Short answer: under the Accessibility for Ontarians with Disabilities Act (AODA), businesses and non-profits with 50 or more employees in Ontario, and designated public sector organizations, must make their public websites and web content meet WCAG 2.0 Level AA. That requirement has applied since January 1, 2021. Separately, organizations with 20 or more employees must file an accessibility compliance report, and the next one for businesses is due December 31, 2026.
This guide explains who’s covered, what WCAG 2.0 AA actually asks of a website, and the practical steps to get a site there. It isn’t legal advice; for your organization’s specific obligations, check the Government of Ontario’s guidance or speak to a lawyer.
Who the AODA website rules apply to
According to the province’s guidance, the website requirement applies to:
- Designated public sector organizations
- Businesses and non-profit organizations with 50 or more employees in Ontario
The organization that controls the website, directly or through a contract, is responsible. That means hiring an agency doesn’t move the obligation to the agency; it stays with you, so your contracts should say which standard the site must meet.
The rules cover public websites and web content published after January 1, 2012. Internal sites such as intranets are exempt for most organizations.
If you have fewer than 50 employees, the website requirement doesn’t apply to you under the AODA. Accessibility is still worth doing: an accessible site is easier for everyone to use, works better on mobile, and tends to be cleaner technically, which helps search too.
What “WCAG 2.0 Level AA” means in plain English
The Web Content Accessibility Guidelines (WCAG) are an international standard published by the W3C. They’re organised around four principles: content must be perceivable, operable, understandable and robust. Each guideline has success criteria at levels A, AA and AAA. “Level AA” means meeting every A and AA criterion.
The AODA makes two exceptions: live captions (criterion 1.2.4) and pre-recorded audio descriptions (1.2.5) aren’t required.
WCAG has moved on since 2.0. The current version is WCAG 2.2, which adds criteria (for example, about focus visibility and target sizes) and removed one obsolete criterion. Building to 2.2 AA is sensible for new work: it covers what 2.0 AA asks for on modern sites and gets you ahead of where standards are going. That’s the level we target on every website we build.
What AA looks like on a real website
Most accessibility failures on small and mid-sized business sites fall into a familiar handful. Here’s what to check, in roughly the order we find problems.
Images and media
- Meaningful images have alternative text that says what the image communicates. Decorative images have empty alt text so screen readers skip them.
- Pre-recorded videos with speech have captions. Auto-generated captions need checking; they’re often wrong on names and technical terms.
- Nothing important is shown only as text inside an image, such as offers baked into a banner graphic.
Colour and contrast
- Body text has a contrast ratio of at least 4.5:1 against its background; large text at least 3:1.
- Colour isn’t the only way information is shown. A red border on an invalid form field needs a text message too.
Keyboard and focus
- Every link, button, menu and form can be reached and used with the keyboard alone.
- The keyboard focus is clearly visible. Many themes remove the focus outline for looks; that’s a failure.
- Pop-ups and menus don’t trap the keyboard, and focus returns sensibly when they close.
Structure and navigation
- Each page has one clear H1 and headings in a logical order, so screen-reader users can skim.
- Link text makes sense on its own. “Read more” repeated ten times doesn’t.
- Pages have meaningful titles and the page language is set.
Forms
- Every field has a visible, programmatically associated label. Placeholder text isn’t a label.
- Errors are described in text, next to the field, with a way to fix them.
- Required fields are marked in text, not just with colour or an asterisk that isn’t explained.
Documents
PDFs published on your site count as web content. Price lists, menus and spec sheets are common gaps. Either make them accessible or publish the information as a web page as well.
How to check your own site
Start with three quick tests anyone can do:
- Tab through your home page. Can you see where you are at every step? Can you open the menu and submit the contact form without a mouse?
- Zoom to 200%. Does the text reflow, or does content overlap and disappear?
- Turn images off (or use a screen reader’s image list). Does each image still make sense from its alt text?
Then run an automated scan. Our free accessibility check tests a page against rules that can be checked automatically and shows the evidence for each finding. Automated tools are useful but limited: they can’t judge whether alt text is accurate or whether a journey makes sense. That’s why a manual review matters before you sign a compliance report.
Our Accessibility Audit is a manual WCAG review of key pages and journeys, beyond automated checks, for $99. It’s listed on our pricing page.
The accessibility compliance report
The compliance report is a separate obligation from the website standard, and it catches a wider group. Businesses and non-profits with 20 or more employees in Ontario must complete one every three years; the next deadline is December 31, 2026. Public sector organizations report every two years.
The province warns that not completing a report can lead to enforcement measures, which can include financial penalties. The AODA itself allows fines for corporations of up to $100,000 for each day an offence continues. The practical point: if you’ll be confirming website compliance in your 2026 report, the time to fix the site is before you file it.
A practical path to compliance
- Inventory. List your public site, subdomains, booking or e-commerce platforms and key PDFs. Third-party tools embedded on your site still affect your users.
- Test. Combine an automated scan with manual checks of your most-used journeys: finding a service, contacting you, booking or buying.
- Prioritise. Fix what blocks people first: inaccessible forms, keyboard traps and missing labels. Then work through contrast, headings and alt text.
- Fix the system, not just the page. If the theme’s buttons fail contrast, fix the theme once rather than each page.
- Record what you did. Ontario’s guidance suggests keeping records of completed work and the resulting level of accessibility.
- Keep it compliant. Every new page, plugin and campaign can reintroduce problems. Build accessibility checks into publishing and maintenance. Our CHRISPS Care plans include a monthly health check reviewed by a person.
If the audit shows deep problems (an old theme, page builders fighting each other, broken markup everywhere), repairing may cost more than rebuilding. Our guide on redesign versus rescue helps with that call, and our website rescue service starts with a $199 plan that tells you which route is cheaper.
Frequently asked questions
Does the AODA apply to my small business website?
The website requirement applies to businesses and non-profits with 50 or more employees, and to designated public sector organizations. Smaller organizations aren’t required to meet WCAG 2.0 AA under the AODA, though other AODA standards (such as customer service) may still apply.
Is an accessibility overlay or widget enough?
No. Overlays add a toolbar on top of the site but don’t fix the underlying code, labels or structure that WCAG is about. Fix the site itself.
We’re building a new site. What should we ask our developer for?
Put the standard in the contract: WCAG 2.2 Level AA (which covers what AODA requires), tested with keyboard and screen reader before launch, with a short report of what was checked.
Find out where your site stands
Run the free accessibility check on your home page and contact page today. If you need confidence before your compliance report, book an Accessibility Audit or start a project and we’ll scope the fixes.
Written by the CHRISPS studio in Cambridge, Ontario. AODA thresholds and deadlines are taken from the Government of Ontario’s published guidance at the time of writing; always check the current guidance for your organization.