AODA Website Compliance: What Ontario Businesses Must Do and the WCAG Level That Applies
Under the AODA, Ontario businesses and non-profits with 50 or more employees must make their public websites meet WCAG 2.0 Level AA, apart from live captions and pre-recorded audio descriptions, and every organization with employees in Ontario must follow the accessible customer service and information rules. Organizations with 20 or more employees must also file an accessibility compliance report, and the current deadline is December 31, 2026. This guide explains who must comply, which WCAG level applies, what to fix first and how to keep a site accessible after launch.
This is general information about Ontario’s accessibility rules, not legal advice. Check the current requirements for your organization on ontario.ca or with a lawyer.
What is the AODA?
The Accessibility for Ontarians with Disabilities Act, 2005 is the Ontario law that sets out how accessibility standards are developed, put in place and enforced. The standards that apply to businesses sit mostly in Ontario Regulation 191/11 (the Integrated Accessibility Standards Regulation) and cover customer service, information and communications, employment, transportation and the design of public spaces. The website rules are part of the information and communications standards.
The Government of Ontario explains the duties on its pages for businesses and non-profits and on how to make websites accessible.
Is AODA compliance mandatory in Ontario?
Yes, for every business and non-profit with employees in Ontario (organizations with no employees in Ontario are exempt), and the duties grow with size:
- Fewer than 20 employees: create accessibility policies, train staff and volunteers on accessible customer service and the Ontario Human Rights Code, provide accessible customer service and make information and communications accessible on request.
- 20 to 49 employees: all of the above, plus an accessibility compliance report filed every three years.
- 50 or more employees: all of the above, plus documented accessibility policies, a multi-year accessibility plan posted on your website and reviewed at least every five years, and public websites that meet WCAG 2.0 Level AA.
Count your employees as the province describes on its business rules page. When you are close to a threshold, plan for the higher one.
Does the AODA require WCAG 2.0, 2.1 or 2.2?
The legal requirement is WCAG 2.0 Level AA for public websites and web content posted after January 1, 2012, with two success criteria excluded: 1.2.4 live captions and 1.2.5 pre-recorded audio descriptions. Since January 1, 2021, this applies to all public websites of designated public sector organizations and of businesses and non-profits with 50 or more employees.
WCAG 2.2 is the current version from the W3C, and it includes the 2.0 criteria plus newer ones on focus visibility, target size and accessible sign-in. Building to WCAG 2.2 Level AA meets the Ontario requirement and covers the newer guidance that phone users and keyboard users rely on. It is also the version most web teams test against today.
Who is responsible: the business or the web developer?
The organization that controls the website, directly or through a contract, must meet the requirements. A developer or agency does the work, but the duty stays with the business. Put the WCAG level in writing when you commission a site, and ask for a record of what was tested.
Do internal sites, PDFs and forms need to be accessible?
Internal sites (an intranet or extranet) do not have to meet WCAG under the website rule for private organizations, but if a person asks for information in an accessible format, you must work with them to provide it. Public web content includes the documents and forms you post, so PDFs, booking forms, contact forms and embedded videos on your public site count. A form with missing labels or a scanned PDF menu is one of the most common gaps.
What WCAG Level AA means in practice
WCAG is a list of testable success criteria grouped under four principles: content must be perceivable, operable, understandable and robust. For a typical small business site, the criteria that fail most often are:
- images without useful alternative text, or decorative images that are announced to screen readers;
- low colour contrast, for example light grey text on white, or white text on a pale photo;
- forms whose fields have no visible labels, or error messages that only use colour;
- menus, sliders and pop-ups that cannot be used with a keyboard, or a focus outline that has been hidden;
- headings used for size instead of structure, which breaks navigation for screen reader users;
- videos without captions, and audio without transcripts;
- text that breaks or overlaps when zoomed to 200 percent;
- links that say only “click here” or “read more”.
How to check your website
- Run a free automated checker on your main templates (home, a service page, a blog post, the contact form). Automated tools catch mechanical problems such as missing alt text and low contrast.
- Test with a keyboard only: press Tab through each page and confirm you can reach and use every link, button and field, and always see where the focus is.
- Zoom the browser to 200 percent and check that nothing overlaps or disappears.
- Try a screen reader (VoiceOver on Apple devices, NVDA or Narrator on Windows) on your contact form.
- Record each issue, the fix and the date, so you can show the work if asked.
Automated scans never cover everything, because many criteria need a person to judge, such as whether alt text actually describes the image. Overlay widgets that promise one-line compliance do not fix the underlying code.
How do I file an accessibility compliance report?
Businesses and non-profits with 20 or more employees file online through Ontario’s Accessibility Compliance Reporting portal, which is linked from the province’s business rules page. Review your policies, training records and website against the requirements for your size before you start. The province’s current deadline is December 31, 2026.
We design and build fast, accessible websites for Canadian businesses, with SEO built in from day one.
How can I get an AODA certificate, and is it free?
The province does not issue a certificate that proves a business is AODA compliant. Courses on accessible customer service often give a certificate of completion, some free and some paid. That certificate helps you show staff were trained on the topics the standard requires: the Ontario Human Rights Code, accessible customer service and the accessibility rules that apply to their jobs.
What are the five AODA standards?
The Integrated Accessibility Standards Regulation contains standards for customer service, information and communications, employment, transportation, and the design of public spaces. Most private businesses deal mainly with customer service, information and communications (which includes websites) and employment.
AODA website checklist
- Know your employee count and which duties apply to you.
- Public website built and tested to WCAG 2.2 Level AA, which also meets the WCAG 2.0 AA requirement.
- Alt text on informative images, captions on videos, transcripts for audio.
- Forms with visible labels and clear error messages, usable by keyboard.
- Colour contrast checked on text, buttons and text over photos.
- A note on your site that information is available in accessible formats on request.
- Accessibility policies, training records and, at 50 or more employees, a posted multi-year plan.
- Compliance report filed by the deadline if you have 20 or more employees.
Our web design team in Toronto builds sites to WCAG 2.2 Level AA from the first wireframe, so colour, forms, keyboard use and captions are handled before launch rather than patched later. If you are planning a new site, our guide on how to make a website for your business covers the full sequence.
Frequently asked questions
Is AODA mandatory in Ontario?
Yes. Every business and non-profit with employees in Ontario must follow the accessibility standards that apply to its size. Organizations with no employees in Ontario are exempt.
What does AODA compliance mean for a website?
Businesses and non-profits with 50 or more employees must make public websites and web content posted after January 1, 2012 meet WCAG 2.0 Level AA, except live captions and pre-recorded audio descriptions.
Does AODA require WCAG 2.0, 2.1 or 2.2?
The legal standard is WCAG 2.0 Level AA. Building to WCAG 2.2 Level AA, the current W3C version, meets that requirement and covers newer criteria such as focus visibility and target size.
What are the 5 standards of AODA?
Customer service, information and communications, employment, transportation, and the design of public spaces, all in Ontario Regulation 191/11.
How do I know if my organization has 50 or more employees?
Count employees as the Government of Ontario describes on its accessibility rules page for businesses and non-profits. If you are close to a threshold, plan for the higher one.
Do small businesses need an accessible website in Ontario?
The WCAG website rule applies at 50 or more employees, but smaller organizations must still provide accessible customer service and make information accessible on request, and an accessible site is the simplest way to do that. Our Toronto web design team builds to WCAG 2.2 Level AA.
Do PDFs and forms need to be accessible under AODA?
Yes, when they are public web content on a site covered by the rule. Booking forms, contact forms, PDFs and embedded videos all count.
When is the AODA compliance report due?
Businesses and non-profits with 20 or more employees file every three years; the current deadline is December 31, 2026, through Ontario's Accessibility Compliance Reporting portal.
How can I get an AODA certificate in Ontario?
Ontario does not issue a certificate of AODA compliance. Accessible customer service courses often give a certificate of completion that helps show your staff were trained.
Is an AODA certificate free?
Some accessible customer service courses are free and others are paid. The training requirement is about the topics covered, not who provides the course.
Who is responsible for AODA compliance, the business or the web developer?
The organization that controls the website, directly or through a contract. Put the WCAG level in writing when you commission a site.
Do accessibility overlay widgets make a site AODA compliant?
No. Overlays add a toolbar on top of the page but do not fix the underlying code, labels, contrast or keyboard access that WCAG tests.