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Since January 1, 2021, Ontario organizations with 50 or more employees in Ontario must make their public websites conform to WCAG 2.0 Level AA under the AODA. Here is who it covers, what it actually requires, and how to check your site.
Updated · 3 min read
The AODA's web accessibility requirements apply to private sector and non-profit organizations with 50 or more employees in Ontario, and to all public sector organizations. The employee count is the Ontario headcount, so a large company with a small Ontario team may still be a small organization under the rules. Since January 1, 2021, their public websites and the web content published on them after January 1, 2012 must conform to WCAG 2.0 Level AA.
If you are under 50 employees, the specific WCAG deadline does not bind you, but the Ontario Human Rights Code still does, and roughly one in four adults in Ontario lives with a disability. Inaccessible checkout flows and forms are lost customers regardless of headcount.
WCAG 2.0 Level AA is a testable standard, not a vibe. In practice the failures we see most are: text that fails minimum contrast against its background, forms with no programmatic labels, images without meaningful alternative text, pages that cannot be operated by keyboard alone, and videos without captions.
The regulation exempts two success criteria outright: live captions and pre-recorded audio description. The rest of Level AA applies, except where meeting a requirement is genuinely not practicable, which the regulation allows an organization to demonstrate rather than assume.
On conviction, the maximums are steep: up to $100,000 a day for a corporation, and up to $50,000 a day for a director or officer who fails their duty of care. The administrative penalties a director can issue day to day are far smaller, topping out at $15,000 for a corporation on the published schedule.
Those offence provisions cover things like filing a false accessibility report or ignoring an order, so a non-conforming website is not itself an offence. The exposure runs through the report and order process, which means the realistic near-term risk is being caught unprepared by a reporting cycle, a complaint, or a lawsuit.
The quieter cost is commercial: an inaccessible site turns away real customers every day and increasingly reads as a quality signal to both buyers and search engines.
Start with an automated scan; it will catch the mechanical failures like contrast, missing labels, and missing alt text in minutes. Nockta builds AdaChecked, which scans a site against WCAG 2.2 AA and returns an audit-ready report. The first scan is free and does not ask for a card.
Then do the two manual tests automation cannot: put the mouse away and complete your most important flow, from landing to checkout or form submission, by keyboard alone; and run a screen reader over the same flow. Automated tools catch a meaningful share of issues, but the blocking failures usually live in those two tests.
Most WCAG failures are markup-level: labels, contrast tokens, heading structure, focus states, and alt text. Fixing the templates fixes every page they render, so remediation is usually a scoped project measured in weeks, not a rebuild.
Every obligated organization in Ontario, from one employee up, has to develop and maintain accessibility policies. At 50 or more employees those policies must also be in writing, publicly available, and include a statement of organizational commitment. Organizations with 20 or more employees file accessibility compliance reports with the province on its published cycle, so keep that date on someone's calendar.
The WCAG 2.0 AA website requirement applies at 50 or more employees. Smaller organizations still carry general obligations under the AODA and the Ontario Human Rights Code, and accessibility failures cost customers at any size.
The regulation names WCAG 2.0 Level AA. The newer 2.1 and 2.2 standards are backwards compatible and where enforcement and best practice are heading, so new builds should target them; meeting 2.2 AA means you meet the legal bar with room to spare.
No. Overlay toolbars do not fix the underlying markup, are widely criticized by actual assistive-technology users, and have not protected companies from complaints. Fix the templates instead; it is usually less work than it sounds.
The primary documents the numbers in this guide come from.
Law 25 applies to any business that collects personal information from people in Quebec, whether or not it has an office there. Since September 22, 2023 that means a published privacy policy, a named privacy officer, consent that is specific and separate, and tracking that stays off until the visitor turns it on. Administrative penalties reach the greater of $10 million or 2 percent of worldwide turnover.
Custom softwareRedesign when the problem is how the site looks and reads; rebuild when the problem is what the site cannot do. The tell is the workaround list: if the team keeps more than a handful of manual steps, plugins or spreadsheets propping the site up, a redesign buys about a year before the same conversation. Here is how to decide, and what each one costs.
Hiring and costMost bad web projects in Ontario fail on the same four things: who owns the code, who actually writes it, what happens after launch, and whether the quote includes the work that always appears later. Here are the questions that surface all four.
Nockta builds ecommerce, custom software, and Amazon operations for businesses across Ontario and Quebec. See where we work or the full service list.