If you operate in Ontario and you have employees, the AODA applies to you. What you actually have to do depends on how big you are and what sector you're in.
This covers what the law is, who it covers, what it asks for, and what happens if you ignore it.
What does AODA stand for?
AODA stands for the Accessibility for Ontarians with Disabilities Act.
It's Ontario legislation, passed in 2005. The goal was a fully accessible province by January 1, 2025. That deadline has passed, and the province did not meet it.
The Act works by setting standards. Organizations have to meet those standards and, above a certain size, report that they've done it.
Who does the AODA apply to?
Every organization that operates in Ontario and has at least one employee.
That's businesses, non-profits, charities, and public sector bodies. Your obligations scale with your size:
- 1 to 19 employees: the standards apply, but you don't file a compliance report.
- 20 to 49 employees: you file an accessibility compliance report. The web standard isn't triggered by headcount at this level.
- 50 or more employees: you file, and your public website has to meet the web standard.
- Public sector: the web standard applies at any size, and you report more often.
Count employees. Not volunteers, not board members.
What are the five AODA standards?
Customer Service. How you serve people with disabilities. Training staff, allowing service animals and support persons, having a feedback process.
Information and Communications. Making your information available in accessible formats. This is where the website requirement lives.
Employment. Hiring, accommodation, return-to-work processes.
Transportation. Only applies to transportation providers.
Design of Public Spaces. Physical spaces. Paths, parking, service counters.
The last four are grouped under the Integrated Accessibility Standards Regulation, usually shortened to IASR. Customer Service is its own standard.
Not all five apply to everyone. If you don't run buses, the transportation standard is not your problem.
What does the AODA require of my website?
If you have 50 or more employees, or you're a designated public sector organization, your public websites and web content have to meet WCAG 2.0 Level AA.
Two criteria are excepted. You don't have to provide live captions (1.2.4) or audio descriptions for pre-recorded video (1.2.5).
The deadline was January 1, 2021. It's not a future obligation. It's five years past.
It applies to new websites and significantly refreshed ones. A new site means a new web address. A significant refresh keeps the address but changes substantially in look and feel, content, or navigation. That second one catches a lot of organizations who redesigned and assumed nothing changed legally.
Ontario is moving to WCAG 2.2, expected by 2027. If you're doing this work now, build to 2.2.
What does AODA compliant actually mean?
It means you've met the standards that apply to your organization, and if you're above the reporting threshold, you've filed saying so.
It's worth being blunt about what it doesn't mean. It doesn't mean you passed an automated scan. Automated tools find a fraction of accessibility failures. They can't tell you whether someone using a screen reader can complete a donation, whether your forms are usable by keyboard, or whether your focus order makes sense.
It also doesn't mean you installed an overlay. Scripts that promise instant compliance don't fix the underlying code and don't hold up to manual testing.
The compliance report
Organizations with 20 or more employees file an accessibility compliance report with the Government of Ontario.
Private and non-profit organizations file every three years. The last deadline was December 31, 2023. The next one is December 31, 2026.
It's self-reported. You're confirming your own compliance, which means filing an inaccurate report is its own problem.
What are the penalties?
Corporations: up to $100,000 per day for each ongoing violation.
Individuals and unincorporated organizations: up to $50,000 per day.
Directors and officers: personally liable up to $50,000 per day where negligence is found.
Historically, enforcement was light. That's changing. Ontario missed its 2025 target, and the Fourth Independent Review of the AODA, led by Rich Donovan, called the province's progress an unequivocal failure and recommended declaring a state of crisis.
Where to start
Work out which standards apply to you based on headcount and sector. Find out whether you've ever filed. Then find out where your website actually stands, which takes a person with a keyboard and a screen reader, not a scan.
Most organizations discover the gap is smaller than they feared and more specific than they expected.
Pragmatica has built websites for Canadian non-profits, charities, and associations since 2004. If you want to know where you stand, get in touch.
