Expert Guide to AODA Compliance

Enacted in 2005, the Accessibility for Ontarians with Disabilities Act(opens in a new tab) (AODA) is a powerful non-discrimination law that applies to both government agencies and private organizations operating in the province of Ontario.

AODA requires organizations with 50 or more workers to meet the Web Content Accessibility Guidelines(opens in a new tab) (WCAG) 2.0 Level AA. However, WCAG 2.2 is the current version of that standard and represents best practice.

Below, we provide an overview of the AODA’s requirements and share tips for improving your website’s compliance.

What is the AODA?

In 2001, Ontario’s provincial government passed the Ontarians with Disabilities Act(opens in a new tab) (ODA), which was designed to “improve opportunities for [people] with disabilities” and identify, remove, and prevent barriers to their “full participation in the life of the province.”

Although the ODA was important legislation, it lacked detailed enforcement mechanisms or deadlines.

The government addressed those shortcomings in 2005 by passing the AODA, which built on the earlier statute by including accessibility standards for five key areas of daily life: customer service, information and communications, employment, design of public spaces, and transportation.

Collectively, these standards are called the Integrated Accessibility Standards Regulations(opens in a new tab) (IASR). The AODA gives the government authority to set deadlines for meeting IASR requirements — and to assess penalties for non-compliance.

Under the AODA, it is important for organizations with 50 or more workers to regularly test their website for website accessibility in order to ensure that it meets WCAG Level AA and is fully accessible to all users, including those with disabilities.

What are the Five Standards Set by the AODA?

The AODA currently contains five standards, but additional standards are being developed. The current standards include:

• Customer Service Standard:  Applies to service providers and requires them to make their “goods, services, and facilities" accessible for customers or patrons with disabilities.

• Information and Communication Standards: Applicable to digital communications such as websites, mobile apps, and web-delivered documents. 

• Employment Standard: Requires that employers make their workplace practices accessible to both current and potential workers with disabilities. It applies to paid workers but not to volunteers.

• Transportation: Requires that transportation companies make the features and equipment on routes and vehicles accessible to passengers with disabilities. Additionally, it requires that transportation companies inform the public about equipment and features. 

• Design of Public Spaces Standard: Outlines the need for newly constructed or redeveloped public spaces to be accessible for people with disabilities.

Two standards currently under development include:

• Health Care Standards: Expected to apply to hospitals, doctors' offices, walk-in clinics, wellness centers, and other healthcare facilities with more than one worker. 

• Education Standards: Expected to apply to colleges, universities, public and private schools, school libraries, and producers of educational materials (such as textbook publishers).

It’s important to note that the AODA currently applies to healthcare and outpatient facilities, schools, and other institutions that are not directly addressed by one of the five current standards. In other words, every organization must follow the AODA.

For the purposes of this article, we’re focusing on compliance with the AODA’s Information and Communication Standards. To learn more about the other standards, review the AODA’s website(opens in a new tab).

Which Disabilities are Protected by the AODA?

According to the AODA, the term “disability” covers a broad range of visible and invisible conditions that may have been present from birth, caused by an accident, or developed over time. This includes, but is not limited to:

• Visual impairments.

• Hearing impairments.

• Mental health disorders, learning disabilities, and neurocognitive differences.

• Physical or mobility disabilities.

To fully comply with the AODA, you must accommodate all these disabilities. Providing a website that works for people with visual or hearing impairments alone isn’t sufficient.

Flow chart of the three levels of WCAG feeding into the AODA.

Who Has to Comply with the AODA?

All public agencies and all private organizations with 50 or more workers must meet WCAG 2.0’s Level AA guidelines. While the law outlines potential exceptions for situations where content cannot be made accessible, those exceptions are extremely limited.

Review the table below for more information on compliance obligations based on organization size and sector.

Under the AODA, businesses must count full-time, part-time, contract, and seasonal employees as “workers.” However, they should not count independent contractors, volunteers, or workers from outside Ontario in their total.

Even if your business falls below the threshold outlined above, following WCAG 2.0 is a smart practice. Doing so may also strengthen your compliance with the Accessible Canada Act(opens in a new tab) (ACA) and the Americans with Disabilities Act(opens in a new tab) (ADA).

AODA Compliance Checklist

Staying compliant with the AODA is an ongoing process, not a one-time fix. The checklist below can be used as a practical starting point to assess (and maintain) your organization's accessibility obligations in Ontario.

1. Confirm Your Employee Headcount 

Count all full-time, part-time, contract, and seasonal employees on your payroll. Do not include independent contractors, volunteers, or workers based outside Ontario. Your total determines which AODA obligations apply to your organization.

2. Review WCAG 2.0 Level AA Criteria 

If your organization meets the 50+ employee threshold or is a public sector body, your website must meet WCAG 2.0 Level AA. While this is the legal requirement, WCAG 2.2 is now the current standard and serves as a best practice benchmark worth working toward.

3. Run Automated Accessibility Testing 

Use automated tools such as WAVE, Axe, Lighthouse, or AudioEye to scan your website for common accessibility issues. Automated testing can catch a significant portion of violations quickly, though it cannot identify every issue on its own.

4. Test With Assistive Technologies 

Manual testing with screen readers, keyboard-only navigation, and other assistive technologies is essential. Automated tools alone will not surface every barrier that a user with a disability might encounter. If possible, test with real users with disabilities.

5. Audit Your Digital Content 

Review PDFs, videos, images, and forms in addition to your web pages. Captions, alt text, and accessible document formatting are all part of WCAG 2.0 AA compliance and are commonly overlooked.

6. Publish an Accessibility Statement 

Post a clear accessibility statement on your website that outlines your organization's commitment to accessibility, the standard you are working toward, and how users can report barriers or request accommodations.

7. File Your AODA Accessibility Compliance Report 

Private organizations with 20 or more employees and all public sector bodies must file an accessibility compliance report with the Ontario government on a set schedule. Missing this deadline can result in penalties, so build it into your annual compliance calendar.

8. Document all Fixes

Document accessibility issues as they are identified and assign ownership for resolving them. A simple tracking spreadsheet or project management workflow helps ensure nothing falls through the cracks between audits.

9. Train Relevant Staff 

Employees who create content, manage your website, or communicate with the public should understand their role in maintaining accessibility. Training does not need to be exhaustive, but it should be role-specific and revisited when WCAG guidance is updated.

10. Schedule Regular Reviews 

Accessibility is not a one-time project. Set a recurring schedule to re-audit your site, review any new content, and check for updates to WCAG guidelines or Ontario accessibility regulations.

AODA Compliance Deadlines

If your organization is subject to the AODA, these are the deadlines you need to act on now.

File your 2025 report if you are a designated public sector organization and have not already done so. The December 31, 2025 deadline has passed, but filing late is still required. Submitting late reduces the likelihood of maximum penalties.

File your 2026 report before December 31, 2026. This is the next mandatory deadline for all eligible organizations in Ontario. Private organizations with 20 or more employees and all designated public sector bodies must submit their accessibility compliance report by this date. 

If you have not yet filed your 2023 or earlier report, file now. Outstanding reports do not disappear. Filing late reduces the likelihood of maximum penalties, which can reach up to $100,000 per day for corporations, though actual penalties assessed typically fall well below that ceiling depending on the severity and history of the violation.

For reference, here is a breakdown of reporting frequency by organization type:

• Businesses and non-profit organizations with 20 or more employees must file every three years.

• Designated public sector organizations must file every two years.

No deadlines beyond 2026 have been published yet. The Ontario government has indicated it will share further guidance on the 2026 reporting process later in the year, so check back as the deadline approaches.

How to Report Your AODA Compliance

The submission process has changed for the 2026 cycle. Organizations must now submit their accessibility compliance report through the Ontario Accessibility Compliance Reporting Portal(opens in a new tab), rather than a downloadable PDF form.

The portal allows organizations to submit a compliance report, update their organization profile, access saved drafts, and review previously submitted reports. To complete your submission, you will need your organization's name, contact information, and the name and contact details of your certifier, who is a senior officer with the legal authority to confirm the report is complete and accurate.

Below are additional helpful resources for AODA compliance reporting:

• Ontario’s accessibility compliance reporting guidance(opens in a new tab), which includes current reporting deadlines and guidance for submitting completed reports.

• The Accessibility Compliance Reporting Portal(opens in a new tab), where all 2026 reports must be submitted.

What are the Benefits of AODA Compliance?

Ensuring that people of all abilities can access information and services online is clearly the right thing to do from an ethical perspective. It’s also the right thing to do from a business perspective — in fact, people with disabilities have an estimated spending power of about $25 billion annually(opens in a new tab) across Canada.

More than 16% of Canadians over the age of 15 are living with a disability(opens in a new tab), and this number will continue to grow as the population ages. Ignoring that audience doesn’t make sense, particularly if you’re trying to grow your business.

AODA website compliance has profound benefits:

• Better user experience: Digital accessibility best practices improve the internet for everyone. Users can navigate your content easily, which often means more sales, more engagement, and better word of mouth.

• Reduced legal risks: Adopting WCAG helps limit the risk of a lawsuit under the AODA or other non-discrimination laws, such as the ADA. 

• Increased traffic: An accessible design reinforces SEO best practices, attracting more users to your website.

• Regulatory readiness: Filing your accessibility compliance report before the December 31, 2026 deadline keeps your organization off the Ontario government's radar and avoids penalties.

AODA compliance isn’t optional, but it’s not a burden. Every organization should invest in digital accessibility, and the AODA’s requirements are both reasonable and achievable.

What are the Penalties for Non-compliance?

The License Appeal Tribunal(opens in a new tab) has jurisdiction over AODA enforcement (and AODA fines), and establishes strong maximum penalties for non-compliance:

• A corporation can be fined up to $100,000 CAD per day.

• Directors and officers of a corporation or organization can be fined up to $50,000 per day.

• Fines grow until the violations are resolved. 

According to the AODA’s monetary penalties scheme, the Tribunal will not assess maximum AODA fines unless an organization has a history of significant compliance violations.

Understanding AODA and WCAG 2.0

Under the AODA's Information and Communications Standards(opens in a new tab), organizations must make their websites and mobile apps accessible by conforming to WCAG 2.0 Level AA (though WCAG 2.2 is the current standard and serves as the best practice benchmark for organizations that want to stay ahead). 

Key success criteria include image alt text, color contrast ratios, keyboard compatibility, captions and transcripts for videos, semantic HTML, and visible focus indicators. Two criteria have limited exceptions under the AODA: Live captions (WCAG 1.2.4) and prerecorded audio descriptions (WCAG 1.2.5). 

For a full breakdown of WCAG requirements, conformance levels, and how to apply them to your digital content, read our WCAG compliance guide.

What Other Canadian Disability Laws Should You Know?

In Ontario, the AODA is the primary law. For federal organizations, the Accessible Canada Act applies. Additional federal laws in Canada also mandate digital accessibility:

• The Accessible Canada Act(opens in a new tab) (ACA) applies to Crown corporations, the federal public sector, and all federally regulated organizations. It requires accessible digital communications.

• The Canadian Human Rights Act(opens in a new tab) prohibits discrimination on the basis of disability, religion, race, and other criteria. It applies to Canadian Federal Government employees and service providers.

Public sector organizations must meet Canada’s Standard on Web Accessibility(opens in a new tab) to comply with the ACA. Like the AODA, the federal Standard on Web Accessibility incorporates WCAG 2.0 Level AA by reference.

The provincial governments in Canada have also passed legislation to ensure equal rights for all, regardless of ability. The Accessibility for Manitobans Act(opens in a new tab) (AMA) and the Accessible Saskatchewan Act(opens in a new tab) (ASA) establish requirements for public and private sector organizations in their respective provinces.

Additionally, if your company operates within Canada and the U.S., you’ll need to comply with the ADA and Section 508.

Ultimately, if your website meets the Level AA requirements of the latest version of WCAG, you’re in a great position for compliance — regardless of where your business is located or your specific industry.

Testing options like automated and manual tests, user feedback, and record of issues and fixes.

Testing Your Website for AODA Compliance

Ontario’s provincial government provides several tips for testing websites for accessibility(opens in a new tab), which we summarize below:

1. Use a combination of automated and expert accessibility tests.

Automated tools like AudioEye's Website Accessibility Checker perform 400+ automated checks against WCAG Level AA criteria, helping you identify common issues quickly. However, automated testing alone is not enough. Expert human testing using screen readers and other assistive technologies catches more high-impact barriers that automation cannot reliably detect, making the combination of both approaches the most thorough path to compliance.

2. Listen to user feedback.

Customer feedback can help guide your accessibility initiative. By publishing an accessibility statement, you can inform people of your website’s current level of accessibility and give them an easy way to report issues.

3. Keep a record of accessibility issues and fixes.

Keep track of your site’s current barriers and the steps you’ve taken to make improvements. Tracking key milestones can keep your team engaged in the process (and may be helpful if you’re asked to prove your AODA compliance).

4. Make sure your team understands the importance of accessibility.

Consider investing in digital accessibility training courses from qualified experts.

Maintain an AODA-Compliant Website With Help From AudioEye

At AudioEye, we’ve built the industry’s most comprehensive platform for web accessibility testing and remediation. Our solution audits your content against current WCAG Level AA success criteria, performing a battery of over 400 tests to find potential accessibility barriers — and fixes many common issues as the page loads, providing users with a more accessible experience.

We combine powerful automation with expert testing and remediation, which helps us detect and fix issues that cannot be caught with automation alone. Our Issue Reporting dashboard helps you keep track of your progress and provides guidance for fixing issues that require human support.