Guide · Website Compliance

AODA website compliance: what Ontario law actually requires

Guide · Updated 2026-07-13 · 10 min read

If your organization has 50 or more employees in Ontario, your public website and web content must meet WCAG 2.0 Level AA — and that has been the law since January 1, 2021, not something arriving in 2026. Businesses under 50 employees have no WCAG mandate. What changes this year is visibility: the accessibility compliance report due December 31, 2026 asks 50+ organizations to certify, yes or no, whether their website complies.

The rule, precisely

What the requirement covers — and what it doesn't

The rule (section 14 of O. Reg. 191/11) applies to businesses and non-profits with 50+ employees and to designated public-sector organizations, for websites they control directly or through a contractual relationship — "our agency runs the site" is not an exemption. It covers content published since January 1, 2012: pages, images, forms, documents like PDFs, and web applications.

Getting the boundaries right matters, because over-claiming is how vendors scare businesses into overlays. The real rule:

Scope — WCAG 2.0 AA under the AODA

  • Public websites and web content published since January 1, 2012 — must meet WCAG 2.0 Level AA
  • Except success criteria 1.2.4 (live captions) and 1.2.5 (pre-recorded audio description) — explicitly carved out
  • Internal sites (intranets, extranets) are exempt — though accessible formats on request still apply
  • Where meeting a criterion is not practicable, the regulation allows posting non-conforming content with an explanation and an accessible summary

In practice

What failing actually looks like

WCAG 2.0 AA is a technical standard, but the failures we find are mundane: product photos with no text description, links a screen reader announces as "link," grey-on-grey text, forms whose fields have no labels, pages that block zooming on a phone. When we scan established Ontario businesses in the 50–100 employee range, a typical site fails 95 to 274 automated checks across just six pages — including issues classed as critical. An excerpt from a real (anonymized) scan:

Website Scan — Findings

Ontario manufacturer · 50–100 employees · 6 pages scanned

Real scan — anonymized axe-core automated review
Critical

Product images missing text descriptionsScreen-reader users cannot tell what they show

WCAG 1.1.1
Critical

Dozens of links with no accessible nameAnnounced only as “link” by assistive technology

WCAG 4.1.2
Serious

74 colour-contrast failuresText illegible for low-vision users — common even on newly redesigned sites

WCAG 1.4.3
Serious

Zoom disabled on mobileUsers cannot magnify text — a one-line fix in the page header

WCAG 1.4.4

Prepared by AODAPrep · Human-reviewed4 of 140 instances shown✓ Each maps to report Q2

Two honest caveats. Automated scanners catch only roughly a third of WCAG criteria — a clean scan is necessary, not sufficient. And a recent redesign is no guarantee: some of the worst contrast and ARIA failures we've found were on professionally rebuilt sites.

Check it yourself — free

Free ways to test your own site today

You don't need a vendor to get a first read. Any of these free tools will surface the automated failures in minutes:

DIY toolbox — all free

  • WAVE — paste your URL, see issues overlaid on your page
  • Lighthouse — built into Chrome (DevTools → Lighthouse → Accessibility)
  • axe DevTools — the same engine our scanner uses, as a browser extension
  • The five-minute manual test: unplug your mouse and try to navigate by keyboard alone; then try zooming to 200%

The catch: these tools produce developer output — hundreds of findings with no prioritization, no sense of what the law actually requires, and nothing about the policy, feedback-process, and accessible-formats obligations that sit next to WCAG in the same report question.

Fixing it

How we take a failing site to a defensible "Yes"

  1. Free scan

    Send us your address; we scan your key pages and top public PDFs and tell you plainly where you stand — free, whether or not we ever speak again.

  2. Two reports, two audiences

    A plain-English report for the owner (what's wrong, what it means for the December certification) and a precise, prioritized fix list your developer or agency can work through ticket by ticket.

  3. Rescan and document

    After fixes, we rescan, record the result, and draft the accessibility-statement and feedback-process pages the same report question expects.

  4. Answer, supported

    Question 2 gets answered with evidence behind it — or, where something genuinely can't be finished in time, an honest answer with a documented remediation plan, which the regulation itself anticipates.

Find out what your website fails — free.

Send us your website address. We’ll run the scan and reply in plain English with your top findings and what they mean for the December report. No obligation.

Send us your website address — free scan → Book a free 15-minute readiness call

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Sources — Official

Report question and checkbox wording captured from the Accessibility Compliance Reporting Portal, July 2026. This guide is general information, not legal advice.