AODA website requirements: what Ontario organizations actually have to do

What the AODA is, in one minute

The Accessibility for Ontarians with Disabilities Act (AODA) is an Ontario law passed in 2005. Its detailed rules sit in a regulation called the Integrated Accessibility Standards Regulation (Ontario Regulation 191/11), which covers customer service, employment, transportation, public spaces, and information and communications. Websites fall under information and communications.

For websites, the regulation points to an international standard rather than writing its own rules: WCAG 2.0, the Web Content Accessibility Guidelines published by the W3C. WCAG is a list of testable “success criteria” grouped into three levels. Level A is the minimum, Level AA is the commonly required target, and Level AAA is the strictest.

In practice, the criteria come down to things like: images have text alternatives, text has enough contrast against its background, everything works with a keyboard alone, forms have proper labels and clear error messages, videos have captions, and the page structure makes sense to a screen reader.

AODA website requirements: who has to comply

The WCAG requirement depends on the type and size of your organization. Here is how it breaks down, according to the Government of Ontario's guide on how to make websites accessible.

A few details catch people out:

• It is about who controls the site. If a developer, agency or platform builds or hosts your site under contract, the obligation is still yours.
• Two criteria are exempt. You do not have to provide live captions for live video (criterion 1.2.4) or audio descriptions for pre-recorded video (1.2.5). Captions for pre-recorded video are still required.
• Older content is excluded. The rule applies to websites and web content published after January 1, 2012. If you republish or significantly update old content, treat it as new.
• Intranets are mostly excluded. Internal sites for staff do not have to meet WCAG, but you still have to help an employee who asks for information in an accessible format.

“Website” also means more than the pages themselves. Online booking forms, donation forms, downloadable PDFs and embedded tools are all part of the web content your visitors use. If you are choosing one, my guide to online booking systems covers what to check before you commit.

Fewer than 50 employees? What you still have to do

Small businesses and non-profits are not legally required to make their public website meet WCAG. That is not the same as having no obligations. Since January 1, 2017, organizations with 1 to 49 employees in Ontario have had to:

• Provide accessible formats and communication supports on request. If someone cannot use the information on your website, you need to work with them to provide it another way, in a timely manner and at no more than the regular cost charged to anyone else. That might be a phone call, an accessible Word document, large print, or help completing a form.
• Make feedback processes accessible. If you take feedback from the public, you need to let people know accessible formats and communication supports are available, and provide them when asked.
• Meet the customer service and employment rules. These are not website rules, but they often show up on websites: telling job applicants that accommodations are available, for example.

My honest advice: even if you are under 50 employees, build to WCAG AA anyway. A site that already works with a keyboard and a screen reader means far fewer accessible-format requests to handle by hand. It is also usually a faster, clearer site for everyone, and it saves a rebuild if you grow past 50 people.

The accessibility compliance report due December 31, 2026

Separately from the website standard, Ontario businesses and non-profits with 20 or more employees must file an accessibility compliance report every three years. The current report is due December 31, 2026. Designated public sector organizations report every two years.

The report is an online self-assessment submitted through the province's Accessibility Compliance Reporting Portal. It asks whether you are meeting your AODA obligations, which for organizations with 50 or more employees includes the website requirement. You will need your legal name, business number and employee count, and someone authorized to certify the report. The province's page on completing your accessibility compliance report walks through it and notes that not filing can lead to enforcement, including financial penalties.

What WCAG 2.0 Level AA means on a real website

WCAG has dozens of criteria, but on the small-business and non-profit sites I review, most problems fall into a short list. If you want to check your own site, start here:

WCAG has moved on since 2.0. Versions 2.1 and 2.2 add criteria for mobile, low vision and cognitive accessibility. Ontario's rule still names 2.0, but building to a newer version is a sensible target: it covers most of what 2.0 asks for and better reflects how people use the web today. The W3C's WCAG overview explains the versions. Every site I build targets WCAG 2.1 AA, as listed on my services page.

How to find and fix accessibility problems

There is no certificate or official badge for AODA compliance. You meet the requirement by making the site meet the criteria and keeping it that way. A realistic process looks like this:

1. Run a free automated check. Tools such as Lighthouse, built into Chrome, flag missing alt text, low contrast and unlabelled fields in minutes. They catch only part of WCAG, so a clean score is not proof of compliance. The W3C's overview of evaluating web accessibility is clear that human testing is still needed.
2. Test by hand. Unplug your mouse and try to book, buy, donate or contact you using only the keyboard. Then try the same with a screen reader: VoiceOver is built into Macs and iPhones, and NVDA is free for Windows. This is where the most serious problems show up.
3. Fix the template first. Problems in the header, navigation, footer or form styles repeat on every page, so fixing them once fixes the whole site.
4. Fix content next. Alt text, headings, link wording, captions and PDFs are usually things your team can learn to do correctly from now on.
5. Write it down. Keep a short record of what you tested, what you fixed and when. It helps when you complete your compliance report, and when someone asks.

If your site is on an older template or a page builder, fixing it can be fiddly but is usually still cheaper than rebuilding. If you would rather have someone else review it, I do accessibility audits and fixes at $45 an hour plus HST, and the pricing page covers new builds. Either way, you can ask me for an honest assessment of what your site needs before spending anything.