AODA and your website: what Ontario businesses actually have to do

Every so often an Ontario business owner gets an email warning that their website is illegal, with an offer to fix it for a monthly fee. Before you pay anyone, it helps to know what the law actually asks of your business.
The rules are real, and there is a reporting deadline at the end of this year that catches a lot of businesses by surprise. Here is the plain version: who it applies to, what it requires, and what is worth doing even if it does not apply to you. It is a practical guide, not legal advice, and the province's own guidance is linked throughout.
What the law says
The Accessibility for Ontarians with Disabilities Act became law in 2005. The part that covers websites sits in the Integrated Accessibility Standards Regulation, which points to an international standard called WCAG, the Web Content Accessibility Guidelines.
Organizations it covers must meet WCAG 2.0 Level AA for their public website and web content published after January 1, 2012, except for live captions and prerecorded audio descriptions. The deadline for that was January 1, 2021. Ontario's website accessibility guide covers the details and exceptions.
Who it applies to
For private businesses and nonprofits, it depends on how many people you employ in Ontario. Count your peak number in the past twelve months, including full time, part time, seasonal and contract employees, but not outside contractors. Ontario's industry guide explains the count. Public sector organizations have their own rules.
50 or more employees. Your public website must meet the standard above, and you need a written multi year accessibility plan, reviewed at least every five years.
20 or more employees. You must file an accessibility compliance report with the province every three years. The next deadline is December 31, 2026. The report is a self declaration, and the province can audit it.
Fewer than 20 employees. No report to file, and below 50 the specific website requirement does not apply. You still have obligations: accessible customer service, staff training, providing information in an accessible format when someone asks, and a way for people to give feedback.
Ontario's Human Rights Code also applies to how you serve customers, whatever your size. A booking form everyone can use is worth having either way.
What the penalties look like
The AODA sets maximum fines, on conviction, of $50,000 a day for individuals and $100,000 a day for corporations, and directors can be held responsible too. Those are maximums for offences, not automatic charges for every defect. The Act also provides for inspections, compliance orders and administrative penalties.
For most small businesses the realistic risks are more ordinary: a missed report that prompts a review, failing an accessibility question when bidding on a contract, and losing customers who could not use your site.
What WCAG 2.0 AA means for an ordinary business site
The standard is long and technical. For a typical business website, it comes down to this:
Images that carry information need a text description. Describe what the image shows or does, not the file name. Purely decorative images should be hidden from screen readers.
Text needs enough contrast. At least 4.5 to 1 for normal text and 3 to 1 for large text. Check buttons and form states too, not just paragraphs.
Everything must work with a keyboard. Put the mouse away and press Tab. If you cannot open the menu, fill in the booking form and submit it, neither can someone who relies on a keyboard.
People must be able to see where they are. The outline that appears around a button when you tab to it is often removed because it looks untidy. Removing it is a failure.
Form fields need real labels. Grey placeholder text inside a box is not a label. It disappears as soon as someone types, and screen readers handle it inconsistently.
Headings must be real headings, in order. Screen reader users move around a page by its headings, the way everyone else scrolls.
Prerecorded video needs captions.
Text must resize to 200% without content or controls breaking. The resize text guidance explains how it is tested.
Do not rely on colour alone. A field that only turns red when something is wrong tells a colour blind visitor nothing. Say what the error is.
Documents count too. A menu, price list or intake form posted as a scanned image is unreadable to a screen reader. Publish it as a web page or a properly prepared document.
Most accessibility failures on small business sites are not missing ramps. They are design choices nobody checked.
About accessibility overlay widgets
You have seen them: a small icon in the corner that opens a panel of contrast and text size controls, sold monthly with a promise of compliance. A widget cannot label an unlabelled field or fix a booking calendar that does not work with a keyboard. The page itself has to be built correctly.
Why it matters even if you are small
Statistics Canada's 2022 Canadian Survey on Disability found that 27% of Canadians aged 15 and older had a disability. That is a lot of customers.
Accessibility work also overlaps with everything else a good site needs. Proper headings, real labels, image descriptions and readable contrast make a site easier for search engines to understand and easier for everyone to use on a phone in bright sun. It is largely the same list as the nine jobs every local site has to do, approached from a different direction.
Run your homepage through a free checker such as WAVE or Lighthouse. Fix the contrast failures, add text descriptions to images that carry information, and tab through your contact or booking form without touching the mouse. Automated checkers catch a lot but not everything, so finish with that keyboard test.
The December deadline
If your business or nonprofit has 20 or more employees in Ontario, put December 31, 2026 in your calendar and follow Ontario's reporting instructions. Gathering training records and policies takes longer than filling in the form, so start early.
Send us the link and we will review it against the fixes above and tell you what matters most. Call 647 846 6561 or email hello@bootstrappedstudios.com.
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