If your non-profit operates in Ontario and has 20 or more employees, you have a government filing due before the end of this year.
Most organizations we talk to find out about it in November. That's not enough time to fix anything, so they file a report that says they're not compliant, and hope nobody follows up.
Here's what's due, who it covers, and why this year isn't like the last one.
What's the deadline?
December 31, 2026.
Every private business and non-profit in Ontario with 20 or more employees has to file an accessibility compliance report with the Government of Ontario. It's a self-reported form. You confirm whether you've met the requirements under the Accessibility for Ontarians with Disabilities Act.
The last one was due December 31, 2023. Private and non-profit organizations file on a three-year cycle. So if you filed in 2023, you're up again. If you've never filed, you're already behind and probably don't know it.
Who actually has to file?
Any private or non-profit organization in Ontario with 20 or more employees.
Count your employees, not your volunteers or your board. If you're a 24-person association, you're in. If you're a 12-person charity, you're not required to file, though the underlying accessibility obligations still apply to you in other ways.
Public sector organizations are on a different cycle and file more often.
Does this mean my website has to be accessible?
This is where it gets confusing, and it's the part people get wrong.
There are two separate obligations, and they have different thresholds:
- Filing the report applies at 20 or more employees.
- Meeting the web accessibility standard applies at 50 or more employees, plus designated public sector organizations of any size.
So if you're a 30-person non-profit, you have to file, but the WCAG requirement for your public website isn't triggered by headcount alone.
If you're at 50 or more, your public websites, mobile sites, public-facing documents, and the social media content you control all have to meet the standard. That deadline was January 1, 2021. It's not new. It's five years past.
What's the actual web standard?
WCAG 2.0 Level AA, with two carve-outs: live captions (1.2.4) and audio descriptions (1.2.5). You don't have to meet those two.
It applies to new websites and significantly refreshed ones. A new site means a new web address. A significantly refreshed site keeps the same address but changes substantially in look and feel, content, or navigation.
That second one catches people. If you redesigned in the last few years and kept your domain, you triggered it.
What are the penalties?
For corporations, up to $100,000 per day for each ongoing violation.
For individuals and unincorporated organizations, up to $50,000 per day.
Directors and officers can be held personally liable, up to $50,000 per day, if they're found to have been negligent.
That last line is the one to bring to your board. AODA liability isn't purely organizational. It reaches the people who sit on your board, and most of them have never heard of it.
Why this year is different
Ontario's original goal was a fully accessible province by January 1, 2025. That deadline came and went.
The Fourth Independent Review of the AODA, led by Rich Donovan, called the province's progress an unequivocal failure. It recommended Ontario declare a state of crisis to force immediate reform.
The practical effect is that enforcement and regulatory attention have intensified going into 2026. The reporting deadline that used to feel like paperwork is landing in a very different climate.
What's coming after this
Ontario is moving from WCAG 2.0 to WCAG 2.2, expected by 2027.
This is worth planning around. If you're going to do accessibility work to meet a December 2026 filing, doing it against the 2.0 standard means doing parts of it again in a year. If you have a redesign or a migration on the roadmap anyway, building to 2.2 now is cheaper than building to 2.0 twice.
What to do between now and December
Confirm your headcount and your filing history. Find out whether you filed in 2023 and who did it. In a lot of organizations this lived with someone who has since left.
Find out where you actually stand. An automated scan will catch some of it. It won't catch keyboard traps, focus order, screen reader behaviour, or whether your forms are usable, and those are the failures that matter most to real users. The rest needs a person.
Fix what you can, and be honest on the form. The report is self-reported. Filing an inaccurate one is worse than filing an accurate one that says you have work left to do.
Tell your board. Not because it's dramatic, but because personal liability is a thing they're entitled to know about, and because it's usually what unlocks a budget.
One honest note
If someone tells you a script you paste into your site makes you AODA compliant, be skeptical. Accessibility overlays don't fix underlying code, they don't hold up to manual testing against WCAG, and organizations using them have still been the subject of complaints. There's no one-line fix for this. There's just the work.
Pragmatica has been building websites for Canadian non-profits, charities, and associations since 2004. Our accessibility work is done by IAAP-certified specialists doing manual testing, not automated scans. If you want to know where you stand before December, get in touch.
