Web Accessibility in Canada: What It Actually Requires
Web accessibility is one of those topics where there is a large gap between what organisations think they have done and what they have actually achieved. We have audited dozens of Canadian websites that were described as “WCAG compliant” by the agencies that built them. Most failed basic manual testing with a keyboard and screen reader.
This is not a criticism of those agencies. Automated accessibility tools — the kind most agencies use — catch roughly 30–40% of real accessibility barriers. The rest require human testing. If your agency ran an automated scan and declared compliance, the work is not finished.
The Canadian Legal Context
Three pieces of legislation are most relevant for Canadian organisations:
AODA (Accessibility for Ontarians with Disabilities Act) requires Ontario organisations with 50 or more employees to meet WCAG 2.0 Level AA. The deadline has passed. Penalties can reach $100,000 per day for organisations found in non-compliance after an investigation.
The Accessible Canada Act requires federally regulated entities — banks, telecoms, broadcasters, federal government — to meet WCAG 2.1 AA. Effective January 2024 for most covered organisations.
Quebec’s Act Respecting Equal Access and similar provincial legislation are increasingly being applied to digital accessibility. The legal landscape is moving toward broader coverage, not narrower.
The Most Commonly Failed WCAG Criteria on Canadian Websites
Based on audits we have conducted for Canadian organisations, these are the failures we find most consistently:
Colour contrast. Light grey text on white backgrounds — a persistent modern design trend — fails WCAG’s 4.5:1 contrast ratio requirement for normal text. We see this on almost every site we audit. It is easy to fix and consistently overlooked.
Form labels. Forms where the label disappears when you click the field (placeholder-only labels) are not accessible. Screen reader users cannot identify what information is required. This is common on contact forms, newsletter signups, and donation flows.
Keyboard navigation. Interactive elements — navigation menus, modal dialogs, custom dropdowns — that cannot be operated with a keyboard alone. Tab through your website right now without touching the mouse. You may be surprised at what breaks.
PDF documents. Scanned PDFs are completely inaccessible to screen readers. They are treated as images, with no text content readable by assistive technology. If your organisation publishes reports, guides, or forms as PDFs, they need to be created as tagged PDFs from accessible source documents.
Missing alt text. Images without descriptive alt text exclude blind users from content. Decorative images should have empty alt attributes so screen readers skip them. Meaningful images need descriptive text that conveys the same information.
What Genuine Accessibility Testing Looks Like
Automated scanning (WAVE, axe, Lighthouse) should be the starting point, not the finish line. After automated testing, every page should be tested with keyboard navigation alone, and representative pages should be tested with a screen reader — VoiceOver on macOS, NVDA on Windows, TalkBack on Android.
The goal is not to pass an audit. The goal is to ensure that people who use assistive technologies can actually use your website to accomplish what they came to do.
Pragmatica provides manual accessibility audits for Canadian organisations and builds all client websites to WCAG 2.1 AA as standard. Learn more about our accessibility services or get in touch to discuss an audit.
