"AODA website requirements" sounds like something every Ontario business with a website has to meet, and the companies selling accessibility scanners are happy to leave it that way. In fact the website rule and the compliance report are two different duties with two different headcounts. And the next report is due on 31 December 2026.
Short answer: Ontario's website rule starts at 50 employees, for businesses and non-profits. The accessibility compliance report starts at 20, and the next one is due 31 December 2026. Under 20, you have other duties, but ontario.ca lists the website rule under the 50 or more tier. The standard is WCAG 2.0 Level AA, minus two video criteria. Count your Ontario staff first.
This is not legal advice. Every rule below comes from the ontario.ca pages linked in the Sources, and if your case is unclear, ask a lawyer or the ministry.
Why doesn't the AODA website rule cover every business?
The AODA is Ontario's accessibility law, and it sets duties by the type and size of the organization. For websites, ontario.ca says public websites must be accessible if the organization is a designated public sector organization, or a business or non-profit with 50 or more employees. The requirement began on 1 January 2021 for those organizations, and it applies to websites and web content published after 1 January 2012.
The part the vendor pages blur is that the compliance report is a different duty. Businesses and non-profits with 20 or more employees file that report, and it is a report about the organization, not the website rule. So a 30-person firm can owe the report without being under the website rule. Ontario's page also says the organization that controls the website has to meet the requirements, and that intranet and extranet sites are not required to meet WCAG 2.0 A or AA for these organizations.
I read the three government pages on 25 October 2026. Their update dates are in the Sources, and I only repeat what they say. If a page changes, trust the page over this post.
Does my business have to comply? Under 20, 20 to 49, or 50 or more
Count your employees in Ontario first. This is how ontario.ca's rules for businesses and non-profits step up. I'm not going to guess how part-timers or contractors are counted, so check that on the ontario.ca rules page.
| Your Ontario employees | What ontario.ca lists |
|---|---|
| Fewer than 20 | Policies to help meet accessibility goals, and customer service for people with disabilities. The website rule is listed under the 50 or more tier. |
| 20 to 49 | The above, plus the accessibility compliance report. The deadline is 31 December 2026, and it repeats every three years. |
| 50 or more | The above, plus a multi-year accessibility plan, documented customer service policies and the public website rule. |
Source: Government of Ontario, accessibility rules for businesses and non-profits (updated 16 June 2026) and completing your accessibility compliance report (updated 19 February 2026).
Designated public sector organizations follow different timing, filing every two years, and their last deadline was 31 December 2025. Organizations with no employees in Ontario are exempt, per the same page. The compliance report asks what you did, so a site nobody has looked at in years is worth looking at now. ontario.ca says that if you miss it, you could face enforcement measures, which can include financial penalties. I won't quote a figure, because the pages I read don't give one. If you run a clinic with 20 or more staff, my page on website design for dental clinics covers how I think about those sites.
Is a free checker, or a WCAG 2.2 site, enough to be compliant?
No, and here's why. The regulation names WCAG 2.0 Level AA, with two criteria left out. One is 1.2.4, which asks for captions on live audio in video. The other is 1.2.5, which asks for audio description on prerecorded video. W3C's own overview says WCAG 2.2 is the latest version, and that content which conforms to 2.2 also conforms to 2.1 and 2.0. So aiming for 2.2 is a sensible target. But I haven't seen Ontario name 2.2, so I'm not saying it has.
A free scanner can flag things like missing image descriptions and weak contrast. To me, a green score is a start, not a certificate. Plenty of the standard needs a person to try the page, and no tool can tell you that you meet it. I think the same of the overlay widgets that promise a one-line fix. I haven't tested one, so that is only my opinion, but I wouldn't rely on one. I also haven't scanned or audited any site for this post, mine included.
What you can check yourself is what to ask a designer. Can the whole site be used with a keyboard alone? Do the forms have labels you can see? Do images that carry meaning have a description? Is the text readable against its background? Do videos have captions? I touched on readability in what patients check on a dental website. If you can't answer these, that tells you something about the site.
Where do I fit, and what should I do before 31 December?
You may not need a new website at all. Many owners at 20 to 49 staff need the report, not a rebuild, so do that first. If your site is old, on a template nobody maintains, or a rebuild is already on your list, then fixing issues one by one can cost more than starting again. That's when redesigning an older site or a new custom-coded site makes sense. I build every site myself, and I'd build with readable text, labels and keyboard use in mind.
But I don't claim that any site I build is certified AODA compliant. I'll tell you what I did and didn't check, and for a legal answer you need a lawyer or the ministry. If you want to know where your current site stands, I can do a free website review, or you can send me a note on the contact page and I'll tell you honestly whether it's worth fixing or rebuilding.
What to do this week:
- Count your Ontario employees and match them to the three tiers on ontario.ca.
- At 20 or more, put 31 December 2026 in your calendar and read the compliance report page.
- Open your site on your phone and with a keyboard, and list what you can't use.
Related posts
- What patients check on a dental website
- Who owns my website domain, me or my web designer?
- Does Google penalize AI content?
- My website redesign service
Sources
- Government of Ontario: How to make websites accessible (updated 21 September 2026, read 25 October 2026)
- Government of Ontario: Completing your accessibility compliance report (updated 19 February 2026, read 25 October 2026)
- Government of Ontario: Accessibility rules for businesses and non-profits (updated 16 June 2026, read 25 October 2026)
- W3C: Web Content Accessibility Guidelines (WCAG) 2.0 (Recommendation of 11 December 2008)
- W3C WAI: WCAG 2 Overview (WCAG 2.2 published 5 October 2023, updated 12 December 2024)
Questions people ask
What is the AODA, in plain words?
It's Ontario's law on accessibility. It sets duties by the type and size of an organization, so what you owe depends on who you are and how many people you employ. The ontario.ca pages in the Sources spell out each tier.
When is the AODA compliance report due?
For businesses and non-profits with 20 or more employees, ontario.ca gives the deadline as 31 December 2026, and the report repeats every three years. It also says you could face enforcement measures, which can include financial penalties, if it isn't filed.
Do PDFs, videos and old pages count?
ontario.ca says the website rule covers websites and web content published after 1 January 2012, and it leaves out two video criteria, 1.2.4 live captions and 1.2.5 prerecorded audio description. For anything else, such as how a particular PDF is treated, check the ontario.ca page or ask a lawyer.
Can I use an accessibility checker to test my site?
Yes, as a first look. It can't prove you meet the standard, so ask a person to try the site with a keyboard and on a phone as well.
Is your older site worth fixing or rebuilding?
Send me your address and I'll tell you honestly. You can also read about redesigning an older site.
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