AODA Website Compliance Checklist for Ontario Businesses (2026)

The short answer: under Ontario’s Accessibility for Ontarians with Disabilities Act (AODA), every designated public sector organization and every business or non-profit with 50 or more employees in Ontario must make its public website, and the web content on it, conform to the Web Content Accessibility Guidelines (WCAG) 2.0 at Level AA. That deadline passed on January 1, 2021, so if your site doesn’t meet it yet, you are already behind.

This guide explains who the rule applies to, what WCAG 2.0 AA means in plain language, and gives you a checklist you can work through with your team or your web partner. It is general information, not legal advice. For anything specific to your organization, check with the Accessibility Directorate of Ontario or a lawyer.

Who has to comply with the AODA website rules?

The website requirement sits in the Information and Communications Standards of the Integrated Accessibility Standards Regulation (Ontario Regulation 191/11). Here is how it breaks down:

The rule covers your public internet website and any web content on it that was published or significantly refreshed after January 1, 2012. Content you control, such as pages, PDFs, forms and videos, is in scope. Federally regulated organizations, such as banks and telecoms, have separate obligations under the Accessible Canada Act.

What is WCAG 2.0 Level AA?

WCAG is the international standard for accessible websites, published by the World Wide Web Consortium (W3C). It is organized around four ideas: content must be perceivable, operable, understandable and robust. Each idea is broken into testable success criteria at three levels: A (the minimum), AA (the standard most laws point to) and AAA (the highest).

The AODA asks for Level AA, which means meeting every Level A and Level AA success criterion in WCAG 2.0, with two exceptions: live captions (1.2.4) and pre-recorded audio descriptions (1.2.5).

WCAG has moved on since 2.0. The current version is WCAG 2.2, published in October 2023, and it adds criteria around focus visibility, target size and accessible sign-in. Building to WCAG 2.2 AA now covers everything 2.0 AA asks for and means you won’t have to rework your site if Ontario updates its standard.

The AODA website compliance checklist

Work through this list on your most important pages first: the homepage, your main service or product pages, contact and booking forms, and anything people need to complete a task.

Images and media

• Every meaningful image has alt text that describes its purpose. Decorative images have empty alt text so screen readers skip them.
• Charts, infographics and images of text have a text version nearby.
• Pre-recorded videos with sound have accurate captions, not just auto-generated ones you haven’t checked.
• Audio-only content, like a podcast, has a transcript.
• Nothing flashes more than three times a second.
• Video and audio that play automatically for more than a few seconds can be paused or stopped.

Colour and text

• Body text has a contrast ratio of at least 4.5:1 against its background. Large text (about 24px, or 19px bold) needs at least 3:1.
• Colour is never the only way information is shown. Error fields, for example, also have an icon or a message.
• Text can be zoomed to 200% without content being cut off or overlapping.
• Real text is used instead of images of text wherever possible.

Keyboard and navigation

• Every link, button, menu and form field can be reached and used with the keyboard alone.
• The keyboard focus is always visible, so people can see where they are.
• Nothing traps the keyboard, such as a pop-up that can’t be closed without a mouse.
• A "skip to content" link lets keyboard users jump past the main menu.
• Navigation is consistent from page to page.
• Every page has a unique, descriptive title.
• Link text makes sense on its own. "Download the 2026 price list" works; "click here" doesn’t.

Structure

• Each page has one H1, and headings follow a logical order (H2, then H3) instead of being chosen for their size.
• Lists, tables and sections are marked up as lists, tables and sections, not just styled to look like them.
• Data tables have header cells so screen readers can announce them.
• The page language is set in the code (English, French, or both where content switches).

Forms

• Every field has a visible label, not just placeholder text that disappears when you type.
• Required fields are marked in text, not only with colour.
• Error messages say what went wrong and how to fix it, next to the field.
• Time limits can be turned off, adjusted or extended.
• CAPTCHA has an accessible alternative.

Documents and third-party tools

• PDFs on your site are tagged and readable by screen readers, or the same content is also available as a web page.
• Embedded tools, like booking widgets, chat and maps, are tested too. If a vendor’s tool isn’t accessible, ask them for their accessibility conformance report.

How to test your website

A good check combines three things:

• Automated scanners such as WAVE, axe or Lighthouse. They are free and quick, but they only catch some issues, often estimated at around a third.
• Manual checks: unplug your mouse and use the site with the Tab, Enter and arrow keys, zoom to 200%, and read the page with a screen reader such as NVDA (Windows) or VoiceOver (Mac and iPhone).
• Real users: if you can, have people who use assistive technology try your key tasks, like booking or requesting a quote.

Beware of overlay widgets that promise one-line compliance. They don’t fix the underlying code, and accessibility advocates widely criticize them.

What happens if you don’t comply?

The AODA allows administrative penalties and, for serious cases, fines of up to $100,000 a day for a corporation and up to $50,000 a day for individuals, including directors and officers. In practice, the more common cost is lost business: if someone can’t book, buy or contact you, they go elsewhere.

The December 31, 2026 compliance report is a good moment to check. A senior officer has to certify that report, so it pays to know where your website actually stands before you sign.

Accessibility as part of good design

Accessibility is easiest and cheapest when it’s designed in from the start, rather than patched on later. Clear headings, readable contrast, obvious buttons and simple forms help everyone, including people on phones in bright sunlight and anyone in a hurry. The same choices also tend to help search engines understand your pages.

Every website Envy Design Co. designs and builds is made to meet WCAG Level AA, from colour choices and type sizes in the design stage to the code and forms at launch. If your current site falls short, a website redesign is often the cleanest way to fix it, and our website design process builds it in from day one. For healthcare organizations, our guide to healthcare website accessibility and WCAG 2.2 goes deeper.