Any AODA website compliance checklist starts with one rule: Ontario businesses and non-profits with 50 or more employees must meet WCAG 2.0 Level AA, the international accessibility standard for websites. Ontario Regulation 191/11, under the Accessibility for Ontarians with Disabilities Act, sets it. Separately, 2026 is a reporting year: every business or non-profit with 20 or more employees must file an accessibility compliance report by December 31, 2026.
- Website rule: WCAG 2.0 Level AA for all public websites and web content since January 1, 2021, minus live captions and pre-recorded audio description (O. Reg. 191/11, s. 14).
- Who: designated public sector organizations, and organizations with 50 or more employees in Ontario.
- Filing: 20+ employees, every three years, next deadline December 31, 2026 (Ontario.ca).
- Fines in the Act: up to $100,000 a day for a corporation, for offences such as false information in a report or ignoring a director's order (AODA, s. 37).
Everything below is general information, not legal advice. If your situation is unusual (several entities, staff in and outside Ontario, a federally regulated business), ask a lawyer.
What does AODA require for websites?
AODA (the Accessibility for Ontarians with Disabilities Act, 2005) requires covered organizations to make their public websites and web content meet WCAG 2.0 Level AA. WCAG means the Web Content Accessibility Guidelines, the international standard published by the World Wide Web Consortium (W3C).
The detail lives in section 14 of the Integrated Accessibility Standards Regulation (O. Reg. 191/11). The version we read on e-Laws is current to October 21, 2026. For designated public sector organizations and "large organizations," the schedule was:
| Date | What had to meet the standard | Level |
|---|---|---|
| January 1, 2014 | New public websites and their content | WCAG 2.0 Level A |
| January 1, 2021 | All public websites and web content | WCAG 2.0 Level AA, except live captions (1.2.4) and pre-recorded audio description (1.2.5) |
The regulation defines a large organization as one with 50 or more employees in Ontario. A small organization has 1 to 49. Section 14 does not put the website rule on small organizations.
Three limits narrow the rule:
- Content date. The rule covers web content published after January 1, 2012.
- Control. It covers sites you control directly or through a contract that lets you change the product.
- Practicability. The rule applies "except where meeting the requirement is not practicable." Ontario's guidance gives online maps and complex diagrams as examples of content that may not convert, and says you must explain why and give a summary if someone asks for it in an accessible format.
Who has to file an AODA compliance report in 2026?
Every business or non-profit with 20 or more employees in Ontario files an accessibility compliance report every three years, and the current deadline is December 31, 2026. Designated public sector organizations file every two years; their last deadline was December 31, 2025.
So the two thresholds differ. A 30-person firm has to file a report but isn't covered by the section 14 website rule. A 60-person firm has to do both.
Ontario's filing page lists what you need before you start:
- your organization's legal name
- your business number (BN9, from your tax return)
- your number of employees
- the name and contact details of your certifier, a senior officer with authority to confirm the report is complete and accurate
You file online through the Accessibility Compliance Reporting Portal: create an account, choose "New Submission," pick "Accessibility Compliance Report," and submit. The certifier and primary contact get a confirmation email with a confirmation number.
The AODA statute also requires you to make the report available to the public, so treat it as a public statement about your website.
WCAG 2.0 vs 2.2: which does AODA require?
AODA requires WCAG 2.0. The regulation doesn't leave room for interpretation: section 14(7) defines the guidelines as the W3C Recommendation "dated December 2008" and titled WCAG 2.0. The 2026 consolidation still defines it that way.
Lawyers who advise Ontario employers read it the same way. Justine Lindner and Tish T. Lewis of McCarthy Tétrault wrote in August 2026: "Website accessibility obligations under WCAG 2.0 Level AA remain in effect and require ongoing compliance" (McCarthy Tétrault).
WCAG 2.2 is still the better target for a site you're building or rebuilding now:
| WCAG 2.0 | WCAG 2.2 | |
|---|---|---|
| W3C date | December 11, 2008 | December 12, 2024 (current version) |
| AODA legal minimum? | Yes, Level AA | No |
| Relationship | Base standard | W3C says content that conforms to 2.2 also conforms to 2.0 and 2.1 |
| What's new | 9 added criteria, including target size, focus not hidden behind sticky headers, dragging alternatives and easier logins | |
| Removed | 4.1.1 Parsing |
Building to 2.2 AA means you meet the AODA floor and you're ahead if Ontario ever updates the reference. Telling a client or a regulator that 2.2 is "the AODA requirement" is wrong, though.
The AODA website compliance checklist
A business owner can run every check below with a browser and a keyboard. Each maps to a WCAG 2.0 success criterion that Ontario's guidance lists as part of Level A or AA.
| Check | WCAG 2.0 criterion | What it means in plain words | How to test it yourself |
|---|---|---|---|
| Alt text | 1.1.1 Non-text content (A) | Every meaningful image has a short text description a screen reader can read out | Right-click an image, inspect it, and look for an alt attribute that describes it. A logo that links home should say where it goes, such as "Company name home" (W3C) |
| Colour contrast | 1.4.3 Contrast (Minimum) (AA) | Body text needs a contrast ratio of at least 4.5:1 against its background | Check light grey text, text on photos and buttons with a free contrast checker |
| Keyboard navigation | 2.1.1 Keyboard, 2.1.2 No keyboard trap (A) | Everything you can click, you can also reach and use with the keyboard alone, and you never get stuck | Put the mouse away. Tab through the menu, a form and checkout or booking |
| Visible focus | 2.4.7 Focus visible (AA) | You can always see where the keyboard is on the page | While tabbing, is there an outline or highlight on each link and button? |
| Form labels | 3.3.2 Labels or instructions (A), 1.3.1 Info and relationships (A) | Each field has a label or instructions saying what goes in it | Click a field and start typing. If the only hint was grey text inside the box that has now vanished, we'd treat that as a fail |
| Error messages | 3.3.1 Error identification (A) | When a form fails, it says which field and why, in text | Submit your contact form empty and read what happens |
| Captions | 1.2.2 Captions (Prerecorded) (A) | Pre-recorded videos with sound have accurate captions | Play each video with sound off. Do the captions match what is said? |
| Headings | 1.3.1 Info and relationships (A), 2.4.6 Headings and labels (AA) | Headings are coded as headings and describe their section | Do subheadings make sense read alone? Is any "heading" just bold text? |
| Link text | 2.4.4 Link purpose (in context) (A) | A link says where it goes | Search for "click here," "read more" and "learn more" with no context |
| Zoom | 1.4.4 Resize text (AA) | Text can be enlarged to 200% without losing content or features | Zoom your browser to 200%. Does anything overlap, get cut off or vanish? |
| Page title and language | 2.4.2 Page titled (A), 3.1.1 Language of page (A) | Each page has a title that describes its topic, and the page declares its language | Look at the browser tab. Do all your pages say the same thing? |
Passing these doesn't prove conformance. Ontario's guidance recommends combining automated testing, testing with assistive technology such as a screen reader, and feedback from people with disabilities. It also says to keep a record of fixed issues, which helps "if your organization is asked to show that your website is WCAG 2.0 Level AA compliant" (Ontario.ca).
Many of these fixes also make a site easier for everyone, which is the argument in our post on sites that make visitors think. If you're hiring someone to fix them, Ontario's guidance suggests asking developers whether they know WCAG 2.0 A and AA and how they test; we list more questions in questions to ask a web designer in Toronto.
Do accessibility overlay plugins make you compliant?
No overlay can make a site conform on its own, because WCAG conformance is about the site's own code and content. Overlays are the floating accessibility buttons, often with a wheelchair icon, that load a script on top of your page.
The University of Michigan, which tests these products, does not support or recommend them. Its guidance says "our testing and most industry research show that overlays do not fix all or many accessibility issues" and may add barriers (University of Michigan). It lists specific problems:
- They duplicate zoom and contrast settings people already have, and can break them.
- Some block keyboard navigation, get in the way of assistive technology such as screen readers, or create inaccurate form labels.
- They may not load when a visitor uses an ad blocker.
Whatever a widget offers visitors, it doesn't replace fixing alt text, labels and keyboard access. Those fixes live in your templates and content, and they stay fixed when the script fails to load.
What happens if you miss the deadline?
Ontario says that if you don't complete your report, "you could face enforcement measures which can include financial penalties." The province also audits and inspects organizations to check they follow the requirements.
The Act sets out two kinds of penalty:
| Penalty | Where in the AODA | What it covers |
|---|---|---|
| Administrative penalty | Section 21 | A director can order one after finding non-compliance, in amounts set by regulation |
| Fine on conviction | Section 37 | Up to $50,000 a day for a person, or $100,000 a day for a corporation |
The section 37 fines apply to specific offences: giving false or misleading information in an accessibility report, failing to comply with an order made under the Act, and intimidating people who seek enforcement. Directors and officers of a corporation can also be fined up to $50,000 a day if they fail to take reasonable care to prevent the offence.
File late rather than not at all; Ontario tells public sector organizations that missed 2025 to file anyway. And answer accurately: a report saying your site meets WCAG 2.0 AA when it doesn't is the kind of false information section 37 covers.
If you'd like a second pair of eyes before you certify, we run a free site check at /audit. If the fixes point to a rebuild, our Toronto website cost guide shows what each scope costs.