the only way to meet the standard.

How to make your website AODA compliant

1. Count your employees in Ontario to confirm whether the WCAG rule applies to you.
2. Test your key pages with WAVE or axe, then with a keyboard.
3. Fix the parts that repeat on every page first, such as the header, menu, footer and forms.
4. Fix page content, such as image alt text, headings, link text and PDFs.
5. Publish an accessibility statement that says how to ask for accessible formats and how to give feedback.
6. Train the people who add content, so new pages and posts stay accessible.
7. Keep a record of what you tested and fixed. Ontario’s website accessibility page suggests this.
8. If you have 20 or more employees, file your compliance report by December 31, 2026.

If your site has many problems, a rebuild can cost less than fixing each page. We check every site we launch for accessibility before handover. If your organization must meet the AODA, tell us at the start so we can plan the work to WCAG 2.0 Level AA. See our web design service, our website redesign service or our prices.

A note on this guide

This guide is general information. It is not legal advice. For advice about your own organization, talk to a lawyer.