Accessibility compliance guides · Canada

AODA website compliance in Ontario

The Accessibility for Ontarians with Disabilities Act is Canada’s oldest provincial accessibility statute. For websites, the deadline has already passed. If you are covered and the site is not conformant, the gap is current.

Technical standard: WCAG 2.0 Level AA (with two caption and audio-description exceptions)
Website deadline: January 1, 2021 — already in force
Penalties: Up to $100,000 per day for corporations

What it is

The AODA, passed in 2005, set a goal of an accessible Ontario by 2025. Website rules live in the Integrated Accessibility Standards Regulation (IASR, O. Reg. 191/11). Since January 1, 2021, covered organizations must make public websites and web content conform to WCAG 2.0 Level AA, except success criteria 1.2.4 (live captions) and 1.2.5 (pre-recorded audio descriptions).

The requirement covers websites and web applications the organization controls directly or through a contract, web content published after January 1, 2012, and documents the public needs. Covered organizations also file an accessibility compliance report on a recurring schedule.

The IASR still names WCAG 2.0 because that was current when it was written. WCAG 2.1 and 2.2 add criteria for mobile, low vision, and cognitive access. We audit to 2.1 and 2.2 AA so an Ontario site also stands up to Manitoba, the ADA Title II rule, and the European Accessibility Act.

Who needs to comply

The website rules do not apply to every Ontario employer. Other AODA duties, and the Human Rights Code, still might.

Ontario government and the Legislative Assembly. Covered in full, including public web content.
Designated public sector. Municipalities, universities, colleges, school boards, hospitals, and other designated public sector organizations.
Private sector and non-profits with 50 or more employees in Ontario. The employee count is Ontario employees, not worldwide headcount. Organizations under 50 are exempt from the website requirement but still have customer-service and policy duties, and remain exposed under the Ontario Human Rights Code.

Timeline

The conformance date is behind us. Reporting is the ongoing obligation.

January 1, 2012. Content published on or after this date is in scope once the WCAG 2.0 AA duty applies.
January 1, 2021. Public websites and web content of covered organizations must conform to WCAG 2.0 Level AA, with the two stated exceptions.
Every 2 or 3 years. Public sector organizations file an accessibility compliance report every two years. Businesses and non-profits file every three years. A false report is itself an offence.

What the rule requires

Conformance is necessary. The filing is what the province checks first.

WCAG 2.0 AA on public web content. Including PDFs and other documents people need in order to use the service. We treat 2.1/2.2 AA as the working target.
Contracted sites count. A website a vendor runs for you is still your website for the IASR if you control the content through the contract.
An accessibility compliance report. Confirming status to the province. We keep the evidence — audit, fixes, and known exceptions — that the report depends on.
Director and officer exposure. Corporations can be fined up to $100,000 per day. Directors and officers can be fined up to $50,000 per day.

How we help

We help Ontario organizations close the WCAG gap and walk into the next compliance report with evidence.

An audit against WCAG 2.0 AA, run at 2.1/2.2 AA so newer criteria are not a surprise later.
A conformance record you can use when you file the accessibility compliance report.
Manual testing with NVDA, JAWS, and VoiceOver, plus keyboard-only use and browser zoom. The failures these rules care about are often invisible to an automated scan.
Remediation in your production code by our developers, so the fix lives in the product and not only in a report.
An accessibility statement and, where a buyer or regulator expects one, a VPAT-based Accessibility Conformance Report grounded in the audit.
Training for the people who publish pages, documents, and campaigns after the audit.
A retest after major releases, so a later deploy does not quietly undo the work.

Web accessibility audit and remediation

Our process

Confirm what applies to you. We confirm whether you are designated public sector or a private or non-profit organization with 50 or more Ontario employees, and when your next report is due.
Audit the live experience. We review the pages, flows, documents, and apps people actually use, with assistive technologies as well as automated checks, and map each finding to the standard this rule points to.
Fix the barriers that block access. Our developers remediate structure, keyboard access, forms, contrast, names, and media in your codebase, starting with the journeys that gate a service.
Document what was tested. You receive the findings, what we fixed, and the statement or conformance report your team, counsel, or procurement office needs on file.
Keep it from slipping. We train publishers and retest after significant releases so new content does not reopen the same gaps.

Longer background: AODA website compliance in Ontario.

Frequently asked questions

We have fewer than 50 Ontario employees. Can we ignore the website rules?

The IASR website requirement does not apply below that threshold. You may still have AODA customer-service duties, and the Human Rights Code can apply to an inaccessible service. If you also sell into Manitoba, the U.S., or the EU, those laws can apply to the same site.

Is WCAG 2.0 AA enough?

It meets the IASR text. It does not meet Manitoba’s WCAG 2.1 AA rule, the ADA Title II rule, or the European Accessibility Act. We audit to the newer level so one remediation serves every market you actually sell into.

What triggers an AODA penalty?

Failing to comply with a standard, and filing a false or misleading compliance report. Ontario runs desk audits and inspections. Fines for corporations reach $100,000 per day.

Do you file the report for us?

The organization files its own report. We give you the audit evidence and a clear status so the person who signs it is not guessing.

Related guides

This page is general information from Peradeo Technologies Inc., not legal advice.

Talk with us about this requirement · hello@peradeo.com · +1 (306) 216-9934