The Canadian Accessibility Baseline
Canadian accessibility law does not specify a single, unified technical standard. Different laws reference different versions of WCAG, and the standards landscape continues to evolve. This page explains what the recommended Canadian baseline is, why it is WCAG 2.1 Level AA, and what organizations should know about the transition to newer versions.
What Canadian laws currently require
Leadership| Law | Required standard | Organization types |
|---|---|---|
| AODA | WCAG 2.0 Level AA | All Ontario organizations (1+ employee) |
| Accessible Canada Act (via EN 301 549) | WCAG 2.1 Level AA | Federally regulated organizations |
| Government of Canada Standard on Web Accessibility | WCAG 2.0 Level AA (update underway) | GC departments and agencies |
| Accessibility for Manitobans Act | WCAG 2.0 Level AA | Manitoba organizations |
| CRTC broadcasting accessibility | WCAG 2.0 Level AA for web-distributed content | Licensed broadcasters |
Why WCAG 2.1 over WCAG 2.0
WCAG 2.1 (published June 2018) added 17 new success criteria across three areas that WCAG 2.0 significantly underserved:
Mobile accessibility (4 criteria)
WCAG 2.0 was written before smartphones became the dominant browsing platform. WCAG 2.1 adds criteria specifically addressing touch interfaces:
| Criterion | Requirement |
|---|---|
| 1.3.4 Orientation | Content is not restricted to a single screen orientation (portrait/landscape) |
| 1.3.5 Identify Input Purpose | Form fields that collect personal information identify their purpose (enables autofill) |
| 2.5.1 Pointer Gestures | Multi-point or path-based gestures (pinch, swipe) have single-pointer alternatives |
| 2.5.4 Motion Actuation | Functionality triggered by device motion (shaking, tilting) can also be activated by UI |
Low vision (7 criteria)
WCAG 2.0’s contrast requirement (4.5:1 for text) was a starting point but left gaps for users with moderate vision loss:
| Criterion | Requirement |
|---|---|
| 1.4.10 Reflow | Content reflows to one column at 320px width (supports 400% zoom) |
| 1.4.11 Non-text Contrast | UI components and graphics have 3:1 contrast against adjacent colours |
| 1.4.12 Text Spacing | No loss of content when line height, letter spacing, and word spacing are increased |
| 1.4.13 Content on Hover or Focus | Hover/focus-triggered content is dismissible, hoverable, and persistent |
Cognitive and learning disabilities (6 criteria)
WCAG 2.0 was acknowledged to underserve users with cognitive disabilities. WCAG 2.1 adds:
| Criterion | Requirement |
|---|---|
| 1.3.5 Identify Input Purpose | Enables autofill, reducing cognitive load on forms |
| 2.5.3 Label in Name | UI components with visible text labels must include that text in their accessible name |
| 4.1.3 Status Messages | Status and error messages are programmatically determined (announced by screen readers) |
WCAG 2.2: What changed
WCAG 2.2 was published in October 2023. It makes 9 additions and 1 removal relative to WCAG 2.1:
Removed
- 4.1.1 Parsing — Removed because modern browsers handle malformed HTML gracefully. The criterion no longer adds accessibility value and was difficult to test consistently.
Added (all at Level AA unless noted)
| Criterion | Level | Requirement |
|---|---|---|
| 2.4.11 Focus Not Obscured (Minimum) | AA | Keyboard focus indicator is not fully hidden by sticky headers or overlays |
| 2.4.12 Focus Not Obscured (Enhanced) | AAA | Keyboard focus indicator is not partially obscured |
| 2.4.13 Focus Appearance | AAA | Focus indicator meets minimum size and contrast requirements |
| 2.5.7 Dragging Movements | AA | Draggable UI (e.g., sliders, sortable lists) has a single-pointer alternative |
| 2.5.8 Target Size (Minimum) | AA | Interactive targets are at least 24×24 CSS pixels |
| 3.2.6 Consistent Help | AA | Help mechanisms (chat, phone, FAQ) appear in consistent locations |
| 3.3.7 Redundant Entry | AA | Information already entered by the user is auto-populated or selectable |
| 3.3.8 Accessible Authentication (Minimum) | AA | Cognitive function tests (e.g., CAPTCHAs) are not required unless alternatives exist |
| 3.3.9 Accessible Authentication (Enhanced) | AAA | No cognitive function tests required for authentication |
WCAG 3.0: The horizon
WCAG 3.0 (previously called “Silver”) is under active development by the W3C. It represents a fundamental rethink of how accessibility conformance is measured:
| Aspect | WCAG 2.x | WCAG 3.0 (proposed) |
|---|---|---|
| Conformance model | Binary pass/fail per criterion | Scored rating system (Bronze/Silver/Gold) |
| Testing approach | Criterion-by-criterion | Outcome-based |
| Coverage | Primarily web content | Web, native apps, cognitive load, emotional response |
| Scope | 78 criteria (2.1) | Hundreds of “outcomes” |
| Stability | Stable, internationally adopted | Working draft — not stable |
Recommended standards roadmap for Canadian organizations
Leadership DeveloperMinimum (legal compliance)
- WCAG 2.0 Level AA — satisfies the AODA for Ontario organizations
Recommended (current best practice)
- WCAG 2.1 Level AA — satisfies both AODA and ACA framework; addresses mobile, low vision, and cognitive gaps not covered by 2.0
Forward-looking (new projects)
- WCAG 2.2 Level AA — adds 8 new AA criteria (removes one obsolete one); future-proofs against expected regulatory updates
Enhanced (high-impact public services)
- WCAG 2.1 Level AA + selected AAA criteria — particularly 1.4.6 Enhanced Contrast, 2.4.9 Link Purpose (Link Only), 3.1.5 Reading Level for content-heavy services
Frequently asked questions
Our legal team says we only need WCAG 2.0. Why are you recommending 2.1?
WCAG 2.1 is backwards-compatible — meeting it means you meet 2.0. There is no downside to targeting 2.1 if your legal minimum is 2.0. The additional 17 criteria in 2.1 address real barriers for real users. The question is not “do we legally have to?” but “do we want our services to work for users with low vision on mobile devices?” The answer should be yes.
How do we document our conformance level for procurement or legal purposes?
Use an Accessibility Conformance Report (ACR) based on the VPAT template (Voluntary Product Accessibility Template). The VPAT 2.4 template has separate sections for WCAG 2.0, 2.1, 2.2, and EN 301 549. Complete the WCAG 2.1 Level AA section at minimum. See Procurement & Compliance for details.
We have legacy content published before WCAG 2.1. Do we need to remediate it?
For the AODA specifically, the obligation applies to new and significantly refreshed content. Legacy content that has not been updated may fall outside the strict letter of the law — but it is still a potential source of human rights complaints if it prevents users with disabilities from accessing your services. A prioritized remediation plan for high-traffic legacy content is strongly recommended.
Should we use EN 301 549 directly instead of WCAG?
EN 301 549 incorporates WCAG by reference — meeting WCAG 2.1 Level AA satisfies the web content requirements of EN 301 549. EN 301 549 also covers non-web software, hardware, and telecommunications products. For digital products beyond websites (native apps, desktop software, kiosks), EN 301 549 provides the broader framework.
Related pages
- WCAG Overview — what WCAG is and how it is structured
- WCAG Levels Explained — A, AA, and AAA in detail with examples
- Accessible Canada Act — federal law and EN 301 549
- AODA — Ontario law and WCAG 2.0 AA requirement
- Testing and Evaluation — how to audit for conformance