If your business has 50 or more employees in Ontario, your public website must meet WCAG 2.0 Level AA under the Accessibility for Ontarians with Disabilities Act (AODA). If you have 20 or more employees, you also have an accessibility compliance report due by December 31, 2026. If you have fewer than 20, there's no website requirement or report, but you still have to serve customers with disabilities and provide information in an accessible format when asked.
That's the short version. The rest of this guide covers what each group has to do, what WCAG 2.0 AA means for an ordinary business website, and how to avoid paying for a fix that doesn't work. It isn't legal advice. If you're unsure which obligations apply, check with a lawyer or the Accessibility Directorate of Ontario.
What applies to you, by business size
Ontario's own rules for businesses and non-profits set the thresholds:
| Employees in Ontario | Website must meet WCAG 2.0 AA | Compliance report by Dec 31, 2026 | Other duties |
|---|---|---|---|
| 1–19 | No | No | Accessible customer service, accessible formats on request, staff training |
| 20–49 | No | Yes | As above |
| 50+ | Yes | Yes | As above, plus documented policies and a multi-year accessibility plan |
Count full-time, part-time and seasonal employees and contract workers. Don't count people who work outside Ontario, volunteers or independent contractors. A contractor with 30 staff across the busy season is in the 20–49 group, even if most of them are only there from May to October.
What the website requirement covers
The requirement has been in force since January 1, 2021. According to Ontario's website guidance:
- It applies to public websites. Most private businesses don't need their intranet to comply.
- It covers content published or changed since January 1, 2012. Older pages that haven't changed since then are exempt.
- The standard is WCAG 2.0 Level AA, with two exceptions: live captions and audio descriptions for pre-recorded video aren't required.
- The organisation that controls the site is responsible, even if an agency built it or a platform hosts it.
Most business websites are rebuilt or edited well after 2012, so the exemption for older content rarely helps.
What WCAG 2.0 AA means in practice
WCAG 2.0 is a set of testable criteria. You don't need to read all of it to understand what commonly fails on small business sites. These problems come up often:
| Check | What goes wrong |
|---|---|
| Images have text alternatives | Photos of the work or menus have no alt text, so screen readers skip them |
| Text contrasts with its background | Light grey text on white, or white text over a busy photo |
| Everything works with a keyboard | Menus, sliders or booking widgets can't be reached or used without a mouse |
| Focus is visible | You can't see where you are when tabbing through the page |
| Form fields have labels | Placeholder text disappears, and errors don't say what's wrong |
| Headings are real headings | Big bold text that isn't marked up as a heading, so pages can't be navigated |
| Video has captions | Pre-recorded videos with speech have no captions |
| Text can be resized | The layout breaks when someone zooms in |
A quick check you can do in five minutes: put your mouse away and press Tab through your homepage and contact form. Can you see where you are at each step? Can you open the menu, fill in the form and submit it? If not, some of your visitors can't either.
Third-party tools count too. A booking system, chat widget or embedded map is part of your website as far as a visitor is concerned. Ask your vendors whether their tools meet WCAG 2.0 AA before you add them.
About the December 31, 2026 report
If you have 20 or more employees, the report is filed online through Ontario's Accessibility Compliance Reporting portal. You need your legal name, business number (BN9), number of employees, and the name and contact details of a certifier. The certifier is a senior officer with authority to confirm the report is complete and accurate.
It's a self-assessment, but that doesn't make it a formality. The certifier is confirming that the business actually meets its obligations. Answering yes about a website you haven't checked is a statement that can be tested. Businesses with 50 or more employees should review the site before filing, not after.
Why an accessibility widget isn't a fix
You'll see ads for plugins that promise "instant AODA compliance" for a monthly fee. They usually add an accessibility toolbar to the page. The toolbar doesn't change the underlying problems: an unlabelled form field is still unlabelled, and a menu that doesn't work with a keyboard still doesn't work.
The strongest public warning on this came from the United States. In 2025, the Federal Trade Commission ordered accessiBe to pay $1 million over claims that its widget could make any website WCAG compliant. That was a U.S. consumer protection case, not an Ontario ruling, but it goes to the same question: whether a script can fix a website's structure without anyone touching the site. It can't.
Automated scanners are useful for finding some problems quickly. They can't judge whether alt text describes the image or whether a form makes sense to someone using a screen reader. A proper review combines an automated scan with manual keyboard and screen reader testing.
Penalties
Ontario says businesses that don't meet their obligations, including filing the report, can face enforcement that may include financial penalties. Law firms advising on the Act cite maximum fines of up to $100,000 a day for a corporation and $50,000 a day for directors and officers.
Those are maximums. Enforcement has mostly been driven by complaints, audits and compliance orders rather than headline fines. The more immediate cost for most businesses is practical: customers who can't book, order or call from your website go to a business whose site works.
What's next: WCAG 2.1 and 2.2
Ontario's regulation still names WCAG 2.0 AA. Newer versions exist, and some legal advisers expect Ontario to move to WCAG 2.2, but that hasn't happened yet. WCAG 2.1 and 2.2 add criteria on top of 2.0; they don't replace it. If you're rebuilding a site now, building it to WCAG 2.2 AA covers today's requirement and whatever update comes next.
A plan based on your size
- Fewer than 20 employees: No website requirement, but fix the obvious problems anyway, starting with contrast, form labels and keyboard access. They cost little to fix and they affect real customers. Make sure your site says how to ask for information in another format.
- 20 to 49 employees: File your compliance report before December 31, 2026. The WCAG website requirement doesn't apply to you, but if you're growing towards 50, build the next version to the standard now.
- 50 or more employees: Have the site reviewed against WCAG 2.0 AA before your certifier signs the report. Keep a record of what was tested, what failed and when it was fixed.
If you're rebuilding, don't treat accessibility as a separate project after launch. Fixing contrast, headings and form structure in a finished site costs more than building them in. The same fixes often help in other ways too, including making your pages easier for AI crawlers to read.
Every site GrowMint builds is held to WCAG 2.0 AA as standard, not as an add-on. If you're not sure where your current site stands, book a free consultation and we'll check it with you. For new builds, see website development.
Frequently asked
Does a small business website have to be AODA compliant?
Under the AODA, the website requirement applies to businesses and non-profits with 50 or more employees in Ontario, and to designated public sector organisations. Those websites must meet WCAG 2.0 Level AA. Businesses with fewer than 50 employees don't have that specific website obligation, but they must still provide accessible customer service and provide information in an accessible format when someone asks.
Who has to file an accessibility compliance report by December 31, 2026?
Ontario businesses and non-profits with 20 or more employees. The report is filed online every three years and is certified by a senior officer who confirms it's accurate. Businesses with 50 or more employees are confirming, among other things, that their website meets the standard. Businesses with fewer than 20 employees don't have to file.
How do I count employees for the AODA?
Ontario's guidance says to include full-time, part-time and seasonal employees and contract workers. Don't count people who work outside Ontario, volunteers or independent contractors. Check the current count before deciding which obligations apply.
Will an accessibility plugin or widget make my site AODA compliant?
Don't rely on one. An overlay widget adds a toolbar on top of the site but doesn't fix problems in the underlying code, such as unlabelled form fields or content a keyboard can't reach. In 2025 the U.S. Federal Trade Commission ordered accessiBe to pay $1 million over claims that its widget could make any website WCAG compliant. Fixing the site itself is what meets the standard.
What are the penalties for not complying with the AODA?
Ontario says organisations that don't meet their obligations, including not filing a compliance report, can face enforcement measures that include financial penalties. Law firms advising on the Act cite maximum fines of up to $100,000 a day for a corporation and $50,000 a day for directors and officers. In practice, enforcement has mostly started with audits, orders and notices rather than maximum fines.
Sources
- How to make websites accessible, Government of Ontario
- Accessibility rules for businesses and non-profits, Government of Ontario
- Completing your accessibility compliance report, Government of Ontario
- Is your business ready for Ontario's next accessibility deadline?, Gowling WLG
- FTC approves final order requiring accessiBe to pay $1 million, U.S. Federal Trade Commission, April 22, 2025
- Web Content Accessibility Guidelines (WCAG) 2.0, W3C
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