New/refreshed websites must meet WCAG 2.0 A
Since 1 January 2014, all new public-sector websites and significantly refreshed internet websites must conform to WCAG 2.0 Level A.
AODA
Canada · Ontario
What is the AODA?
The Accessibility for Ontarians with Disabilities Act 2005 is the most mature provincial accessibility law in Canada — with an explicit target of a fully accessible Ontario by 2025 and hard WCAG conformance requirements enforced by law.
Enacted
13 June 2005
Enforced by
Ministry for Seniors & Accessibility
Technical target
WCAG 2.0 Level AA
Threshold
50+ employees
The Accessibility for Ontarians with Disabilities Act (AODA) was passed in 2005 with the statutory goal of making Ontario fully accessible by 1 January 2025. It is implemented through the Integrated Accessibility Standards Regulation (IASR, O. Reg. 191/11), which contains five standards: Customer Service, Information and Communications, Employment, Transportation and Design of Public Spaces.
For digital accessibility, the Information and Communications Standard is the operative part. It requires both public-sector and larger private-sector organisations to make their websites, web content and mobile-delivered content conformant with WCAG 2.0 Level AA — with a specific exclusion for live captions and pre-recorded audio description.
Enforcement sits with the Ministry for Seniors and Accessibility, which administers compliance reporting, audits and orders. The AODA also establishes the License Appeal Tribunal (Accessibility Division) to hear appeals of orders and penalties.
Unlike the ADA in the United States, AODA is a prescriptive regulatory regime, not a civil-rights statute. It operates on the logic of prescribe, report, audit, fine — closer in structure to GDPR than to ADA case law.
Scope
Who must comply?
AODA applies to every organisation that provides goods, services, facilities, accommodation, employment, buildings, structures or premises in Ontario — whether public or private, for-profit or non-profit.
Broad public sector. All Government of Ontario ministries and agencies, municipalities, hospitals, school boards, colleges, universities, and public transportation organisations. These entities face the earliest and strictest compliance dates and must file annual compliance reports.
Designated public-sector organisations. 200+ organisations listed in the regulation, including public libraries, conservation authorities and children’s aid societies.
Large private-sector and non-profit organisations. Any organisation with 50 or more employees in Ontario. Bound by the Information and Communications Standard including the WCAG 2.0 AA web requirement. Must file compliance reports every three years.
Small organisations (1–49 employees). Bound by the Customer Service Standard and most Information and Communications requirements, but NOT the WCAG 2.0 AA web-content requirement. Not required to file compliance reports but can be audited on complaint.
Volunteers count. The employee count includes volunteers, contractors and seasonal staff. Many charities and arts organisations are caught by the 50-employee threshold for this reason.
Key requirements
What AODA actually requires
The Information and Communications Standard has specific, prescriptive requirements. It is not a “reasonable endeavours” regime — conformance is auditable and orders can be issued for failures.
All websites must meet WCAG 2.0 AA
Since 1 January 2021, all public-sector and large-private internet websites and web content must conform to WCAG 2.0 Level AA (excluding live captions and pre-recorded audio description).
Accessible feedback mechanisms
Processes for receiving and responding to feedback must be accessible — with accessible formats and communication supports available on request.
Accessible formats on request
All public-sector content and, where practicable, all private-sector content must be available in accessible formats and communication supports on request, without extra cost, in a timely manner.
Educational and training resources
Producers of educational or training resources must provide accessible versions or conversion-ready formats to educators and learners on request.
Training for staff
All staff, volunteers and agents who develop policies or provide services must be trained on the IASR and on the Ontario Human Rights Code. Training must be documented.
Emergency procedures and public-safety info
Emergency procedures, plans and public-safety information available to the public must be provided in accessible formats on request.
Accessible library resources
Public and educational libraries must provide accessible or conversion-ready formats of print resources and digital/multimedia resources on request.
Public libraries — digital resources
Public libraries must provide access to or arrange for the provision of accessible materials where they exist.
Multi-year accessibility plan
Designated public-sector and large-private organisations must establish, implement and maintain a multi-year accessibility plan. Post on website. Review every five years.
Penalties & enforcement
What non-compliance costs
AODA has real financial teeth. The maximum penalties are among the highest in Canadian accessibility law and are levied through administrative orders rather than civil litigation.
$100,000
Corporate daily maximum
Up to CAD 100,000 per day for a corporation found in violation of an administrative order under the AODA. Section 21 of the Act.
$50,000
Officer/director daily maximum
Up to CAD 50,000 per day for a director or officer of a corporation where the organisation is in violation of an order.
$15M+
Record highest cumulative fine
Individual orders can compound day-over-day. The highest publicly reported fines have exceeded CAD 15M when pro-rated over months of non-compliance.
Compliance reporting regime. Designated public-sector and large-private organisations must file a compliance report every 3 years (private) or annually (public). Failure to file itself triggers an order and, if unresolved, financial penalty.
Random audits. The Ministry conducts proactive audits by sector (e.g. universities in 2023, credit unions in 2024). Organisations are selected by size, sector and compliance-history. An audit that reveals WCAG 2.0 AA non-conformance on a public website produces an order with a remediation deadline — typically 30–90 days.
Complaints. Members of the public can file an AODA complaint via ServiceOntario. Each complaint triggers an inspection. Complaint volume has grown steadily since the 2021 public-sector deadline.
Deadlines
Key AODA compliance dates
AODA rolled out requirements in tranches between 2012 and 2021. The central web-accessibility deadline (WCAG 2.0 AA for all bound websites) has now passed — everything you ship must meet it from day one.
13 June 2005
AODA signed into law
Goal: a fully accessible Ontario by 1 January 2025. Framework for five standards.
1 January 2012
Customer Service Standard enforceable
Initially a separate regulation, later integrated. First standard in force.
1 July 2011
Integrated Accessibility Standards Regulation
Consolidated regulation O. Reg. 191/11 takes effect, structuring remaining standards.
1 January 2014
WCAG 2.0 Level A required
New public-sector websites and significantly refreshed sites must meet WCAG 2.0 Level A.
1 January 2021
WCAG 2.0 Level AA required
All public-sector and large-private websites and web content must meet WCAG 2.0 Level AA. This is the current operative requirement.
1 January 2025
Full accessibility goal date
Statutory target for a fully accessible Ontario. Marked the end of AODA’s original 20-year horizon; review and renewal of the framework is ongoing.
Post-2025
Expected update to WCAG 2.1 or 2.2
Reviews by successive Ontario governments have recommended updating the web reference to WCAG 2.1 or 2.2 AA. Formal amendment expected; no date confirmed.
How to comply
Your AODA compliance checklist
AODA is the rare regime where the legal requirement is precisely aligned with a WCAG conformance audit. Pass WCAG 2.0 AA and file your compliance report on time and you are, on paper, compliant.
Confirm you’re in scope
Public sector (any size): yes. Private/non-profit with 50+ Ontario employees: yes. Smaller private: Customer Service + some Info and Comms requirements only.
Audit your website against WCAG 2.0 Level AA
Excluding 1.2.4 (Captions — live) and 1.2.5 (Audio Description — prerecorded). Everything else is required.
Audit PDFs and documents served from your site
Not explicitly WCAG-mandated for documents, but the “accessible formats on request” rule means your proactive PDFs must be accessible or you’ll be doing costly one-off conversions.
Publish an accessibility plan
Multi-year plan published on your website. Progress report at least every 5 years. Statement of organisational commitment to accessibility.
Train all staff, volunteers and agents
Train on both the IASR and the Ontario Human Rights Code. Document who was trained, when and what was covered. Ministry asks for training logs in audits.
File compliance reports on schedule
Designated public-sector: annual. Large-private and non-profit: every 3 years. Filed via ServiceOntario. A missed filing itself triggers compliance action.
Operate an accessible feedback process
Accept accessibility feedback through accessible channels (email, phone, in-person). Respond in accessible formats on request. Log feedback and response times.
Re-audit when the IASR updates
Any move from WCAG 2.0 AA to 2.1 or 2.2 AA will require a re-audit window. Monitor the Ministry for Seniors and Accessibility announcements.
Next step
Audit your Ontario website against WCAG 2.0 AA
Our checker tests the exact criteria AODA requires — WCAG 2.0 Level A and AA excluding the two AODA-exempt criteria. Every failure maps to the specific WCAG success criterion and the specific IASR provision.