Who must make their website accessible
Under the AODA, two groups must make their public websites accessible: designated public sector organizations, and businesses and non-profit organizations with 50 or more employees in Ontario. This requirement has applied since January 1, 2021.
The employee count is based on your organization's peak number of employees at any one time during the previous twelve months. It includes full-time and part-time employees, seasonal employees and contract workers.
This guide gives a practical overview. It is not legal advice. The Government of Ontario publishes detailed guidance on accessible websites and on accessibility compliance reports; for your specific case, refer to ontario.ca or consult a professional.
What the standard requires
Public websites and web content posted after January 1, 2012 must meet the Web Content Accessibility Guidelines (WCAG) 2.0, Level A and Level AA, except for two criteria: live captions and pre-recorded audio descriptions.
- Covered: your public website and the web content you post on it, including documents you publish there.
- Not covered: internal intranets and extranets, which are not public-facing, and content published before January 1, 2012.
- Narrow exception: if, after a documented search, no commercial software or tool exists to make certain content conform, some requirements may not apply. This is not a general way out.
Organizations with 50 or more employees also have related obligations: a written multi-year accessibility plan, updated at least once every five years and posted on the website, and an accessibility compliance report filed every three years.
What WCAG 2.0 AA means in practice
WCAG is organized around four principles: content must be perceivable, operable, understandable and robust. In day-to-day website terms, that translates into concrete checks.
| Check | What it means for your site |
|---|---|
| Text alternatives | Every meaningful image has a text description; decorative images are ignored by screen readers |
| Colour contrast | Text stands out clearly from its background, including on buttons and over photos |
| Not colour alone | Information is never conveyed only by colour (for example, a red field without an error message) |
| Keyboard access | Every menu, button, form and pop-up works with the keyboard alone |
| Visible focus | You can always see which element is selected when navigating by keyboard |
| Headings and structure | Pages use real headings in a logical order, so screen reader users can navigate |
| Forms | Each field has a label; errors are explained in text, with how to fix them |
| Link text | Links say where they go, instead of “click here” |
| Zoom and resizing | Text can be enlarged to 200% without losing content or function |
| Captions | Pre-recorded videos with sound have captions |
| Page language | Each page declares its language, so screen readers pronounce it correctly |
| Documents | PDFs and other files posted on the site are accessible too, or offered in an accessible format |
How to test your website
- 01Run an automated scan
Free browser tools flag missing image descriptions, low contrast and missing labels. They catch only part of the issues, but they are a quick start.
- 02Put the mouse away
Navigate every page with the Tab, Enter and arrow keys. Can you open the menu, fill in the form and close a pop-up?
- 03Try a screen reader
VoiceOver is built into Mac and iPhone, TalkBack into Android, and NVDA is free on Windows. Listen to your home page and your main form.
- 04Zoom to 200%
Check that nothing overlaps or disappears, on desktop and on a phone.
- 05Review your documents
List the PDFs on your site and check whether they are accessible or need an alternative.
- 06Ask real users
Feedback from people who use assistive technologies is the most reliable test.
Write down what you tested, when and with which tools, along with the issues found and how they were fixed. That record helps you track progress, supports your compliance reporting and makes the next review faster.
Accessibility is not a one-time project. Every new page, image or document must follow the same rules, so the people who publish content need simple guidelines. A full review once a year is a sensible rhythm.
Accessibility in your publishing routine
Most accessibility problems appear after launch, when new content is published. Give the people who update your website a short set of rules they can follow without technical knowledge.
- Describe every meaningful image in a sentence; leave decorative images without description.
- Use the heading levels of the editor in order instead of making text bold and large.
- Write links that say where they go, such as “see our opening hours”.
- Never put important information only inside an image, such as a poster with dates and prices.
- Add captions to every video with sound before publishing it.
- Check the accessibility of a PDF before uploading it, or publish the content as a web page instead.
If your website has a content management space, ask your provider to make these fields mandatory where possible, for example a required description for each uploaded image.
Smaller organizations and sales outside Ontario
If your organization has fewer than 50 employees, the AODA's website requirement does not apply to you, but accessibility remains good practice: it helps customers with disabilities, older visitors and anyone on a small screen in bright sunlight. Most of the checks above also make a site clearer and easier to use for everyone.
If you sell to customers in the European Union, note that the European Accessibility Act has applied since June 28, 2025 to e-commerce and several digital services, with an exemption for micro-enterprises providing services. The rules differ, but the WCAG checks above are a common foundation.
Building accessibility in from the start
Fixing accessibility after launch is always more expensive than designing for it. At Ecosystem Annexe, we design every site for the phone first, with clear structure, real headings, labelled forms and readable contrast, and we check those points before launch. If your organization is subject to the AODA, tell us at the start of the project so the WCAG 2.0 AA criteria are part of the scope and the testing.
Accessibility often goes hand in hand with the other Canadian rules: language in Québec, covered in our Bill 96 guide, and privacy, covered in our Law 25 guide. For budgets, see our website cost guide, and for a project in Ontario, see our page on web design in Toronto or contact us (page in French; we reply in English).
Updated November 13, 2026