Accessibility laws · Manitoba, Canada
The Accessibility for Manitobans Act (AMA)
Manitoba is the second Canadian province with a binding web accessibility duty, and if you learned Canadian accessibility law from AODA coverage you are probably under-estimating it. Ontario names WCAG 2.0 AA and starts at 50 employees. Manitoba names WCAG 2.1 AA and starts at one. The private sector date was May 1, 2025, so for most Manitoba businesses this is not a deadline to plan for. It is one that has already gone.
- WCAG version named
- 2.1 AA
- Employees to be covered
- 1
- Private sector date
- May 2025
- Public sector date
- May 2024
What the law is
The Accessibility for Manitobans Act became law in 2013, and like Ontario's AODA it works by issuing standards rather than by naming every duty in the act itself. Five standards were planned. The one that reaches your website is the Accessible Information and Communication Standard Regulation, made in May 2022, and it is the reason this page exists. It requires web content and web applications to meet or exceed WCAG 2.1 Level AA.
That version number matters more than it looks. Ontario's AODA still names WCAG 2.0 Level AA, and carves two captioning criteria out of it. Manitoba names 2.1 whole, which adds the mobile, low-vision and cognitive criteria that 2.0 never had. An organisation that built to satisfy Ontario has not automatically satisfied Manitoba, and the gap is real rather than academic.
The duty is narrower than a blanket conformance requirement, and reading it carefully saves work. It covers newly published web content, web content that is required to access goods and services, and web applications that are new or significantly updated. It is not an instruction to retrofit fifteen years of archive by Friday. It is an instruction that what you publish now, and what a customer has to use to buy from you, has to work.
This applies to you if…
- You have at least one employee in Manitoba. That is the whole threshold, and it is the fact most likely to catch a business out, because the AODA number everybody remembers is fifty. A five-person shop in Winnipeg is inside this standard. A five-person shop in Toronto is not inside Ontario's.
- You are a public sector body in Manitoba. Government agencies, universities and colleges, regional health authorities, the City of Winnipeg and specified municipalities, public and independent schools, adult learning centres, private vocational institutions and libraries all passed their date on May 1, 2024, a year ahead of the private sector.
- You are a non-profit operating in the province. Non-profits sit on the same May 1, 2025 date as private business, with no separate tier and no size carve-out.
- You sell into Manitoba from elsewhere in Canada and employ somebody there. The standard follows the employment relationship rather than your head office, so an Ontario company with a Winnipeg salesperson is answering to both provinces at once, against two different versions of WCAG.
What it technically requires
- Web content and web applications that meet or exceed WCAG 2.1 Level AA, on the scope described above. The practical reading is that every page you publish from now on, and every page in the path between a customer and the thing they are buying, is in. A marketing page from 2019 that nobody needs to get through is treated differently from your checkout.
- Exceptions exist and they are named rather than open-ended. Technical infeasibility, technology not being available, undue hardship, content you do not directly control, and product labels. None of those is a general hardship escape hatch, and the burden of showing one applies sits with you. If you are relying on "we do not control it", be ready to say who does.
- Information in an accessible format, or with a communication support, when somebody asks for it. You have to tell the public and your employees that they can ask, you have to consult the person about what would actually work for them rather than deciding on their behalf, and you have to deliver it in a timely manner at no extra cost. Charging a disabled customer for the accessible version of something is the failure this clause exists to stop.
- A feedback process, and one that is itself accessible. A contact form nobody can complete with a keyboard is not a feedback process.
- Training for staff and volunteers on accessible communication and on The Human Rights Code (Manitoba). The training duty is separate from the web duty and the two are often confused. Fixing the site does not discharge it.
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
The Manitoba Accessibility Office administers the standard and the Act carries administrative penalties. We are not going to put a maximum figure on this page, because no source we could reach states a current one for a web-standard breach, and the number people reach for is Ontario's CA$100,000 per day, which belongs to a different statute in a different province. If a vendor quotes you a Manitoba penalty figure, ask them which section it comes from.
The more likely first contact is a complaint rather than an inspection. Somebody cannot use your site, they say so, and the process starts there. That is also why the feedback duty and the accessible-format duty matter as much as the WCAG number: they are the parts a real person interacts with when something has already gone wrong.
Human rights law sits underneath all of it. The Human Rights Code (Manitoba) reaches discrimination in services regardless of what any standard says, and the training requirement in the standard points at the Code directly, which tells you how the province sees the relationship between the two.
Key dates
- May 2022The Accessible Information and Communication Standard Regulation is made under the Act
- May 1, 2023The Government of Manitoba has to meet the standard
- May 1, 2024Public sector bodies: agencies, universities and colleges, regional health authorities, the City of Winnipeg and specified municipalities, schools, adult learning centres, private vocational institutions and libraries
- May 1, 2025Private sector and non-profit organisations with at least one employee in Manitoba. This date has passed
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.
Primary sources
Other laws
- United StatesADAWCAG 2.1 AA (Title II rule, de facto standard in Title III cases)
- European UnionEAAAnnex I, EN 301 549 (includes WCAG 2.1 AA)
- United States (federal)Section 508WCAG 2.0 AA (incorporated by the 2017 refresh)
- United States (aviation)ACAAWCAG 2.0 AA, named in 14 CFR 382.43
- United States (telecoms)Section 255WCAG 2.0 A and AA, through the Revised 255 Guidelines
- European UnionWeb Accessibility DirectiveEN 301 549 V3.2.1, which carries WCAG 2.1 AA
- California, USUnruh ActWCAG 2.1 AA (what courts and settlements expect)
- ArgentinaArgentina Ley 26.653WCAG 2.0, referenced by the law
- ChinaChina PPD LawNo WCAG version named in the law itself
- ColombiaColombia guidelinesWCAG 2.1
- Hong KongHong Kong guidelinesWCAG 2.0
- TaiwanTaiwan 110.07WCAG 2.1 derivative
- Saudi ArabiaSaudi SWAWCAG 2.1 AA
- QatarQatar Law No. 2WCAG 2.1 AA
- United Arab EmiratesUAE requirementsWCAG 2.1 AA
- Ontario, CanadaAODAWCAG 2.0 AA (excl. 1.2.4 & 1.2.5)
- United KingdomUK Equality ActWCAG A and AA, named in PSBAR regulation 9 as amended from time to time
- United States (healthcare)HHS Section 504WCAG 2.1 AA (2024 final rule)
- New York, USNew York HRLWCAG 2.1 AA (what complaints and settlements cite)
- Colorado, USColorado HB21-1110WCAG 2.1 AA (written into state standards)
- Canada (federal)Accessible Canada ActCAN/ASC-EN 301 549 → WCAG 2.1 AA
- NorwayNorway (Universal Design)WCAG 2.0 AA private / 2.1 AA public
- IsraelIsrael IS 5568WCAG 2.0 AA (via IS 5568)
- AustraliaAustralia DDAWCAG 2.2 AA (AHRC 2025 guidance)
- GermanyGermany BFSGEN 301 549 → WCAG 2.1 AA
- FranceFrance RGAARGAA (WCAG-based) / EN 301 549
- ItalyItaly Stanca ActWCAG 2.1 AA (AgID guidelines)
- JapanJapan JIS X 8341-3JIS X 8341-3:2016 = WCAG 2.0 AA
- SpainSpain RD 1112/2018UNE-EN 301549, which incorporates WCAG 2.1 AA
- NetherlandsNetherlandsEN 301 549, which incorporates WCAG 2.1 AA
- IrelandIrelandEN 301 549, which incorporates WCAG 2.1 AA
- BrazilBrazil LBIeMAG, aligned with WCAG, plus ABNT NBR 17225 for web content
- IndiaIndia RPwDGIGW 3.0, which references WCAG 2.1
- New ZealandNew ZealandWCAG 2.2 Level AA
- South KoreaSouth KoreaKWCAG 2.2, a national standard aligned with WCAG
- SwitzerlandSwitzerland BehiGeCH-0059, which references WCAG 2.1 AA
- DenmarkDenmarkEN 301 549, which incorporates WCAG 2.1 AA
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.