If your organization is in Ontario's public sector, or is a business or non-profit with 50 or more employees in Ontario, your public website must meet WCAG 2.0 Level AA under the Accessibility for Ontarians with Disabilities Act (AODA). That has been the law since January 1, 2021. The rule covers every page, form and document you have published on that site since January 1, 2012, with two exceptions: live captions and pre-recorded audio descriptions. This guide explains who has to comply, what the standard actually asks for, what is due in 2026, and how to find and fix the problems on your own site.
Who has to make their website accessible under AODA?
The website requirement sits in section 14 of Ontario Regulation 191/11, the Integrated Accessibility Standards Regulation. It applies to three groups:
- The Government of Ontario and the Legislative Assembly: internet and intranet sites, WCAG 2.0 Level AA with no exceptions since January 1, 2020.
- Designated public sector organizations: municipalities, school boards, colleges, universities, hospitals and similar bodies, of any size.
- Large organizations. The regulation defines these as businesses and non-profits with 50 or more employees in Ontario.
The organization that controls the website is the one responsible, whether it controls it directly or through a contract that lets it change the site. If an agency built your site and you can ask them to change it, the obligation is yours, not theirs.
Small organizations (1 to 49 employees in Ontario) are not covered by section 14. They are still covered by section 12 of the same regulation: on request, every obligated organization must provide information in an accessible format or with communication supports, at no extra cost, and must tell the public that this is available. A site that already works with a screen reader is by far the cheapest way to meet that duty.
What does WCAG 2.0 Level AA actually require?
WCAG 2.0 is the W3C's Web Content Accessibility Guidelines, published in December 2008. It is organized into four principles. Content must be perceivable, operable, understandable and robust, each with testable success criteria at three levels: A, AA and AAA. AODA asks for Level A and Level AA, which together are 38 success criteria. In practice that means:
- Text has enough contrast against its background (4.5:1 for normal text, 3:1 for large text).
- Every image that carries meaning has a text alternative.
- Every function works with a keyboard alone, and you can always see where the keyboard focus is.
- Every form field has a label a screen reader can announce, and errors are explained in text.
- Pages have a logical heading structure, a page title and a declared language.
- Pre-recorded video has captions.
- Content still works when the text is enlarged to 200%.
For private and broader public sector organizations, two Level AA criteria are excepted: 1.2.4 Captions (Live) and 1.2.5 Audio Descriptions (Pre-recorded).
What content is covered, and what isn't
| Covered | Not covered |
|---|---|
| Public website pages published after January 1, 2012 | Content published before January 1, 2012 |
| Web applications you control (booking tools, portals, checkouts) | Internal intranet and extranet sites (except the Government of Ontario's) |
| PDFs, Word files and other documents posted on the site | Live captions and pre-recorded audio descriptions |
| Forms, menus, images and video on those pages | Cases where meeting the standard is genuinely not practicable |
"Not practicable" is a narrow exception, not a way out. The regulation lets an organization consider things like whether commercial software or tools exist to do the job. If something truly can't be made accessible and a person asks for it, you must explain why and give them the information in another form.
The AODA website timeline
| Date | Requirement (public sector and organizations with 50+ employees) |
|---|---|
| January 1, 2012 | Cut-off: content published after this date is covered |
| January 1, 2014 | New websites (a new domain or a significant refresh) must meet WCAG 2.0 Level A |
| January 1, 2021 | All public websites and web content must meet WCAG 2.0 Level AA (except 1.2.4 and 1.2.5) |
| December 31, 2026 | Next accessibility compliance report due for businesses and non-profits with 20+ employees |
The 2026 accessibility compliance report
Reporting is a separate duty from the website rule, with a lower threshold. Businesses and non-profits with 20 or more employees in Ontario must file an accessibility compliance report every three years, and the current deadline is December 31, 2026. Designated public sector organizations report every two years; their last deadline was December 31, 2025, and they must still file if they missed it. Reports are filed online through the Accessibility Compliance Reporting Portal, and the report asks you to confirm whether you meet the requirements that apply to you. If you have 50 or more employees, that includes the website requirement.
That makes the months before the deadline a sensible time to test your site: you want to be able to answer the website question honestly.
What happens if you don't comply?
Enforcement starts with the Ministry: a director can order an organization to comply and can order it to pay an administrative penalty under section 21 of the AODA. The heavier penalties sit in section 37 of the Act. Failing to comply with a director's order, or giving false or misleading information in an accessibility report, is an offence punishable by a fine of up to $50,000 a day for an individual and up to $100,000 a day for a corporation. Directors and officers of a corporation have a personal duty to take reasonable care to prevent the offence, and face up to $50,000 a day if they don't.
Penalties are not the only exposure. An inaccessible site also shuts out customers: anyone who uses a screen reader, a keyboard instead of a mouse, or magnification can't buy, book or contact you through a page that doesn't work for them.
12 accessibility failures we fix most often
When we audit Ontario sites against WCAG 2.0 AA, the same problems come up again and again. Most are fixable without a redesign:
- Low colour contrast: light grey body text, white text on bright brand colours, placeholder text used as labels.
- Missing or useless alt text: images with no alternative, or alt text like "image1.jpg".
- Form fields without labels: the placeholder disappears as soon as someone types, and a screen reader announces just "edit text".
- Error messages that only use colour: a red border with no text saying what went wrong.
- Menus you can't use with a keyboard: drop-downs that open on hover only.
- Invisible keyboard focus:
outline: nonein the theme, so keyboard users can't see where they are. - Keyboard traps: pop-ups, chat widgets and sliders that you can tab into but not out of.
- Broken heading structure: headings chosen for their size rather than their level, or no H1 at all.
- Vague link text: a page full of "Click here" and "Read more" links.
- Untagged PDFs: scanned images of documents, or PDFs exported without tags, reading order or a language.
- Video without captions: auto-generated captions that were never checked.
- Missing page language and titles: every page called "Home", no
langattribute, so a screen reader can't pick the right voice.
How to test your own website
No single tool proves compliance. A sound check combines automated scanning with a person using the site the way a disabled visitor would:
- Run an automated scan on your key templates: home, a service page, a blog post, the contact form, checkout. Free tools such as WAVE, axe DevTools and Google Lighthouse find contrast errors, missing labels and alt text quickly. Automated tools catch only part of the WCAG criteria, so treat a clean scan as a starting point.
- Put the mouse away. Tab through each page. Can you reach every link, button and form field? Can you always see where the focus is? Can you open and close the menu and any pop-up?
- Listen to it. Turn on a screen reader (VoiceOver on a Mac or iPhone, NVDA on Windows) and try to fill in your contact form.
- Zoom to 200%. Nothing should overlap or disappear.
- Open your PDFs in Adobe Acrobat and run the accessibility checker, or check them with the free PDF Accessibility Checker (PAC).
- Write it down. Keep a record of what you tested, what failed and what you fixed. It is what you'll rely on when you file your compliance report.
Smaller organizations: what makes sense
If you have fewer than 50 employees, section 14 doesn't apply to you. You are still an obligated organization under the regulation, and many of your customers, clients or funders may expect an accessible site. A practical approach: fix contrast, labels, alt text and keyboard access when the site is next updated, make sure your contact form works with a screen reader, and add a short note telling visitors how to ask for information in another format. If you're planning a new site anyway, build it to WCAG 2.0 AA from the start; it costs far less than retrofitting later, and you'll already be compliant if you grow past 50 employees.
Why accessibility widgets don't solve it
Overlay widgets promise one-line compliance: a toolbar that lets visitors change contrast or font size. They don't change the underlying code, so the problems a screen reader or keyboard user actually hits (unlabelled fields, focus traps, untagged PDFs, missing headings) are all still there. Many screen-reader users find overlays get in the way of the tools they already use. AODA asks for a site that conforms to WCAG 2.0 AA, and the only way to get there is to fix the site.
Get your site AODA-ready
We build new websites to WCAG 2.0 Level AA and audit and fix existing ones, including templates, forms, menus and PDFs, so you can answer the website question on your compliance report with confidence. See our web design and development services, or ask for a free, no-obligation accessibility review. We respond within one business day. Prefer to talk? Call (647) 689-6069.
Sources: Ontario Regulation 191/11, sections 2, 12 and 14; Accessibility for Ontarians with Disabilities Act, 2005, sections 21 and 37; Ontario: How to make websites accessible; Ontario: Completing your accessibility compliance report. This guide is general information, not legal advice.
