AODA Website Compliance: What Ontario Businesses Need to Know

Ontario’s accessibility law doesn’t only apply to ramps and doorways. Under the Accessibility for Ontarians with Disabilities Act (AODA), many organizations must make their public websites accessible to people with disabilities, including people who use screen readers, navigate with a keyboard, magnify their screen or can’t hear video audio.

This guide explains who has to comply, what the law actually requires, and how to check your own website before you hire anyone. It’s written for business owners and managers, not accessibility specialists. It isn’t legal advice; for your specific obligations, start with the Government of Ontario’s guidance (opens in a new tab).

#Who has to comply?

As of January 1, 2021, the AODA requires all public websites to be accessible if you are a designated public sector organization, or a business or non-profit organization with 50 or more employees. The requirement sits in the Integrated Accessibility Standards Regulation (O. Reg. 191/11), which sets out the information and communications standards under the Act.

Two details catch many organizations out. First, responsibility sits with the organization that controls the website, whether directly or through a contract, so hiring an agency doesn’t transfer the obligation. Second, the rules apply to websites and web content published after January 1, 2012, which covers almost every page a business has published or updated in the last decade.

#What does the AODA require for websites?

Covered organizations must make their public websites and web content conform to the Web Content Accessibility Guidelines (WCAG) 2.0 at Level AA, published by the W3C. Two Level AA success criteria are exempt: 1.2.4, captions for live audio, and 1.2.5, audio descriptions for pre-recorded video.

The regulation also recognizes that some content can’t practically be made accessible. Where an organization has made best efforts and meeting the standard isn’t practicable, certain exceptions may apply. Treat those as narrow exceptions, not a way around the requirement, and document the reasoning.

#WCAG 2.0 Level AA in plain language

WCAG is organized around four principles: content must be perceivable, operable, understandable and robust. Each principle has testable success criteria at three levels, A, AA and AAA. Level AA includes everything in Level A plus a further set of requirements, and it’s the level the AODA asks for.

WCAG 2.1 and 2.2 add criteria for mobile use, low vision and cognitive accessibility. The AODA still references 2.0, but if you’re building a new website, designing to WCAG 2.2 Level AA covers the AODA requirement and the expectations of most other standards. Our custom website design work is built to that standard from the first Figma screen.

#A practical AODA website checklist

You can check many of the most common problems yourself in under an hour. This isn’t a complete audit, but it shows quickly whether a site was built with accessibility in mind.

• Alt text: every meaningful image has a short description; decorative images are hidden from screen readers.
• Colour contrast: normal body text has a contrast ratio of at least 4.5:1 against its background, and large text at least 3:1.
• Keyboard access: you can reach and use every link, menu, button and form field with the Tab, Enter and arrow keys, and you can always see where the focus is.
• Headings: each page has one main heading and a logical heading structure, so screen reader users can jump between sections.
• Forms: every field has a visible label, required fields are identified, and error messages explain how to fix the problem.
• Video: pre-recorded video with speech has captions.
• Links: link text makes sense on its own; avoid a page full of “click here”.
• Zoom: text can be enlarged to 200% without content being cut off or overlapping.
• Page basics: every page has a descriptive title, and the page language is declared in the code.
• Documents: PDFs and other files you publish are accessible too, or offered in an accessible alternative format.

#How to test your website

Good testing combines three methods, and Ontario’s own guidance asks developers to plan for all three: automated tests, manual tests and testing with assistive technology such as screen readers.

Automated scanners are a useful start, but they can’t judge whether alt text is accurate, whether a form error is understandable or whether a menu works by keyboard. A clean automated score doesn’t prove a site is compliant. Keep a record of what you tested and when; Ontario’s guidance notes that this helps if your organization is ever asked to show that its website meets Level AA.

#Do accessibility overlays make a site compliant?

Overlays are scripts that add an accessibility toolbar or try to repair a page automatically in the browser. They can change some things on screen, such as text size or contrast, but they can’t reliably fix problems in the underlying code and content: missing form labels, poor heading structure, inaccessible custom menus or meaningless link text.

Many people who rely on assistive technology already have their own tools for size and contrast, and some find overlays get in the way. If you’re paying for an overlay instead of fixing the site, you may be paying for the appearance of compliance rather than the real thing. The durable approach is to build and maintain the site to WCAG, then keep it there as content changes.

#What to ask your web developer

Whether you’re redesigning or fixing an existing site, put accessibility in the brief. Ontario’s guidance suggests telling your developer your expectations for WCAG 2.0, the level required and your timelines, and asking for a project plan. Useful questions include:

• Have you built websites to WCAG 2.0 or 2.1 Level AA before, and can you show one?
• How will you test the site: automated tools, keyboard testing and a screen reader?
• Will our team be able to add accessible content after launch, and will you show us how?
• What happens if an accessibility problem is found after launch?

If your current site is far from compliant, rebuilding can be cheaper than patching. Our website redesign service rebuilds sites to Level AA without losing the Google rankings they’ve earned, and our website cost guide explains how scope affects budget.

#If you have fewer than 50 employees

Small organizations aren’t required to meet the AODA website rule, but there are good reasons to build accessibly anyway. Accessible sites are easier for everyone to use on a phone, load cleanly, and share much of their structure with good SEO: descriptive headings, meaningful link text, alt text and clear page titles all help search engines too. And if your business grows past 50 employees, you won’t need to rebuild.

Want a second opinion on your current site? Send us its address, and we’ll tell you honestly where it stands against WCAG 2.0 Level AA and what it would take to fix.

#Frequently asked questions