AODA

The Accessibility for Ontarians with Disabilities Act, commonly known as the AODA,
is an Ontario law designed to identify, remove and prevent barriers for people with
disabilities.

The Act applies to the Ontario government, designated public-sector organisations,
businesses and non-profit organisations that provide goods, services, facilities,
employment, accommodation or other activities in Ontario.

Website accessibility is one part of the AODA framework. Covered organisations must
also consider accessible customer service, employment, information and communication,
transportation and the design of public spaces.

What is the AODA?

The Accessibility for Ontarians with Disabilities Act was enacted in 2005. Its
purpose is to develop, implement and enforce accessibility standards so that barriers
affecting Ontarians with disabilities are identified, removed and prevented.

The Act established a target of achieving accessibility in Ontario on or before
January 1, 2025. That date did not end the legal obligations. Organisations must
continue complying with applicable standards, maintaining accessibility policies
and addressing new barriers as services and technology change.

What accessibility standards exist under the AODA?

Ontario accessibility requirements are primarily set through the Integrated
Accessibility Standards Regulation and the Customer Service Standard.

Who must comply with AODA website requirements?

As of January 1, 2021, public websites and web content must meet the applicable
accessibility requirements when the organisation is:

• A designated public-sector organisation.
• A business with 50 or more employees in Ontario.
• A non-profit organisation with 50 or more employees in Ontario.

The organisation that controls the website, either directly or through a contractual
relationship, remains responsible for meeting the requirements.

Smaller organisations may still have other AODA duties, Ontario Human Rights Code
obligations or contractual accessibility requirements even when the specific public
website rule does not apply.

Which websites and content are covered?

The public website accessibility requirements apply to public-facing websites and
web content published after January 1, 2012.

Relevant digital content may include:

• Corporate and organisational websites.
• E-commerce websites.
• Customer and member portals available to the public.
• Online forms and applications.
• Public documents and downloadable files.
• Videos and multimedia.
• Booking and registration processes.
• Public information and support content.

Content published before January 1, 2012 is generally outside the specific web-content
requirement unless it is significantly updated. However, organisations may still
need to provide that information in an accessible format upon request.

What accessibility standard is required?

Covered public websites and web content must generally conform to the Web Content
Accessibility Guidelines 2.0 Level AA.

The Ontario regulation contains exceptions for:

• WCAG 2.0 Success Criterion 1.2.4, Captions (Live).
• WCAG 2.0 Success Criterion 1.2.5, Audio Description (Prerecorded).

Although WCAG 2.0 is the version referenced by the current Ontario regulation,
organisations developing or redesigning digital services should consider newer
accessibility practices where practical. Newer WCAG versions build on WCAG 2.0 and
address additional barriers involving focus, target size, dragging and authentication.

Learn more about the
Web Content Accessibility Guidelines.

What does WCAG Level AA cover?

Common AODA website accessibility barriers

• Images without meaningful alternative text.
• Forms without persistent labels.
• Error messages that are not connected to fields.
• Insufficient text or component contrast.
• Keyboard-inaccessible menus, buttons or dialogs.
• Missing visible focus indicators.
• Heading levels that do not reflect content structure.
• Videos without captions.
• PDF documents without tags or logical reading order.
• Content that breaks when text is enlarged.
• Dynamic updates that are not announced to assistive technologies.
• Third-party booking, payment or chat tools with inaccessible controls.

Are intranets and extranets covered?

The specific WCAG website requirement does not generally require internal intranets
and extranets to meet WCAG 2.0 Level A or AA.

However, employers still have accessibility and accommodation duties. If an employee
asks for information in an accessible format or requires communication support, the
organisation must work with the individual to address the need.

Accessible internal systems can also reduce workplace barriers involving recruitment,
training, performance management, scheduling and employee communication.

Accessible formats and communication supports

Organisations must notify the public and employees that accessible formats and
communication supports are available upon request.

When a person requests accessible information, the organisation should consult with
them to determine an appropriate format or support.

Accessible formats may include:

• Accessible HTML.
• Tagged PDF.
• Large print.
• Plain-language content.
• Audio.
• Braille.
• Electronic formats compatible with assistive technology.

Organisations cannot charge more for an accessible format than they charge for the
original format.

When content cannot be converted

In limited circumstances, information may not be technically convertible into an
accessible format.

When conversion is not possible, the organisation should:

• Explain why the information cannot be converted.
• Provide a summary of the information.
• Explore another accessible method of communicating the content.
• Consult with the person requesting access.

Difficulty, inconvenience or the use of an old content-management system should not
automatically be treated as proof that accessibility is impossible.

What is an accessibility policy?

Organisations must develop accessibility policies describing how they meet their
obligations.

Organisations with 50 or more employees must generally document these policies and
make them publicly available in an accessible format upon request.

An accessibility policy can address:

• Accessible customer service.
• Information and communication.
• Employment practices.
• Training.
• Procurement.
• Feedback and complaints.
• Digital accessibility.
• Responsibility and governance.

Multi-year accessibility plans

Organisations with 50 or more employees and designated public-sector organisations
must prepare a multi-year accessibility plan.

The plan should:

• Identify accessibility barriers.
• Describe actions to prevent and remove barriers.
• Set priorities and timelines.
• Assign responsibility.
• Be posted on the organisation’s website.
• Be available in an accessible format upon request.
• Be reviewed and updated at least every five years.

Digital accessibility should be included where websites, applications, documents
and online services are important to employees or the public.

Accessibility compliance reports

AODA compliance reporting thresholds are different from the website threshold.

Businesses and non-profit organisations with 20 or more employees must file
accessibility compliance reports. Designated public-sector organisations also have
reporting obligations.

For businesses and non-profit organisations, the next reporting deadline is
December 31, 2026.

Organisations should keep supporting evidence for every answer submitted in a
compliance report.

What evidence should organisations retain?

• Accessibility policies.
• Multi-year accessibility plans.
• Staff-training records.
• Website and application audits.
• Pages and user journeys tested.
• Accessibility findings and remediation records.
• Verification results.
• Requests for accessible formats.
• Feedback and complaint records.
• Vendor accessibility documentation.
• Completed compliance reports.

How should an AODA website audit be performed?

A reliable audit should combine several testing methods.

Automated scanning

Automated tools can identify repeatable technical findings across large numbers of
pages, including missing attributes, contrast failures and structural issues.

Manual review

Human review is needed to assess content meaning, keyboard behavior, form errors,
heading hierarchy and complex components.

Assistive-technology testing

Important journeys should be tested with tools such as screen readers, keyboard-only
navigation and magnification.

Functional journey testing

Testing should confirm that users can complete real tasks such as registration,
purchasing, booking, submitting a form or accessing support.

How to build an AODA remediation process

1. Define the scope:
   identify public websites, applications, documents and critical user journeys.
2. Audit representative content:
   test shared templates, components and important workflows.
3. Validate findings:
   confirm which issues create genuine user barriers.
4. Prioritise:
   address issues based on impact, frequency and business importance.
5. Assign ownership:
   route issues to design, development, content, product or QA.
6. Remediate:
   correct shared components and repeated templates where possible.
7. Verify:
   retest each correction before closing the finding.
8. Document:
   preserve findings, decisions, fixes and verification evidence.
9. Monitor:
   review accessibility after future releases and content changes.

Third-party platforms and vendors

Organisations may remain responsible for the accessibility of a website they control
through a contractual relationship.

Contracts with web agencies, software vendors and platform providers should address:

• Applicable accessibility requirements.
• Testing responsibilities.
• Accessibility documentation.
• Known product limitations.
• Remediation timelines.
• Verification and acceptance testing.
• Responsibilities after upgrades or redesigns.

Vendor claims should be reviewed and tested rather than accepted without supporting
evidence.

Enforcement and penalties

Ontario can use inspections, director’s orders and administrative penalties to
enforce AODA requirements.

The Act also provides offence penalties on conviction of up to CAD 50,000 per day
for an individual and CAD 100,000 per day for a corporation.

These maximum offence fines should not be confused with every administrative penalty.
The actual enforcement response depends on the violation, circumstances, applicable
regulation and decisions made by the responsible authority.

Why accessibility must be maintained

A website that meets accessibility requirements today can develop new barriers after
a redesign, plugin update, new form, uploaded PDF or third-party integration.

Organisations should include accessibility in:

• Design-system requirements.
• Development reviews.
• Content-publishing procedures.
• Quality-assurance testing.
• Vendor procurement.
• Release management.
• Recurring monitoring.

How Pluro supports AODA accessibility work

Pluro is an accessibility workflow platform that helps teams manage digital
accessibility findings from detection through verified remediation.

Organisations can use Pluro to centralise automated and manual findings, capture
behaviour evidence, assign responsibilities, provide remediation guidance and retain
verification history.

This can support an organisation’s digital accessibility process by creating a clear
record of barriers, owners, corrections and verification across websites and teams.

Pluro is not a legal adviser, an overlay or a one-click compliance solution. Formal
AODA applicability and legal decisions should be reviewed with qualified Ontario
professionals.

AODA website accessibility checklist

• Confirm the organisation’s employee count and classification.
• Identify covered public websites and web content.
• Assess applicable WCAG 2.0 Level AA requirements.
• Test keyboard access, focus, forms, contrast and structure.
• Review PDFs, videos and downloadable content.
• Provide accessible formats and communication supports upon request.
• Publish applicable accessibility policies and plans.
• Train staff involved in content and service delivery.
• Include accessibility in vendor contracts.
• Verify remediation before closing findings.
• Maintain records for compliance reporting.
• Monitor accessibility after future changes.

Important notice

This page provides general information and does not constitute legal advice.
AODA obligations depend on the organisation’s size, sector, classification,
activities and applicable regulations. Review the official Ontario legislation
and obtain qualified legal advice for specific compliance decisions.

Read the official

Accessibility for Ontarians with Disabilities Act
.

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