AODA website accessibility: who must comply, and by when.
Two different thresholds catch Ontario businesses out. Private-sector organizations with 50 or more employees must meet WCAG 2.0 Level AA on public web content — that deadline passed on 1 January 2021. But organizations with 20 or more employees must file an accessibility compliance report with the province, and the next one is due 31 December 2026. Under 20 employees, neither obligation applies.
The two obligations are separate.
Most of the confusion around the AODA comes from treating it as one rule. It is two, with different thresholds, and a business can easily fall under one and not the other.
Meeting the standard — 50+ employees
Private and non-profit organizations with 50 or more employees must ensure public-facing web content meets WCAG 2.0 Level AA. Public-sector organizations of any size are covered regardless of headcount. The compliance date was 1 January 2021, so this is an obligation already in force rather than one approaching.
Filing the report — 20+ employees
Businesses and non-profits with 20 or more employees must file an accessibility compliance report with the Government of Ontario. The next filing deadline is 31 December 2026. This is a separate obligation from the technical standard, and it catches organizations between 20 and 49 employees who correctly concluded the WCAG requirement did not apply to them.
If you employ fewer than 20 people, neither applies. That covers a large share of the businesses we work with, and it is worth knowing before paying anyone to fix a problem you do not have.
What WCAG 2.0 Level AA actually requires.
The standard is a published specification, not a matter of opinion. The AODA adopts WCAG 2.0 Level AA with two exceptions: success criterion 1.2.4 (captions on live audio) and 1.2.5 (audio description for pre-recorded video) are not required. Everything else at Level A and AA is.
The requirement applies to web content published or substantially refreshed after 1 January 2012. Older material left untouched is not retroactively captured, though in practice most sites have been rebuilt at least once since then.
What usually fails in practice
Insufficient colour contrast on body text and buttons. Images without meaningful alternative text. Forms whose fields have no programmatic label. Content that cannot be operated by keyboard alone. Video without captions. These five account for the majority of what an audit finds on a small business site.
What an overlay widget does not do
Accessibility overlays — the floating accessibility button sold as a one-line fix — do not make a non-compliant site compliant. They sit on top of the underlying markup rather than correcting it, and they have been the subject of legal action elsewhere. Treat them as a supplement at best, never as the remedy.
Why this is worth doing past the legal minimum.
The requirements overlap almost entirely with things that improve a site regardless of the law. Programmatic form labels, meaningful alt text, proper heading structure and keyboard operability are the same signals search engines and AI assistants use to understand a page. A site built to WCAG is easier to crawl, easier to quote, and easier to use on a phone in bright sunlight.
We build to Level AA by default on every project, including for clients well below the 50-employee threshold, because the marginal cost during a build is close to zero and the cost of retrofitting later is not.
Common questions.
Does the AODA apply to my business if I have 10 employees?
No. Neither the WCAG 2.0 Level AA requirement (50 or more employees) nor the compliance reporting requirement (20 or more) applies below 20 employees. Building accessibly is still worthwhile, but it is a choice rather than an obligation.
How are employees counted for the thresholds?
Counts are based on employees in Ontario, including part-time and seasonal staff, rather than full-time equivalents. Independent contractors are generally not counted. If you are close to a threshold, confirm your specific situation rather than estimating — the difference between 19 and 20 employees is the difference between filing and not.
What happens if we do not comply?
The Government of Ontario can issue monetary penalties to organizations found in violation, and to directors and officers of non-compliant corporations. Enforcement has historically focused on the reporting obligation, which is straightforward for the province to check because it is simply a filing that either exists or does not.
Does an accessibility overlay make my site compliant?
No. Overlays modify presentation at runtime rather than correcting the underlying markup, and a site relying on one will still fail an audit on the criteria that matter. The fix is in the build.
How do we know whether our current site passes?
Automated tooling will find roughly a third of issues — contrast, missing alt attributes, unlabelled form fields. The rest need manual checking: keyboard operability, focus order, whether alt text is actually meaningful rather than merely present. Start with an automated scan to size the problem, then review manually.
Sources.
This page states the law as we understand it and is not legal advice. Confirm against the primary sources, particularly if you are near a threshold:
Not sure where you stand?
We will tell you which obligations apply to your organization and what your current site would fail, in one call. If neither threshold catches you, we will say so.