AODA website requirements for Ontario businesses
Short answer: Ontario businesses and non-profits with 50 or more employees and designated public sector organizations are generally required to make covered public websites and web content meet WCAG 2.0 Level AA under the Integrated Accessibility Standards Regulation (O. Reg. 191/11, section 14). The regulation includes scope limits and exceptions; employee count alone does not settle every requirement.
Two different employee thresholds:
- 50 or more employees — your public website must meet the WCAG 2.0 Level AA website standard.
- 20 or more employees — you must file an accessibility compliance report with Ontario every three years (next deadline December 31, 2026), even if the website standard does not apply to you.
Who must comply
The website rule applies to businesses and non-profits with 50 or more employees, and to designated public sector organizations. Ontario’s reporting guidance uses the peak employee count in Ontario during the previous 12 months. Count full-time, part-time and seasonal employees; whether contract workers count depends on the employment relationship. Consult Ontario’s instructions for your organization.
What the standard requires
- For covered organizations, public websites and web content published after January 1, 2012 must conform to WCAG 2.0 Level AA.
- Two success criteria are excluded: live captions (1.2.4) and pre-recorded audio description (1.2.5).
- On request, you must provide information in an accessible format or with communication supports, in a timely way, at a cost no greater than the regular cost charged to others.
- Feedback processes (contact forms, phone, email) must be accessible.
WCAG 2.2 is the current W3C Recommendation, adding requirements such as minimum target size, focus not being obscured and accessible authentication. W3C states that content conforming to 2.2 also conforms to 2.0 and 2.1. Our remediation target is 2.2 Level AA; this is not a guarantee of conformance or a change to Ontario’s legal baseline.
What WCAG 2.0 AA means in practice
- Informative images need appropriate text alternatives; decorative images can use empty alt text.
- Everything works with a keyboard alone, with a visible focus indicator.
- Text has enough colour contrast (4.5:1 for normal text and 3:1 for large text, subject to criterion exceptions).
- Forms have labels and clear error messages.
- Pages have a logical heading structure, a page language, and descriptive titles.
- Pre-recorded synchronized media generally needs captions. Text must resize to 200% without loss of content or functionality, subject to criterion exceptions.
The December 31, 2026 compliance report
Businesses and non-profits with 20 or more employees must file an accessibility compliance report with the Province every three years. The next deadline is December 31, 2026. Reporting covers all applicable standards, not only the website. A person authorized to legally bind the organization certifies the report. Use Ontario’s current questions and guidance; our filing-prep worksheet is not the official form.
Website requirements apply to content the organization controls directly or through a contractual relationship that allows modification, unless meeting a requirement is not practicable as described in section 14. Pre-2012 content is outside this website rule, but accessible-format duties may still apply. See Ontario’s scope and exceptions guidance.
What happens if you don't comply
The Province can audit and inspect organizations, issue compliance orders, and impose administrative penalties. Under the Act, a corporation convicted of an offence can be fined up to $100,000 for each day the offence continues.
How to check your website
Start with an automated scan to find the obvious issues, then have a person test with a keyboard and screen reader — automated tools catch only part of WCAG. Our no-cost automated website scan uses Google PageSpeed mobile analysis on the submitted URL and Fortress HTML checks on up to 500 discoverable same-host pages. It may miss pages and issues; larger crawls take several minutes. No signup is required.
See also: How much does AODA website compliance cost? · AODA compliance review
Official sources
- O. Reg. 191/11, section 14 — Accessible websites and web content
- Ontario: How to make websites accessible
- Ontario: Completing your accessibility compliance report
- AODA, 2005, section 37 — Offences
- WCAG 2.0 (W3C)
- WCAG 2.2 (W3C)
This page is general information, not legal advice. Questions? colin@fortresswebcompliance.com
Last updated: October 2026