Accessibility for Ontarians with Disabilities Act (AODA)

The Accessibility for Ontarians with Disabilities Act (AODA) was passed in 2005 with the goal of making Ontario accessible to persons with disabilities by January 1, 2025. It is one of the most comprehensive provincial accessibility laws in Canada and the one most directly affecting day-to-day digital work for Ontario organizations.

Who must comply?

The AODA applies to all organizations in Ontario with one or more employee, including:

  • Private sector businesses (for-profit and non-profit)
  • Ontario provincial government ministries, agencies, and Crown corporations
  • Municipalities and local boards
  • Universities, colleges, and school boards
  • Hospitals and health care organizations

The Integrated Accessibility Standards Regulation (IASR)

Web accessibility requirements come from Ontario Regulation 191/11, the Integrated Accessibility Standards Regulation (IASR). The IASR consolidates standards for:

  1. Customer Service — how you serve people with disabilities
  2. Information and Communications — websites, digital documents, feedback processes
  3. Employment — recruitment, accommodation, performance management
  4. Transportation — public transit providers
  5. Design of Public Spaces — outdoor paths, service counters, etc.

For digital teams, the Information and Communications standard is the key section.

Web content requirements

WCAG 2.0 Level AA

The IASR requires that all new and significantly refreshed public-facing websites and web content conform to WCAG 2.0 Level AA, with two exceptions:

ExceptionDetails
Live captionsOrganizations must make reasonable efforts; if not possible, provide alternative access
Pre-recorded audio descriptionsNot required for content published before January 1, 2012
Developer Designer

Compliance timelines

Organization typeWCAG 2.0 Level AWCAG 2.0 Level AA
Government of Ontario (large)January 1, 2012January 1, 2016
Large private/non-profit (50+ employees)January 1, 2014January 1, 2021
Small private/non-profit (1–49 employees)January 1, 2014January 1, 2021

Other digital obligations

Beyond WCAG, the IASR requires Ontario organizations to:

  • Provide accessible formats and communication supports on request (e.g., large print, Braille, audio, accessible digital formats)
  • Provide accessible formats in a timely manner and at no extra cost
  • Post an accessibility feedback process on their website
  • Publish an accessibility plan (large organizations) that is updated every 5 years
  • Ensure feedback forms on websites are accessible

Accessible documents

Existing documents (PDFs, Word files) must be made accessible upon request. New documents intended for public use should be accessible from the start. This includes:

  • Forms with proper field labels and tab order
  • PDFs with tagged structure, alt text, and reading order
  • PowerPoint files with slide titles, alt text, and logical reading order

Enforcement

Leadership

The AODA is enforced by the Accessibility Directorate of Ontario, part of the Ontario government.

Compliance reporting

Organizations must file accessibility compliance reports to demonstrate they are meeting IASR requirements. Filing periods:

Organization typeFiling schedule
Ontario governmentEvery year
Large organizations (50+ employees)Every 3 years
Small organizations with 20+ employeesEvery 3 years
Organizations with fewer than 20 employeesNot required to file

Penalties

Violation typeMaximum penalty
Individuals$50,000 per day
Corporations and unincorporated organizations$100,000 per day

These penalties are among the highest in North America for accessibility non-compliance. The Accessibility Directorate has the power to conduct audits and issue orders.

What “significantly refreshed” means

The AODA applies to new content and content that is significantly refreshed. Organizations sometimes misinterpret this as meaning legacy content is permanently exempt. Courts and the Accessibility Directorate consider a significant refresh to include:

  • A major website redesign
  • Adding a new section or feature to an existing site
  • Substantially rewriting or replacing content

Minor copy edits are not typically considered a significant refresh. However, practically speaking, every content update on a site that has not been made accessible is an opportunity to bring that content into compliance.

Frequently asked questions

Does the AODA apply to intranet sites?

The AODA applies to websites and web content that members of the public access. Internal intranets used only by employees are not subject to the public-facing web standards, but the AODA’s employment standard requires employers to provide accessible formats and communication supports to employees with disabilities upon request — which effectively means intranets should be accessible.

Does the AODA apply to social media?

Social media platforms themselves are not under Ontario’s control. However, the content you post on social media — images, videos, documents — should follow accessibility best practices where possible: alt text on images, captions on videos, accessible links in posts.

We're a national company with offices in Ontario. Does AODA apply to our whole site?

If your organization operates in Ontario and has employees in Ontario, the AODA applies to you. There is no geographic exception for the web content standard — your public-facing website is accessible to Ontarians regardless of where your servers are located.

Our small non-profit has 5 volunteers. Do we need to comply?

The AODA applies to organizations with one or more employee. Volunteers do not count as employees for this purpose. An organization with no paid employees is not covered by the AODA, but may still be subject to the Ontario Human Rights Code if it provides services to the public.

Is there a grace period for old websites?

No. The WCAG Level AA compliance deadlines have passed. The only partial exception is for content that has not been significantly refreshed since before the applicable deadline — but this is a narrow exception and provides no protection if a person files a complaint.