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AODA: Ontario's Web Accessibility Requirements and Compliance Guide
Introduction
The Accessibility for Ontarians with Disabilities Act (AODA) is one of North America's first comprehensive accessibility laws. Passed in 2005 and progressively implemented since, the AODA requires all organizations serving the public in Ontario—including private businesses, non-profits, and government—to remove accessibility barriers and make digital content accessible.
Unlike federal accessibility laws, the AODA is proactive and prescriptive, requiring ongoing accessibility improvements rather than only addressing complaints. Organizations can face penalties of up to $100,000 per day for non-compliance.
Legal Disclaimer
A11yscan is not a law firm and does not provide legal advice. We operate under best practices based on WCAG Guidelines, ADA requirements, and applicable jurisdictions. Courts don't always agree on terms and expectations for web accessibility, and legal standards can vary by jurisdiction. However, an accessible website works better for all users regardless of legal requirements. For specific legal guidance, consult with a qualified attorney specializing in accessibility law.
What is AODA?
The Accessibility for Ontarians with Disabilities Act (AODA) is Ontario provincial legislation that mandates barrier removal in all sectors. It covers private businesses, non-profit organizations, public sector bodies, and public transportation systems.
Core Principle
The AODA requires organizations to treat accessibility as an ongoing responsibility, not a one-time project. All organizations must:
- Develop accessibility policies
- Create accessibility plans
- Report on progress annually
- Provide feedback mechanisms
Official information: Accessibility for Ontarians with Disabilities Act (Ontario e-Laws)
Technical Requirements: WCAG 2.0 Level AA
The AODA Information and Communication Standard requires web content meet WCAG 2.0 Level AA accessibility standards.
Current Requirements (as of 2025)
- All new websites must be WCAG 2.0 AA compliant
- Existing websites must be remediated to WCAG 2.0 AA
- Web applications and digital tools must be accessible
- PDF documents must be tagged and accessible
- Video content must have captions and audio descriptions
- 4.5:1 color contrast for text (minimum)
- Keyboard navigation throughout
- Screen reader compatibility
WCAG 2.0 AA Key Requirements
- Perceivable: Content must be distinguishable from background
- Operable: All functionality keyboard accessible
- Understandable: Clear language and predictable navigation
- Robust: Compatible with assistive technologies
Learn more: WCAG 2.0 Quick Reference
Scope and Coverage
The AODA applies broadly to organizations operating in Ontario that provide goods, services, or facilities to the public.
Who Must Comply
- Private businesses (all sizes)
- Non-profit organizations
- Educational institutions
- Healthcare providers
- Government agencies
- Public transportation (Metrolinx, TTC, etc.)
- Any organization with 50+ employees
Limited Exemptions
- Microenterprises (fewer than 50 employees) have extended timelines
- Some government services covered under different requirements
- Undue hardship provisions (rarely granted)
Compliance requirements by organization size: Ontario AODA Compliance Guide
Compliance Timeline and Deadlines
The AODA has progressive implementation deadlines that have largely passed, but ongoing compliance remains mandatory:
Completed Milestones
- January 1, 2012: All new websites must be WCAG 2.0 A compliant
- January 1, 2014: All websites must be WCAG 2.0 AA compliant
- January 1, 2015: Public websites fully accessible
Ongoing Requirements
- All digital content must maintain WCAG 2.0 AA compliance
- New websites/content must be accessible from launch
- Accessibility statements required on websites
- Annual progress reporting mandatory
- Feedback mechanisms must be in place
Enforcement and Penalties
The AODA is enforced by the Ontario Human Rights Commission and the Accessibility Standards Development Council (now Service Ontario). Non-compliance carries significant penalties.
Potential Penalties
- Daily fines up to $100,000 for individual violations
- Daily fines up to $100,000 for corporate violations
- Orders to remediate accessibility barriers
- Injunctions preventing business operations
- Public reporting of non-compliance
How Violations Are Enforced
- Complaints filed with Ontario Human Rights Commission
- Ministry of Labour investigations
- Private civil lawsuits for damages
- Proactive compliance inspections (rare)
Filing a complaint: Ontario Human Rights Commission
Steps to Achieve AODA Compliance
Organizations operating in Ontario should implement a structured accessibility program:
Phase 1: Assessment
- Audit all websites and digital content against WCAG 2.0 AA
- Identify accessibility barriers
- Assess organizational capacity
- Set realistic remediation timeline
Phase 2: Planning
- Develop accessibility policy
- Create multi-year accessibility plan
- Allocate resources and budget
- Assign accessibility coordinator
- Publish accessibility statement
Phase 3: Remediation
- Fix identified accessibility issues
- Train staff on accessibility
- Update procurement policies
- Establish feedback mechanisms
Phase 4: Ongoing Compliance
- Maintain accessibility in new content
- Regular accessibility audits
- Respond to accessibility feedback
- Annual reporting and updates
AODA implementation resources: Ontario AODA Standards
Key Takeaways
- AODA applies to all organizations in Ontario serving the public
- WCAG 2.0 Level AA is the mandatory standard
- Compliance deadlines largely passed; ongoing compliance now required
- Penalties can reach $100,000 per day per violation
- Accessibility must be integrated into organizational planning
- Annual reporting and feedback mechanisms required
- Accessible websites serve all users better