---
title: "AODA Website Compliance for Ontario Businesses: What's Actually Required"
description: "What AODA requires of an Ontario business website: who the WCAG 2.0 AA rule covers, its two exceptions, reporting dates and penalties. Not legal advice."
category: "UX & Redesign"
question: "What does AODA require for a business website in Ontario?"
datePublished: 2026-10-15
dateModified: 2026-10-15
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---

# AODA Website Compliance for Ontario Businesses: What's Actually Required

## Key facts

| Fact | Value |
|---|---|
| Standard required | WCAG 2.0 Level AA for public websites and web content, except 1.2.4 Captions (Live) and 1.2.5 Audio Description (Prerecorded) |
| Who the website rule covers | Designated public sector organizations, and businesses and non-profits with 50 or more employees in Ontario |
| Since when | 1 January 2021, for content published on a website after 1 January 2012 |
| Compliance report | Businesses and non-profits with 20 or more employees file every three years; next deadline 31 December 2026 |
| Administrative penalties (corporations) | $500 to $15,000 per penalty, or daily up to $100,000 where impact and history are both major (O. Reg. 191/11 s. 83) |

**Under Ontario's Integrated Accessibility Standards (O. Reg. 191/11, section 14), a business or non-profit with 50 or more employees in Ontario, and every designated public sector organization, must make its public website and web content conform with WCAG 2.0 Level AA. Since 1 January 2021 that covers all content published after 1 January 2012, except live captions (1.2.4) and pre-recorded audio description (1.2.5). Smaller businesses are outside the website rule but still have other AODA duties, and businesses with 20 or more employees file a compliance report, next due 31 December 2026.**

## What does AODA require of a business, in order?

[AODA](/glossary#aoda) (the Accessibility for Ontarians with Disabilities Act, 2005) is a framework. The duties that touch a business website sit in one regulation, the Integrated Accessibility Standards Regulation (IASR, [O. Reg. 191/11](https://www.ontario.ca/laws/regulation/110191)), consolidated on 30 March 2026. As of 15 October 2026, the practical order is:

1. **Customer service standard.** Applies to every "obligated organization" that provides goods, services or facilities (Part IV.2, section 80.45). That includes a small organization: one with at least one but fewer than 50 employees in Ontario.
2. **Information and communications standard.** Every obligated organization has to make its feedback process accessible (section 11) and provide accessible formats and communication supports on request, at no more than the regular cost (section 12). The website rule in section 14 sits here too, and it is scoped by size.
3. **Training.** Employees, volunteers and anyone who provides goods or services on your behalf are trained on the standards and on the Human Rights Code as it applies to persons with disabilities (section 7).
4. **Reporting.** Businesses and non-profits with 20 or more employees file an accessibility compliance report every three years.

## Who does the website rule apply to?

The regulation defines a "large organization" as one with 50 or more employees in Ontario. Section 14 then sets the website schedule.

| Organization | Website requirement (O. Reg. 191/11 s. 14) |
|---|---|
| Government of Ontario, Legislative Assembly | WCAG 2.0 Level AA for internet and intranet sites, in full since 1 January 2020 |
| Designated public sector organization (every municipality, and the bodies the regulation lists) | Level A for new sites from 1 January 2014; Level AA for all internet sites and content since 1 January 2021, except 1.2.4 and 1.2.5 |
| Business or non-profit, 50+ employees in Ontario | Same schedule: Level AA since 1 January 2021, except 1.2.4 and 1.2.5 |
| Business or non-profit, 1–49 employees | Section 14 does not apply; sections 11 and 12 (accessible feedback and formats on request) and the customer service standard still do |
| Business or non-profit, 20+ employees | Files an accessibility compliance report every three years; next deadline 31 December 2026 |

Three details in section 14 matter when you plan a site. It covers web content published on a website after 1 January 2012, so older content is outside it. It covers sites and web-based applications you control "directly or through a contractual relationship that allows for modification of the product", so a vendor-built site is still yours. And it applies "except where meeting the requirement is not practicable"; the regulation lets an organization consider, among other things, the availability of commercial software or tools. The Province's [website guidance](https://www.ontario.ca/page/how-make-websites-accessible), updated 21 September 2026, says the same about who must comply and which content is covered.

## What does meeting WCAG 2.0 Level AA mean in practice?

[WCAG 2.0](https://www.w3.org/TR/WCAG20/) is the W3C standard the regulation names. It is organised around four principles: content must be perceivable, operable, understandable and robust. For a small business site, the success criteria that come up most are:

- **Text alternatives (1.1.1).** Every image that conveys information has a [text alternative](/glossary#alt-text) that does the same job.
- **Captions (1.2.2).** Pre-recorded video with sound has captions. Live captions (1.2.4) and pre-recorded audio description (1.2.5) are the two Level AA criteria Ontario exempts.
- **Keyboard (2.1.1, 2.1.2).** Everything works by keyboard alone, and focus never gets stuck in a component.
- **Colour (1.4.1, 1.4.3).** Colour is never the only way information is shown, and text meets a contrast ratio of at least 4.5:1 (3:1 for large text).
- **Forms (3.3.1, 3.3.2).** Inputs have labels or instructions, and errors are described in text.
- **Flashing (2.3.1).** Nothing flashes more than three times in any one second.

Most of this is disciplined HTML and a palette checked with a contrast tool, not a redesign. Our [Ontario Practice Website Index](/research/ontario-practice-website-index) runs three of these checks (page language, image alt text and text contrast) on Ontario practice homepages, if you want a sense of where sites in your sector stand. Our guides on [what a UX audit checks](/blog/what-is-a-ux-audit) and [what a website care plan should include](/blog/what-is-a-website-care-plan) cover how it fits into a review and into ongoing maintenance.

## What are the penalties?

AODA has two enforcement routes. The first is administrative: a director can order an organization to pay an administrative penalty (AODA [section 21](https://www.ontario.ca/laws/statute/05a11)), and section 83 of the regulation sets the amount from the impact of the contravention and the organization's history. The second is prosecution under section 37 of the Act. As of 15 October 2026:

| Penalty route | Corporation | Individual or unincorporated organization |
|---|---|---|
| Administrative penalty (O. Reg. 191/11 s. 83, Schedules 2 and 3) | $500 to $15,000 per penalty | $200 to $2,000 per penalty |
| Daily penalty, only where impact and history are both major | Up to $100,000 | Up to $50,000 |
| Fine on conviction for an offence (AODA s. 37) | Up to $100,000 a day | Up to $50,000 a day |

The offences in section 37 are specific: giving false or misleading information in a report or to a director, failing to comply with a director's or the Tribunal's order, and intimidating or penalizing people who seek enforcement or co-operate with it. A director or officer of a corporation who fails to take reasonable care to prevent the corporation's offence can be fined up to $50,000 a day. For a smaller business the likelier consequence is a compliance order, a complaint, or a site some visitors cannot use.

## What should you do if you are under 50 employees?

Section 14 is not a legal requirement for your website. Three things still make building to WCAG 2.0 AA worth it:

1. **Growth.** If you pass 50 employees in Ontario, the rule applies to the website you already have.
2. **Your existing duties.** You must offer accessible formats on request and tell the public they are available (section 12). An accessible site makes those requests rarer and easier to meet.
3. **Your visitors.** Older clients, people with low vision or a tremor, and anyone on a small phone in sunlight benefit from the same fixes.

Accessibility is one of the checks we build into [website design and build](/services/website-design-build), and our [compliance overview](/services/compliance) explains how we mark up the rules that apply to your sector.

## FAQ

### Does AODA apply to a business with fewer than 50 employees?

Yes, but not the WCAG website rule. Section 14 of O. Reg. 191/11 covers designated public sector organizations and businesses or non-profits with 50 or more employees in Ontario. A business with 1 to 49 employees still has other duties under the same regulation, including accessible customer service, training, and accessible formats and communication supports on request.

### Does a brand-new website have to comply?

If your organization is covered, yes. The rule applies to websites and web content published after 1 January 2012, and the Level AA deadline for businesses with 50 or more employees was 1 January 2021. A site launched in 2026 has no grace period.

### Is an accessibility overlay widget enough to comply?

Nothing in the regulation or the Province's guidance says an overlay satisfies it. Section 14 requires the website and web content to conform with WCAG 2.0 Level AA, so the test is whether the pages themselves pass: headings, form labels, keyboard access, contrast and captions.

### Does the rule cover a site our web studio hosts for us?

Yes. Section 14 applies to websites and web content an organization controls directly or through a contractual relationship that allows the product to be modified. A site built or hosted by a vendor under your contract is still yours to make conform.

## Next step

If you are not sure where your site stands, [request a free Redline](/redline): we mark up your homepage by hand, with what to cut, what to add, and why. The Full Redline covers your key pages the same way, with the rules that apply to your sector. For a build that treats accessibility as structure rather than a bolt-on, see [website design and build](/services/website-design-build) or the [Tokas Lex law firm site](/work/tokas-lex-law-office).

*Reviewed for accuracy against the cited primary sources on 15 October 2026. General information, not legal advice.*

## Sources

- [O. Reg. 191/11, Integrated Accessibility Standards (ss. 2, 7, 11, 12, 14, 80.45, 83 and Schedules 2 and 3; consolidated 30 March 2026)](https://www.ontario.ca/laws/regulation/110191) (accessed 2026-10-15)
- [Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 (ss. 14, 21, 37)](https://www.ontario.ca/laws/statute/05a11) (accessed 2026-10-15)
- [How to make websites accessible (updated 21 September 2026)](https://www.ontario.ca/page/how-make-websites-accessible) (accessed 2026-10-15)
- [Completing your accessibility compliance report (updated 19 February 2026)](https://www.ontario.ca/page/completing-your-accessibility-compliance-report) (accessed 2026-10-15)
- [Web Content Accessibility Guidelines (WCAG) 2.0](https://www.w3.org/TR/WCAG20/) (accessed 2026-10-15)