AODA and your website: what Ontario businesses should know
What the Accessibility for Ontarians with Disabilities Act asks of business websites: who must meet WCAG 2.0 Level AA, what counts as web content, the reporting rule, and how to plan the work.
Ontario's accessibility law covers private businesses as well as the public sector. If your organization has employees in Ontario, the Accessibility for Ontarians with Disabilities Act (AODA) may set rules for your website. This guide summarizes what the law and its regulation say about websites, based on the Government of Ontario's own pages. It is general information, not legal advice; for questions about your organization, check the official sources below or speak to a lawyer.
What is the AODA?
The Accessibility for Ontarians with Disabilities Act, 2005 set the goal of an accessible Ontario by 2025. The detailed rules are in accessibility standards made under the Act. Most of them are in one regulation, the Integrated Accessibility Standards Regulation (Ontario Regulation 191/11), which covers information and communications, employment, transportation, the design of public spaces and customer service.
Website rules are part of the Information and Communications Standards in that regulation. Other parts of the regulation can also affect your website, for example the requirement to provide information in accessible formats when someone asks for it.
Does the website rule apply to your organization?
The website requirement in section 14 of the regulation applies to designated public sector organizations and to large organizations. The regulation defines a large organization as one with 50 or more employees in Ontario, and a small organization as one with at least one and fewer than 50 employees in Ontario.
For large organizations and designated public sector organizations, the regulation sets out that:
- new internet websites and web content on those sites had to meet WCAG 2.0 Level A from January 1, 2014;
- all internet websites and web content had to meet WCAG 2.0 Level AA from January 1, 2021, except for two success criteria: live captions (1.2.4) and pre-recorded audio descriptions (1.2.5).
The requirement applies to websites and web content, including web-based applications, that the organization controls directly or through a contractual relationship that allows for modification of the product. It applies to web content published on a website after January 1, 2012. The regulation allows exceptions where meeting the requirement is not practicable.
Small organizations are not covered by the section 14 website requirement, but other parts of the regulation still apply to them. Every organization with at least one employee in Ontario has customer service duties under the regulation, and must provide or arrange accessible formats and communication supports when a person with a disability asks.
What does WCAG 2.0 Level AA ask for?
WCAG, the Web Content Accessibility Guidelines, is published by the World Wide Web Consortium (W3C). Its success criteria are grouped under four principles: content must be perceivable, operable, understandable and robust. Level AA includes every Level A criterion plus the AA ones. In practice, these are the areas that most often need work on a business website:
- Text alternatives: meaningful alt text for informative images.
- Captions: captions for pre-recorded video. (Live captions are excepted under the Ontario rule.)
- Colour contrast: at least 4.5:1 for normal text and 3:1 for large text.
- Keyboard access: every function works without a mouse, with a visible focus indicator.
- Structure: proper headings, lists and labels, so screen readers can announce the page correctly.
- Forms: clear labels and error messages that explain how to fix the problem.
- Consistency: navigation that appears in the same place and works the same way on every page.
WCAG has been updated since 2.0. Version 2.1 was published in 2018 and version 2.2 in October 2023. W3C states that content that conforms to WCAG 2.2 also conforms to 2.0 and 2.1, so building to WCAG 2.2 Level AA is a sensible way to meet the Ontario requirement and the current version of the guidelines at the same time.
Do you have to report on accessibility?
Yes, if your organization is large enough. Ontario's guidance says that businesses and non-profit organizations with 20 or more employees in Ontario must file an accessibility compliance report every three years, confirming whether they are meeting their requirements under the AODA. Designated public sector organizations have their own reporting schedule. The Government of Ontario's pages explain how to file and when your next report is due.
What about the federal Accessible Canada Act?
The Accessible Canada Act is a separate federal law that came into force in 2019. It applies to the Government of Canada and to federally regulated private sector organizations, such as banks, telecommunications companies and interprovincial transportation providers. If your business is federally regulated, check the federal requirements as well as Ontario's. Most Ontario businesses are provincially regulated, so the AODA is the law that applies to them.
How do you plan the work on an existing website?
A practical order of work for an existing site:
- Inventory. List your website, any subdomains, web apps, online forms and important documents such as PDFs.
- Audit. Combine an automated scan with manual testing using a keyboard and a screen reader. Automated tools find only part of the problems.
- Prioritize. Fix the pages and tasks people use most first: the home page, contact and booking forms, product pages and checkout.
- Fix templates, not just pages. Most problems come from shared templates and components, so fixing them once fixes them everywhere.
- Train editors. The people who add content need to know how to write alt text, use headings and caption videos.
- Keep a record. Note what you tested, what you fixed and what remains, and publish a way for visitors to report problems.
If you are building a new site, write WCAG 2.2 Level AA into the requirements from the start. It costs far less to design accessible colours, focus states and forms than to change them after launch. Our website development in Canada page explains how we work, and our UI/UX design service covers accessible design reviews. You can also contact us to discuss an audit of your current site.
Sources
Questions we hear often.
Does the AODA website rule apply to small businesses?
The section 14 website requirement applies to designated public sector organizations and to large organizations, defined as 50 or more employees in Ontario. Small organizations still have other duties under the regulation, such as providing accessible formats on request.
Which version of WCAG does Ontario require?
The regulation refers to WCAG 2.0. Large organizations had to meet Level AA from January 1, 2021, except for live captions and pre-recorded audio descriptions. W3C states that content meeting WCAG 2.2 also meets 2.0.
Does the rule cover old content on my website?
The requirement applies to web content published on a website after January 1, 2012. The regulation also allows exceptions where meeting the requirement is not practicable. Check the official text for the exact wording.
Do PDFs on my website need to be accessible?
Documents you publish as web content can fall under the requirement, and anyone can ask you for information in an accessible format. Where possible, publish important information as accessible web pages rather than only as PDFs.
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