Accessibility laws · Ontario, Canada

Accessibility for Ontarians with Disabilities Act (AODA)

Ontario put WCAG 2.0 Level AA into a regulation, named the two success criteria most organizations get to skip, and set a deadline that passed on January 1, 2021. No court had to decide any of it. What catches owners out is that this law runs on two different employee counts. At 50 or more employees in Ontario your public website owes the standard, and at 20 or more you owe a compliance report even if the web rule never reaches you. That report is due December 31, 2026.

WCAG written into law: 2.0 AA
Employees to be covered: 50+
Max daily fine (corp., CAD): $100k
Full web deadline: 2021

What the law is

The Accessibility for Ontarians with Disabilities Act, the AODA, was passed in 2005 with a date written into its own purpose. Ontario was to be accessible for people with disabilities on or before January 1, 2025. That date has passed, and the province did not get there, which is the honest frame for every number further down this page. The web duty itself sits in the Information and Communications Standard, one of five standards under the regulation alongside Employment, Transportation, Design of Public Spaces, and Customer Service. If you are a covered organization, your public websites and web content have to meet WCAG 2.0 Level AA. That sentence is in the regulation, section 14 of O. Reg. 191/11, so nobody has to argue a court into it first.

Two success criteria are carved out by name. Live captioning for real-time audio and video, criterion 1.2.4, and audio description for pre-recorded video, criterion 1.2.5, are both excluded, so you do not have to meet those two to be compliant. WCAG 2.0 carries 38 criteria at Level A and AA, which makes the Ontario web duty 36 of them. One group does not get that discount. Section 14 puts the Government of Ontario and the Legislative Assembly on their own schedule, covering intranets as well as public sites, and their last step was the full Level AA with no exclusions at all by January 1, 2020. The rule reaches content published on your site after January 1, 2012, and it covers every site you control directly or through a contractual relationship that lets you modify the thing. So a hosted platform or an agency-run microsite is still yours.

As of 2026 the regulation still names WCAG 2.0 by version. The regulation was last amended in March 2026, by O. Reg. 69/26, and that amendment touched species-at-risk and building-code references in the physical-access rules rather than section 14's WCAG edition. Ontario's own plain-language web guidance still stated WCAG 2.0 Level AA with the same two exceptions when we read it on August 29, 2026. We should be straight about the next bit, because you will read it stated as fact elsewhere. We found no official Ontario commitment to a particular newer WCAG version or date. Testing against WCAG 2.2 AA covers almost all of today's actual requirement and adds a good deal on top. Almost. WCAG 2.2 dropped success criterion 4.1.1 Parsing and Ontario's regulation still names WCAG 2.0, which has it, so a 2.2-only audit leaves that one untested. Whether it also covers whatever Ontario does next is a guess, and ours is no better than anyone else's.

This applies to you if…

You are an Ontario public-sector organization, which the regulation calls a designated public sector organization. Size changes nothing here, so a small library board is covered on the same terms as a hospital. A ministry is a different animal, though. The Government of Ontario and the Legislative Assembly sit in their own subsection, with intranets in scope and both excluded criteria back on the list.
You are a business or non-profit with 50 or more employees in Ontario, which is where the WCAG 2.0 AA web duty starts outside government. Ontario's own guidance counts your highest employee total during the previous twelve months rather than a number on today's payroll, so a seasonal peak can put you over the line. Count full-time, part-time, and seasonal staff along with contract employees. Leave out volunteers, independent contractors, and anyone employed outside the province, which means a 5,000-person American company with 20 people in Toronto counts as a small organization here and does not owe section 14 at all.
You are a business or non-profit with 20 or more employees in Ontario, which is a lower and completely separate line. It triggers the accessibility compliance report rather than the web standard. A 30-person Ontario business owes Ontario a report by December 31, 2026 and owes nothing under the web rule.
A vendor runs your website and you assumed that made it their problem. Section 14 covers web content you control directly or through a contractual relationship, so the hosted platform, the booking widget, and the agency-built microsite are all yours to answer for.

What it technically requires

Your public websites and the web content on them have to conform to WCAG 2.0 Level AA, minus the two excluded criteria, for anything published after January 1, 2012. New sites had to reach Level A by January 1, 2014, and everything had to reach Level AA by January 1, 2021. Both dates are behind us, so the full standard is simply due. If you are the Government of Ontario or the Legislative Assembly, your date was January 1, 2020, it took in your intranet, and you do not get the two exclusions.
A redesign does not buy you a grace period, and the regulation's own definitions are why. A new internet website means one with a new domain name, or one on an existing domain going through a significant refresh. Either way it is a covered site under section 14, and the Level AA deadline it has to meet passed in January 2021.
File your accessibility compliance report on Ontario's schedule, and watch the threshold, because it is 20 employees rather than 50. Businesses and non-profits file every three years, and the current deadline is December 31, 2026. Designated public sector organizations file every two years, and their last deadline fell on December 31, 2025. The report carries a signed statement certifying that everything required is in it and that the information is accurate. Section 15 says who may sign. The list is wider than most guidance suggests. A director, a senior officer, or another responsible person with authority to bind the organization. What it is not is whoever built the site.
Make the filed report available to the public, because the Act requires that too. And treat the filing cycle as something that can move. The statute's default is an annual report, with the two-year and three-year cycles coming from a director specifying otherwise, so your schedule can change without the law changing.
Provide accessible formats and communication supports whenever somebody asks, a duty that reaches past the website into how your organization communicates at all. Section 14 also carries an exception, for content where meeting the requirement is not practicable. That exception is not a shrug. If someone requests content you genuinely cannot convert, you have to explain why it cannot be converted and give them a summary of what it says.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

How it is enforced

Ontario's Ministry for Seniors and Accessibility runs the compliance audits, and a director under the Act can issue orders and administrative penalties. Administrative penalties run on their own track, separate from a conviction in court. Part V of the regulation sorts contraventions into minor, moderate, and major, with major covering the priority requirements, particularly anything that puts the health or safety of people with disabilities at risk. The dollar amounts live in schedules to the regulation that we have not been able to read, so we are not going to quote you a figure we cannot show you.

On conviction the ceilings are high, and they run by the day. Read what they attach to first, because it is not a failed WCAG test. Section 37 makes three things an offence. Giving a director false or misleading information, in an accessibility report or otherwise. Failing to comply with an order made by a director or the Tribunal. And retaliating against somebody for seeking enforcement or cooperating with an inspector. A corporation convicted of one faces up to CA$100,000 for each day or part of a day the offence occurs. An individual or unincorporated organization faces up to CA$50,000 a day. A director or officer who fails to carry out the duty to keep the corporation from committing an offence carries that CA$50,000 daily exposure personally, which is the number that tends to get a boardroom listening.

What actually happens is far gentler than those ceilings, and you deserve the real figure rather than the scary one. In its 2024-25 report the ministry counted 1,855 audits of businesses, not-for-profit organizations, and the broader public sector, and put the share resolved as compliant at 99.8% for 2024. Those are two different periods sitting in one paragraph, which is the ministry's own arrangement rather than ours. The ministry's stated posture is to work with an organization that falls short and try to establish compliance before it considers enforcement at all. Read the word resolved carefully, because it is doing the work. That figure counts organizations compliant after the ministry helped them get there. Ontario publishes the other half itself. Compliance with the four foundational requirements, meaning policies, plans, feedback, and training, measured at the start of an audit with no further action needed, sat at 67% in 2024 against a target of 77% by December 2025. So two thirds are ready when the auditor arrives, and almost everybody is compliant by the time the file closes. Those are two different facts, and only the first one describes an organization before the ministry gets involved with it.

The compliance report is an obligation in its own right, written into the Act separately from the web standard in the regulation, and it carries a certification requirement with it. So a site still mid-remediation is not a reason to file late, or to file something you cannot stand behind. Fix the site on your schedule. File the report on Ontario's.

Key dates

Jan 1, 2014New public websites: WCAG 2.0 A
Jan 1, 2021All public websites and content since 2012: WCAG 2.0 AA
2026 →Regulation still cites WCAG 2.0 AA. No newer version or date has been officially committed to

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

Order your audit Run the free scan

Primary sources

Other laws

Related on this site

What to read next, and the terms this page uses.

Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.