AODA Website Requirements: What Ontario Organizations Must Do

Short answer: if your business or non-profit has 50 or more employees in Ontario, or you are a designated public sector organization such as a municipality, school board, hospital, college or university, Ontario law requires your public website and its web content to conform to WCAG 2.0 Level AA. That has applied in full since January 1, 2021. Two success criteria are exempt: live captions and audio description for pre-recorded video.

Smaller organizations are not covered by the website section, but they still have accessibility duties under the same regulation. And if you have 20 or more employees, 2026 is a filing year: your accessibility compliance report is due by December 31, 2026. This guide covers what the rules say, what they mean for a real website, and a checklist you can work through.

What is the AODA?

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) is the Ontario law that sets accessibility standards for organizations operating in the province. Its stated purpose was to achieve accessibility for Ontarians with disabilities on or before January 1, 2025. That date has passed, but the obligations did not expire with it. The standards remain in force.

The detailed rules, often called the AODA standards, live in the Integrated Accessibility Standards Regulation (O. Reg. 191/11). It covers five areas: information and communications, employment, transportation, design of public spaces, and customer service. Website rules sit in the information and communications standard, in section 14.

Who must comply with the AODA website rules

Section 14 applies to three groups:

• Large organizations: any organization with 50 or more employees in Ontario, other than the government or a designated public sector organization. This includes private businesses and non-profits.
• Designated public sector organizations: every municipality, plus bodies listed in the regulation, including district school boards, public hospitals, colleges, publicly funded universities and public transportation organizations.
• The Government of Ontario and the Legislative Assembly, which have a stricter schedule that also covers intranets.

Note that the threshold is employees in Ontario. A national company with a small Ontario office counts only its Ontario staff when deciding whether it is a large organization under this regulation.

Small organizations (1 to 49 employees)

If you have fewer than 50 employees in Ontario, section 14 does not require your website to meet WCAG. You are still an obligated organization, though. You must make your feedback processes accessible on request, provide accessible formats and communication supports on request at no extra cost, and tell the public that these are available. A short accessibility statement on your website with a contact method covers the notice part. In practice, a site built to WCAG AA makes the rest much easier.

What the law actually requires: WCAG 2.0 Level AA

WCAG (Web Content Accessibility Guidelines) is the international standard published by the W3C. Its success criteria are graded A, AA and AAA. Ontario's regulation points to WCAG 2.0, published in December 2008. For large organizations and designated public sector organizations, the schedule was:

• By January 1, 2014: new internet websites and web content on those sites had to meet WCAG 2.0 Level A.
• By January 1, 2021: all internet websites and web content had to meet WCAG 2.0 Level AA.

Two Level AA success criteria are exempt for these organizations:

• 1.2.4 Captions (Live): you do not have to caption live-streamed video.
• 1.2.5 Audio Description (Pre-recorded): you do not have to add audio description to recorded video.

Everything else at Level A and AA applies, including captions for pre-recorded video (1.2.2). The exemption covers live captions only.

What “new or significantly refreshed” means

The regulation defines a new internet website as one with a new domain name, or an existing domain undergoing a significant refresh. It does not define “significant refresh.” A redesign, a move to a new platform or a rebuilt navigation is a reasonable reading. Since 2021 this distinction matters less, because all public websites of covered organizations must now meet Level AA. It still matters when you plan a redesign: if you are rebuilding anyway, there is no good reason to launch something that fails.

Content published after January 1, 2012

The rules apply to web content published on a website after January 1, 2012. Older material, such as an archive of PDFs from 2009, is not caught by the requirement. If you edit or republish older content, the safer course is to treat it as new and make it accessible.

What counts as your website

Section 14 covers websites and web content, including web-based applications, that you control directly or through a contract that allows you to modify the product. Your booking widget, online store or member portal is included if you or your vendor can change it. There is a narrow exception where meeting a requirement is “not practicable,” for example when no accessible commercial software exists. It is not a general escape hatch, and you should document your reasoning if you rely on it.

Accessibility compliance reports

Filing a compliance report is a separate legal obligation from making your site accessible. According to Ontario's guidance:

• Businesses and non-profits with 20 or more employees must file an accessibility compliance report every three years. The current deadline is December 31, 2026.
• Designated public sector organizations file every two years. Their most recent deadline was December 31, 2025.
• Reports are submitted online through the Accessibility Compliance Reporting Portal.

The report asks you to confirm whether you are meeting your obligations, including the website requirement if you have 50 or more employees. Do not tick “yes” on a site you have not tested. A false or careless report is a bigger problem than an honest gap with a plan to fix it.

Penalties for non-compliance

The AODA provides two kinds of penalties:

• Administrative penalties under the regulation, set by the severity of the contravention and your history. For corporations they range from $500 to $15,000; for individuals and unincorporated organizations, from $200 to $2,000. Where both impact and history are major, a director can treat the penalty as a daily penalty, up to $100,000 for a corporation and $50,000 for an individual or unincorporated organization.
• Offences under section 37 of the Act: on conviction, up to $50,000 for each day an offence continues, or up to $100,000 per day for a corporation. Directors and officers of a corporation also have a duty to take reasonable care to prevent the corporation from committing an offence.

Beyond the penalties, an inaccessible site shuts out customers, and a compliance report that misstates your status is a risk you do not need to take.

Federally regulated? The Accessible Canada Act

If your organization is federally regulated, such as a bank, telecom company, broadcaster or airline, the federal Accessible Canada Act also applies. It requires the Government of Canada and federally regulated private sector organizations, generally those with an average of 10 or more employees, to publish accessibility plans, set up a feedback process and publish regular progress reports. Information and communication technologies are one of its priority areas, which includes your website. The maximum penalty for a violation is $250,000. How the federal and provincial regimes interact for a given organization is a question for your lawyer.

Why WCAG 2.1 or 2.2 AA is the sensible build target

Ontario's rule still references WCAG 2.0, but no one building a site in 2026 should stop there. WCAG 2.1 (2018) and WCAG 2.2 (2023) add criteria rather than replacing old ones, so a site that meets 2.2 AA also satisfies the 2.0 AA requirement. The newer criteria deal with problems that matter on modern sites:

• Content that reflows on a phone without horizontal scrolling.
• Visible keyboard focus that is not hidden behind sticky headers or cookie banners.
• Touch targets large enough to tap accurately.
• Text spacing and contrast for non-text elements such as form borders and icons.
• Accessible authentication that does not depend on memory puzzles.

Building to the current version once is cheaper than retrofitting later, and newer accessibility standards and procurement requirements increasingly reference WCAG 2.1 or 2.2. When we handle accessibility compliance work, WCAG 2.2 AA is the target.

AODA website compliance checklist

Use this as a working checklist. It is not exhaustive, but it covers the failures we see most often on Ontario business sites:

• Every meaningful image has useful alt text; decorative images have empty alt text.
• The whole site works with a keyboard alone, with a visible focus indicator and no keyboard traps.
• Text contrast is at least 4.5:1 (3:1 for large text); buttons and form borders are distinguishable.
• Headings follow a logical order and pages have unique, descriptive titles.
• Every form field has a visible label, and errors are announced in text, not by colour alone.
• Links make sense out of context; no lists of “click here.”
• Pre-recorded video has accurate captions; audio-only content has a transcript.
• Nothing flashes more than three times a second, and auto-playing carousels or video can be paused.
• The page language is set, and the site zooms to 200% without loss of content.
• PDFs and other documents published after 2012 are accessible, or offered in an accessible alternative.
• Third-party tools you control by contract (booking, chat, e-commerce) have been tested too.
• An accessibility statement tells visitors how to request accessible formats and give feedback.
• Your compliance report is filed by December 31, 2026 if you have 20 or more employees.

How to test your site

Automated checkers are a useful start but catch only part of the problem. They can find missing alt text and low contrast; they cannot tell you whether alt text is accurate or whether a menu makes sense to a screen reader user. Start with our free website check to spot the obvious issues, then follow up with manual keyboard and screen reader testing. If the site has deeper structural problems, a website redesign built accessible from the start is often cheaper than patching an old theme.

This isn't legal advice

This guide explains the rules as written in Ontario's legislation and government guidance as of October 2026. It is not legal advice. For questions about how the AODA or the Accessible Canada Act applies to your organization, talk to a lawyer. For the website side, testing, fixing and building accessible sites, get in touch and I'll take a look.