AODA Website Compliance Requirements: What Ontario Law Requires

Ontario's AODA requires organizations to make their websites accessible to WCAG 2.0 Level AA. These requirements have been in force for years — the deadline for organizations with 50 or more employees to make all public-facing web content compliant passed in January 2021.

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Ontario’s Accessibility for Ontarians with Disabilities Act requires organizations to make their websites accessible. The specific standard is WCAG 2.0 Level AA — the Web Content Accessibility Guidelines published by the World Wide Web Consortium, at the middle tier of compliance.

These requirements have been in force for years. The deadline for organizations with 50 or more employees to make all public-facing web content compliant passed in January 2021. If your website was built or significantly updated after those dates and has not been tested for accessibility, it is almost certainly non-compliant.

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The legal basis for website accessibility in Ontario

Website accessibility requirements in Ontario come from the Information and Communications Standard, Part II of the Integrated Accessibility Standards Regulation (IASR), Ontario Regulation 191/11. Section 14 requires designated public sector organizations and large private-sector organizations to make websites and web content conform to WCAG 2.0 Level AA.

The standard applies to all internet websites and web content an organization controls directly or through a contractual relationship that allows for modification of the product.

What 'controls directly or through a contractual relationship' means

If your website is built by an agency or hosted on a platform, you are still responsible for its accessibility. The fact that a third party built or manages your website does not transfer your AODA obligations to them. If you have the ability to modify content, design, or functionality — either directly or by instructing a contractor — the accessibility requirements apply to you.

This includes content management systems (WordPress, Drupal, Squarespace), e-commerce platforms (Shopify, WooCommerce), and booking systems where you control the content published on them.

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AODA website compliance deadlines by organization size

The IASR phased in website compliance requirements over several years. All deadlines have passed. Here is where each organization size stands in 2026.

Organization size	Requirement	Deadline	Status in 2026
1–49 employees (private sector)	New websites and significantly refreshed web content must meet WCAG 2.0 Level AA	January 1, 2014	Overdue — applies to all content created or significantly updated since January 2014
50+ employees (private sector)	All internet websites and web content must conform to WCAG 2.0 Level AA (excluding live captions and pre-recorded audio descriptions)	January 1, 2021	Overdue — all public-facing content must comply, including content created before 2014
Designated public sector organizations	All internet websites must conform to WCAG 2.0 Level AA	January 1, 2014 (new) / January 1, 2016 (existing)	Overdue — the strictest deadline of all organization types

For organizations with 1–49 employees, the requirement applies to content created or significantly updated since January 2014, not to all historical content. However, “significantly refreshed” is broadly interpreted — a redesigned homepage, a new service page, or substantially rewritten existing pages all fall within scope.

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What WCAG 2.0 Level AA requires

WCAG 2.0 Level AA consists of 38 success criteria organized under four principles. Every criterion is a testable pass/fail requirement. Here are the most commonly tested and most frequently failed criteria, written in plain language.

Principle 1: Perceivable — Content must be perceivable by all users

1.1.1 · Level A

Alternative text for non-text content

Every image that conveys information must have a text alternative (alt text) that serves the same purpose. Decorative images must have empty alt text (alt="") so screen readers skip them.

✓ Do Use descriptive alt text: alt="Bar chart showing quarterly revenue growth of 12% in Q4 2025"

✗ Don't Use filename as alt text: alt="img_20250401_chart.png" or leave alt attribute absent

1.2.2 · Level A

Captions for pre-recorded video

All pre-recorded video content with audio must have synchronized captions. Auto-generated captions from YouTube or similar platforms do not meet this requirement without review and correction.

✓ Do Provide accurate, reviewed captions that include speaker identification and non-speech audio cues

✗ Don't Use auto-generated captions without reviewing or correcting them for accuracy

1.3.1 · Level A

Information and relationships conveyed through structure

Information conveyed visually — headings, lists, tables, form labels — must also be conveyed through markup so assistive technologies can interpret it. Visual formatting alone is not sufficient.

✓ Do Use semantic HTML: <h2> for section headings, <ul>/<li> for lists, <label> for form fields

✗ Don't Use styled <div> elements to create visual headings without using heading tags

1.4.3 · Level AA

Colour contrast — minimum ratio

Text must have a contrast ratio of at least 4.5:1 against its background. Large text (18pt+ or 14pt+ bold) requires at least 3:1. This is the most frequently failed WCAG criterion.

✓ Do Check contrast ratios with a tool like the Colour Contrast Analyser before finalizing any design

✗ Don't Use light grey text on white backgrounds, or white text on pastel backgrounds

1.4.4 · Level AA

Text resize

Text must be resizable up to 200% without loss of content or functionality. Fixed-size text that breaks the layout when zoomed fails this criterion.

✓ Do Use relative units (em, rem, %) for font sizes rather than fixed pixel values

✗ Don't Set body text in px and use overflow:hidden on containers, causing text to be clipped when zoomed

Principle 2: Operable — Interface components must be operable

2.1.1 · Level A

Keyboard accessible

All functionality must be available using a keyboard alone. Users who cannot use a mouse — including many users with motor impairments and blind users navigating with screen readers — rely on keyboard access.

✓ Do Test every interactive element: links, buttons, dropdowns, modals, date pickers, carousels — all must be reachable and operable by Tab, Enter, arrow keys, and Escape

✗ Don't Build dropdown menus that require hover to reveal submenus with no keyboard equivalent

2.4.1 · Level A

Skip navigation

A mechanism must be provided to skip past repeated blocks of content (header, navigation) to reach the main content. Typically implemented as a "Skip to main content" link at the top of the page.

✓ Do Provide a visible or visually hidden skip link that becomes visible on keyboard focus

✗ Don't Include no skip link, forcing keyboard users to Tab through the entire navigation on every page load

2.4.6 · Level AA

Descriptive headings and labels

Headings and form labels must describe their topic or purpose. Vague headings ("Section 1", "More information") fail this criterion.

✓ Do Write headings that describe the content that follows: "AODA compliance deadlines by organization size"

✗ Don't Use generic headings like "Introduction" or "Section 3" that convey no information

Principle 3: Understandable — Content and operation must be understandable

3.3.1 · Level A

Error identification

If a form submission error is detected, the error must identify the field that failed and describe the problem in text, not colour alone.

✓ Do Show an error message next to the field: "Email address is required" or "Enter a valid date (DD/MM/YYYY)"

✗ Don't Highlight the field border in red with no text explanation of the error

3.3.2 · Level A

Labels or instructions

Form fields must have visible labels or instructions that describe the expected input before a user submits. Placeholder text inside form fields does not satisfy this requirement.

✓ Do Use <label> elements visible above or beside each form field; include format instructions where needed

✗ Don't Use only placeholder text (which disappears on input) as the label, with no persistent visible label

Principle 4: Robust — Content must be interpretable by assistive technologies

4.1.1 · Level A

Parsing — valid HTML

HTML must be well-formed and valid. Duplicate IDs, missing closing tags, and improperly nested elements can cause screen readers to misinterpret page content.

✓ Do Run HTML through a validator and fix parsing errors before publishing

✗ Don't Use duplicate id attributes on multiple page elements; leave elements unclosed

4.1.2 · Level A

Name, role, value for UI components

All user interface components — custom buttons, toggles, tabs, accordions — must have names, roles, and states that can be programmatically determined by assistive technologies. Custom components built without ARIA are typically failures.

✓ Do Use native HTML elements where possible; apply appropriate ARIA roles and attributes to custom components

✗ Don't Build a custom toggle switch using styled <div> elements with no ARIA role, state, or accessible name

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What is explicitly not required under AODA (yet)

The IASR includes two partial exceptions to the WCAG 2.0 Level AA requirement.

Exception	What it means	Who it applies to
Live captions	Live video content does not need to have real-time captions to meet the IASR requirement. However, captions are best practice and increasingly expected for live-streamed events, webinars, and broadcasts.	All organizations — applies to live-streamed events, webinars, and broadcasts
Pre-recorded audio descriptions	Pre-recorded video does not need audio descriptions (narration of visual content for blind users) to meet the current IASR. Audio descriptions will likely be required as Ontario updates to align with WCAG 2.1.	All organizations — applies to pre-recorded video with visual-only information

Critical point:

Automated tools alone catch only 30–40% of WCAG failures. The majority of accessibility issues — including those most likely to prevent users with disabilities from completing tasks — require human judgment to identify. A credible AODA audit always includes manual testing.

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The most commonly failed WCAG 2.0 Level AA criteria in Ontario

Every professional AODA website audit reveals a consistent pattern of failures. These are the criteria that generate the most findings across Ontario organizations in 2026.

WCAG criterion	Common failure	Why it matters
1.4.3 Colour Contrast	Light grey body text on white backgrounds; white text on medium-tone brand colours	Affects users with low vision and colour processing differences. Often requires design system changes across the entire site.
1.1.1 Non-text Content	Images with missing alt text, filename-based alt text, or alt text that does not describe the image's purpose	Prevents blind users from accessing any information conveyed visually. One of the highest-volume failure categories.
2.1.1 Keyboard Access	Dropdown navigation menus, modal dialogs, and date pickers that require a mouse to operate	Prevents users with motor impairments and keyboard-only users from accessing navigation and interactive features.
1.3.1 Info and Relationships	Visual headings styled with CSS but not using semantic heading elements; tables without proper headers	Screen readers cannot convey page structure to blind users without semantic markup.
4.1.2 Name, Role, Value	Custom interactive components (tabs, accordions, carousels, toggles) built without ARIA attributes	Screen reader users cannot identify or operate custom components without proper ARIA markup.
3.3.1 Error Identification	Form validation that highlights fields in red without a text description of what went wrong or how to fix it	Users with colour blindness cannot perceive the error state; screen reader users receive no error information.
2.4.4 Link Purpose	"Read more", "Click here", and "Learn more" links without surrounding context	Screen reader users often navigate by scanning a list of links. Vague link text provides no meaningful destination information.
1.2.2 Captions	Video content with auto-generated captions that have not been reviewed for accuracy	Inaccurate captions fail Deaf and hard-of-hearing users. Auto-generated captions routinely have 10–30% error rates.

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Frequently asked questions

Does AODA apply to our website if we are a small business?

Yes, if you have at least one employee and operate in Ontario. For organizations with 1–49 employees, the AODA requires that web content created or significantly updated after January 1, 2014 meets WCAG 2.0 Level AA. If your website was built or significantly redesigned since 2014 and has not been tested for accessibility, the requirement applies to it.

Does AODA cover our mobile app as well as our website?

The IASR’s website requirements are written in terms of “internet websites and web content.” Native mobile applications (apps downloaded from an app store) are not explicitly covered by the IASR’s website requirements. However, web-based apps and mobile-optimized websites are covered. As accessibility law evolves, mobile app accessibility is likely to be explicitly addressed.

Our website was built before 2014. Do we need to make it accessible?

For organizations with 50 or more employees, yes — all public-facing web content must now meet WCAG 2.0 Level AA regardless of when it was created. The 2021 deadline covers all existing content. For organizations with fewer than 50 employees, content created before January 2014 is technically outside the IASR’s scope, but significantly refreshing older content brings it into scope. A redesigned page is new content.

We use a website builder (Squarespace, Wix, Shopify). Are we still responsible?

Yes. Your AODA compliance obligations follow your organization, not the platform. Website builders vary significantly in how well they support accessible development — some generate inaccessible HTML by default. You are responsible for ensuring the content you publish and the templates or themes you choose meet WCAG 2.0 Level AA.

What is the difference between WCAG 2.0 Level A and Level AA?

WCAG 2.0 has three conformance levels: A (minimum), AA (standard), and AAA (enhanced). Level A covers the most fundamental barriers. Level AA builds on Level A and adds requirements that address the most significant remaining barriers. AODA requires Level AA. Level AAA is not required by AODA and is generally considered impractical to achieve across an entire website.

How is AODA website compliance enforced?

Enforcement happens through the Accessibility Directorate of Ontario. Organizations can be audited randomly or following a complaint. If a compliance review identifies gaps, the organization receives a compliance order specifying what must be corrected. Failure to comply can result in fines of up to $100,000 per day for organizations and $50,000 per day for individuals.

On this page

01 Legal basis for website accessibility 02 Compliance deadlines by org size 03 What WCAG 2.0 Level AA requires 04 What is not yet required 05 Most commonly failed criteria 06 FAQs

Find out whether your website meets WCAG 2.0 Level AA

The only way to know for certain whether your website meets AODA requirements is to test it. Our website accessibility audit covers every testable WCAG 2.0 Level AA criterion — automated scanning, manual testing, and screen reader evaluation — and delivers a prioritized report your development team can work from directly.

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AODA Website Compliance Requirements: What Ontario Law Requires

Quantity Discounts

Price per course

6 to 20 courses

$20.95

21 to 50 courses

$17.95

51 to 200 courses

$13.95

201+ courses

Custom offer

The legal basis for website accessibility in Ontario

AODA website compliance deadlines by organization size

What WCAG 2.0 Level AA requires

Principle 1: Perceivable — Content must be perceivable by all users

Principle 2: Operable — Interface components must be operable

Principle 3: Understandable — Content and operation must be understandable

Principle 4: Robust — Content must be interpretable by assistive technologies

What is explicitly not required under AODA (yet)

The most commonly failed WCAG 2.0 Level AA criteria in Ontario

Frequently asked questions

Find out whether your website meets WCAG 2.0 Level AA

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