The short version
If your organisation is in the Ontario public sector, or is a business or non-profit with 50 or more employees, your website and web content must conform to WCAG 2.0 Level AA. That deadline passed on 1 January 2021 — it is a current obligation, not an upcoming one.
Separately, if you have 20 or more employees, you must file an accessibility compliance report with the province. 2026 is a reporting year, and the deadline is 31 December 2026.
Two success criteria that are normally part of Level AA are specifically excluded by the regulation. Most checklists miss this. They are listed below.
What the AODA actually requires
The Accessibility for Ontarians with Disabilities Act is the statute. The rules that bind you sit in a regulation made under it — the Integrated Accessibility Standards Regulation (IASR, O. Reg. 191/11). The IASR covers five standards: Information and Communications, Employment, Transportation, Design of Public Spaces, and Customer Service.
Websites fall under Information and Communications, at section 14. That section is short, and it is worth knowing precisely what it says, because it is narrower than most summaries suggest.
The standard is WCAG 2.0 — not 2.1, not 2.2
Ontario law references WCAG 2.0 Level AA. This surprises people, because WCAG 2.1 was published in 2018 and 2.2 in 2023. The regulation has not been updated to follow them.
This matters in both directions. You are not legally obliged in Ontario to meet WCAG 2.1 criteria such as reflow (1.4.10), text spacing (1.4.12) or non-text contrast (1.4.11). But most organisations target 2.1 AA anyway — it is what procurement documents increasingly ask for, what other jurisdictions require, and what actually reflects how people use sites on phones. Meeting 2.0 AA is the legal floor. Meeting 2.1 AA is the sensible target.
The two criteria you are exempt from
Section 14 excludes two Level AA success criteria from the requirement:
- 1.2.4 Captions (Live) — you are not required to caption live audio content such as streamed council meetings.
- 1.2.5 Audio Description (Pre-recorded) — you are not required to provide audio description for pre-recorded video.
Both remain good practice, and live captioning of public meetings is increasingly expected regardless. But neither is a legal requirement under the IASR, and a consultant who tells you otherwise has not read section 14.
What content is covered
The requirement applies to websites and web content you control directly, or through a contractual relationship that allows modification. It applies to content published after 1 January 2012. Content posted before that date is outside the requirement, though it is still reachable by the public and still a barrier.
Who must comply
Two different thresholds apply, and they are easy to confuse:
- Website conformance (WCAG 2.0 AA) — designated public sector organisations, and businesses and non-profits with 50 or more employees in Ontario.
- Accessibility compliance reporting — every organisation with 20 or more employees, public or private.
So an organisation with 30 employees must file a report, but is not bound by the website conformance requirement. An organisation with 60 is bound by both.
Employee counts are based on employees in Ontario. Organisations with fewer than 20 employees have obligations under other parts of the AODA, but neither of the two above.
The 31 December 2026 reporting deadline
Accessibility compliance reports are filed every few years, and 2026 is a reporting year. If you have 20 or more employees, your report is due by 31 December 2026.
The report is a self-declaration filed through the province. It is short. The difficulty is not the filing — it is that signing it commits you, in writing, to statements about your website that may not currently be true. Organisations that have never audited their site are attesting to a conformance level nobody has measured.
If you are going to check one thing before filing, check the site. That is the part of the declaration most likely to be wrong.
The checklist
Worked through in the order that tends to surface the most problems fastest. WCAG 2.0 success criteria are named so you can cite them in a report or hand them to a developer.
1. Forms tell people when something goes wrong
Every field has a programmatic label, not just visible placeholder text. When submission fails, the error is announced to screen-reader users, identifies which field failed, and says how to fix it. This is the single most common blocking failure on municipal and institutional sites — someone can fill in your entire contact form, press submit, and be told nothing at all.
SC 3.3.1, 3.3.2, 3.3.3, 1.3.1, 4.1.2
2. Everything works from the keyboard
All functionality is operable without a mouse. Focus is always visible. Tab order follows the visual order. Nothing traps focus — menus, modals and embedded widgets are the usual offenders.
SC 2.1.1, 2.1.2, 2.4.3, 2.4.7
3. Text contrast meets the ratios
4.5:1 for normal text, 3:1 for large text (18pt, or 14pt bold). Check text over background images and gradients, which automated tools cannot measure and therefore silently skip. Colour is never the only way information is conveyed.
SC 1.4.1, 1.4.3
4. Images carry real alternative text
Meaningful images describe their content or function. Decorative images are marked so assistive technology skips them. Charts and infographics have a text equivalent — alt text of "chart" conveys nothing.
SC 1.1.1
5. Headings and landmarks describe the page
One h1, levels that descend without skipping, and headings that describe the section rather than decorate it. Main, navigation and footer landmarks are present. Screen-reader users navigate by heading far more than by reading top to bottom.
SC 1.3.1, 2.4.1, 2.4.6
6. Links and buttons say where they go
Link text makes sense read on its own, out of context. "Read more" repeated eleven times down a page tells a screen-reader user nothing. Icon-only buttons have accessible names.
SC 2.4.4, 4.1.2
7. Language is declared
Every page declares its language. On bilingual sites — most Ontario municipalities — French passages inside an English page need their own language marking, or a screen reader reads French with English pronunciation rules and the result is unintelligible.
SC 3.1.1, 3.1.2
8. Text can be resized
Text can be enlarged to 200% without loss of content or function. Note that reflow at 320px (SC 1.4.10) is a WCAG 2.1 criterion, so it is best practice rather than an Ontario legal requirement — but on a site most people reach by phone, it matters more than its legal status suggests.
SC 1.4.4
9. Pre-recorded media has captions
Pre-recorded video needs captions and pre-recorded audio needs a transcript. Remember the two exemptions: live captioning and audio description are not required under the IASR.
SC 1.2.1, 1.2.2, 1.2.3
10. Behaviour is predictable
Navigation stays in the same place across pages. Components that look the same behave the same. Focusing or changing a field does not trigger an unexpected change of context.
SC 3.2.1, 3.2.2, 3.2.3, 3.2.4
11. Test with assistive technology, not only a scanner
Run a keyboard-only pass and a screen-reader pass with NVDA or JAWS. This is where the failures that actually stop people get found.
Manual testing — no single SC
Automated testing reliably detects roughly a third of WCAG issues. It is very good at the mechanical ones — missing alt attributes, unlabelled fields, contrast on flat backgrounds, duplicate IDs, heading order.
It cannot judge whether alt text is accurate, whether a form's error message is understandable, whether tab order is logical, or whether your video captions are correct. It also silently gives up on things it cannot measure — text over a gradient, for instance, is reported as "needs review" rather than pass or fail, and it is easy to read a clean scan as a clean site.
A scan is the right first step and a poor last one. Use A11ytek Monitor or any axe-based tool to clear the mechanical layer, then test manually for the rest.
Documents count as web content
The Information and Communications standard covers web content, and that includes the documents you publish — PDFs, Word files, spreadsheets and presentations. A council agenda posted as an untagged PDF is as much a barrier as an inaccessible page, and on many public sector sites the documents outnumber the pages.
Tagging structure, reading order, alternative text, table headers and document language all apply. Our PDF accessibility checklist covers the document side in detail.
Penalties, stated accurately
You will see the figure "$100,000 per day" quoted often, usually by vendors selling something. It is worth being precise about what it means.
That figure is the statutory maximum on conviction for a corporation — the ceiling a court could impose, not a routine outcome. Day-to-day AODA enforcement is administrative: the province issues director's orders and administrative penalties, and the amounts are far smaller. Prosecution of an organisation over website conformance is not the ordinary path.
The realistic exposure is different, and in our experience more persuasive: a complaint from a resident, a failed procurement because you could not produce a conformance statement, a report you have signed that turns out to be inaccurate, and the plain fact that people who need your service cannot use your site.