If your organization operates in Ontario, website accessibility isn't optional — it's the law. And with the next round of AODA compliance reports due December 31, 2026, now is the time to confirm your website actually meets the standard.
This guide explains who must comply, what the rules require, what's changing federally, and a practical checklist for finding and fixing the most common problems.
Who must comply
Under section 14 of the Integrated Accessibility Standards Regulation (O. Reg. 191/11) under the Accessibility for Ontarians with Disabilities Act (AODA), website rules apply to:
- designated public sector organizations, and
- businesses and non-profits with 50 or more employees in Ontario.
The requirement covers public websites and web content, including web-based applications, that the organization controls directly or through a contractual relationship. That last part matters: if an agency built and hosts your site, you are still the organization responsible for it.
A few limits apply. The rule covers content published after January 1, 2012; private organizations don't have to make internal intranets conform; and there's an exception where meeting a requirement isn't practicable — but you must be able to explain why.
What the standard requires
Since January 1, 2021, covered websites must conform to WCAG 2.0 Level AA, with two exceptions:
- 1.2.4 Captions (Live), and
- 1.2.5 Audio Descriptions (Pre-recorded).
An earlier milestone, January 1, 2014, required new websites — a new domain name, or an existing site "undergoing a significant refresh" — to meet Level A.
The December 31, 2026 compliance report
Ontario requires organizations to report on their accessibility compliance:
- Businesses and non-profits with 20 or more employees file every three years. The next report is due December 31, 2026.
- Designated public sector organizations file every two years (the last deadline was December 31, 2025).
The report asks whether you meet your obligations — including website accessibility. If your site hasn't been audited recently, do it before you sign.
What happens if you don't comply
The AODA allows fines of up to $50,000 per day for individuals and unincorporated organizations, up to $100,000 per day for corporations, and up to $50,000 per day for directors and officers. Enforcement can also include director's orders and administrative penalties.
Federally regulated? New digital rules are coming
The federal Accessible Canada Act covers the Government of Canada, Crown corporations and federally regulated industries such as banking, telecommunications, broadcasting and transportation, with penalties of up to $250,000 per violation.
New regulations registered in December 2025 require conformance, "to the extent feasible", with CAN/ASC-EN 301 549, which incorporates WCAG Level AA:
- federal public sector: web pages by December 5, 2027; mobile apps and documents by December 5, 2028;
- private sector: organizations with 500+ employees, and those with 100–499 employees (web pages only), by December 5, 2028;
- businesses with 99 or fewer employees are exempt.
Why aim for WCAG 2.2
Ontario's legal baseline is still WCAG 2.0, even though a standards committee recommended moving to the latest version in 2020. But the W3C published WCAG 2.2 on October 5, 2023 (it's now also ISO/IEC 40500:2025) and encourages everyone to use the latest version. WCAG 2.2 adds nine success criteria — covering things like focus visibility, target size and accessible authentication — and content that meets 2.2 also meets 2.1 and 2.0.
If you're rebuilding or refreshing your site, target 2.2 AA. You'll satisfy today's law and be ready for tomorrow's.
A practical checklist: the most common failures
Start with the issues auditors find most often:
- Images without text alternatives — every meaningful image needs
alttext; decorative images need an empty one. - Low colour contrast — body text needs at least 4.5:1 against its background (3:1 for large text).
- Keyboard traps and invisible focus — every link, button and form field must be reachable and operable by keyboard, with a clearly visible focus indicator.
- Unlabelled form fields — each input needs a programmatic label, and errors must be described in text, not colour alone.
- Broken heading structure — one H1, then a logical H2/H3 hierarchy screen-reader users can navigate.
- Vague links — "click here" and "read more" say nothing out of context.
- Video without captions — pre-recorded video needs captions.
- Content that breaks when zoomed — pages must stay usable at 200% zoom and reflow on small screens.
- Missing skip link and landmarks — let keyboard users jump past repeated navigation.
- Inaccessible PDFs — tag documents properly, or publish the content as HTML.
- Motion and time limits — respect reduced-motion preferences and let users extend timeouts.
- ARIA misuse — incorrect ARIA can make things worse; use native HTML elements first.
How to test properly
Automated scanners are a good first pass, but they catch only part of the issues. A credible audit combines:
- automated testing across every template;
- manual keyboard testing of key journeys such as navigation, forms and checkout;
- screen-reader testing with tools like NVDA or VoiceOver;
- content review for alternative text, link text, headings and error messages.
Then prioritize fixes by impact on real users — starting with anything that blocks a task completely.
Sources
- Government of Ontario — How to make websites accessible and Completing your accessibility compliance report
- O. Reg. 191/11, section 14 (Integrated Accessibility Standards)
- AODA, 2005 — offences and fines
- Government of Canada — Accessible Canada Act summary and SOR/2025-255
- W3C — WCAG overview
