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AODA website compliance: what Ontario businesses must do (and what it costs)

Who must make their website accessible under the AODA, which WCAG level applies, a practical checklist, and what fixing or rebuilding a site usually costs.

October 21, 20267 min read

If your business or non-profit has 50 or more employees in Ontario, your public website must meet WCAG 2.0 Level AA under the Accessibility for Ontarians with Disabilities Act (AODA), with two exceptions: live captions and pre-recorded audio descriptions. That rule has applied since January 1, 2021. Businesses with fewer than 50 employees have no specific website requirement under the AODA, although they have other accessibility duties, and an accessible site is still worth building. The cost to get there ranges from a few hours of fixes to a full rebuild, depending on how the site was made.

Below: who is covered, what the standard actually asks for, a checklist you can run yourself, and how to decide between fixing and rebuilding.

Who has to comply

The Ontario government's guidance is direct: as of January 1, 2021, designated public sector organizations and businesses or non-profits with 50 or more employees must make their public websites accessible.

A few details matter in practice:

It applies to the organization that controls the website. If an agency or freelancer built and hosts your site under contract, you are still the one responsible.
It covers public websites and web content published after January 1, 2012. Older archived content is not in scope, but anything you post or update now is.
Internal sites (intranets) are generally exempt for private businesses.
Smaller organizations still have duties. Ontario's rules for businesses with 1 to 49 employees include creating accessibility policies, even if documenting them is optional. Organizations with 20 or more employees must file an accessibility compliance report; the current deadline for businesses and non-profits is December 31, 2026, and reports are due every three years.

The compliance report is a separate obligation from the website rule, but the two meet in one place: if you have 50+ employees and file a report, you are confirming that your public website meets the standard. If it doesn't, now is the time to find out.

What WCAG 2.0 Level AA means in plain terms

WCAG (Web Content Accessibility Guidelines) is the international standard published by the W3C. Version 2.0 dates from 2008. Versions 2.1 (2018) and 2.2 (2023) added more criteria, and the W3C states that content conforming to WCAG 2.2 also conforms to 2.1 and 2.0. So if you are fixing or building a site today, aim for 2.2 AA: you meet Ontario's legal bar and you are covered if the rules are updated.

Level AA is the middle of three levels. Level A covers the basics (a page must be usable with a keyboard, images need text alternatives). Level AA adds things like minimum colour contrast, consistent navigation and visible focus indicators. Level AAA is rarely required for whole sites.

The underlying idea is that people use the web in different ways: with a screen reader, with keyboard only, with zoom at 200%, with captions, or with limited fine motor control. A compliant site works for all of them.

The checklist: what to test on your own site

You can run most of these checks in an afternoon. They won't replace a full audit, but they catch the issues we see most often on small-business sites.

Keyboard and focus

Put your mouse away. Press Tab from the top of the home page. Can you reach every link, button, menu and form field?
Can you see where you are at each step? If the focus outline disappears, that's a failure.
Can you open and close the mobile menu, pop-ups and cookie banners without a mouse? Pop-ups that trap the keyboard are a common problem.

Images and media

Every meaningful image needs alt text that describes what it shows or does. Decorative images should have empty alt text so screen readers skip them.
Videos with speech need captions. Auto-generated captions are a starting point, not a finished job; correct them.
Autoplaying video or audio needs a way to pause or stop it.

Text and colour

Body text needs a contrast ratio of at least 4.5:1 against its background (3:1 for large text). Light grey text on white is the classic failure.
Don't use colour alone to carry meaning, such as "required fields are in red."
Zoom the browser to 200%. The page should still be readable without content overlapping or disappearing.

Structure

Each page should have one main heading, with subheadings in a logical order. Screen reader users navigate by headings.
Links should make sense out of context. "Click here" and "Read more" repeated ten times don't.
The page language should be declared in the code (and set correctly on French pages if your site is bilingual).

Forms

Every field needs a visible label, not just placeholder text that vanishes when you type.
Error messages should say what's wrong and how to fix it, in text.
If you use a CAPTCHA, there must be an accessible alternative.

Documents

PDFs you publish (menus, brochures, forms) are web content too. Either make them accessible or provide the same information as an accessible web page.

Free automated tools such as WAVE or the accessibility panel in Lighthouse will flag contrast, missing alt text and labelling problems. They catch only part of the issues, though. Keyboard testing and a quick screen reader pass (VoiceOver on Mac and iPhone, NVDA on Windows) are what reveal whether the site is truly usable.

What about accessibility overlays

You've probably seen ads for a widget that claims to make any website compliant with one line of code. Be careful. These overlays add a toolbar for adjusting contrast or font size, but they don't fix the underlying code: unlabelled buttons, broken heading structure and keyboard traps are still there. Many accessibility practitioners and disabled users report that overlays interfere with the assistive technology people already use. Treat them as a convenience at most, never as your compliance plan.

When the standard allows exceptions

Ontario's guidance recognizes that some content can't reasonably be made accessible, such as certain complex diagrams or maps. You can still post it. If someone asks for it in an accessible format and you can't provide one, you must explain why and give them a summary. The guidance also suggests that if your current platform can't support compliance, you move to accessible tools at your next site refresh.

This is not a loophole for an entire website. It's for specific pieces of content after you've made a real effort.

Penalties and enforcement

The AODA allows the province to issue compliance orders and administrative penalties, and secondary sources such as Carleton University's AODA resource cite maximum fines on conviction of up to $100,000 per day for corporations and $50,000 per day for individuals and directors. In practice, enforcement typically starts with a compliance review or a missed report rather than a fine out of nowhere. The more immediate costs of an inaccessible site are lost customers, complaints, and a scramble when a large client or public-sector buyer asks you to prove compliance in a contract.

Fix or rebuild: how to decide

The right answer depends on how your current site was built.

Situation	Usually the better path
Modern site, a handful of issues (contrast, alt text, form labels)	Fix in place
Site built on a page builder with heavy custom widgets, sliders, pop-ups	Audit first; often partial rebuild of templates
Old theme, no responsive design, outdated code	Rebuild
Planning a redesign within 12 months anyway	Build the new site to WCAG 2.2 AA and fix only urgent issues now

What it costs

Prices vary widely by site size and by who does the work. As rough Canadian ranges for small and mid-sized businesses (these are orientation figures, not quotes):

Audit: an automated scan is free. A manual audit of key templates and pages by a practitioner typically runs from several hundred dollars for a small brochure site to a few thousand for a larger site with forms, booking or e-commerce.
Remediation of an existing site: a small site with common issues can often be fixed in a few days of developer time. Costs climb quickly when the problems sit inside a theme or plugin you don't control.
Rebuild: a new site built accessibly from the start costs about the same as any professionally built site of that size. Accessibility done at design time adds little; retrofitting it later is what gets expensive.

What drives the price up:

Number of unique page templates (not total pages)
Forms, booking widgets and checkouts, especially third-party ones
Video and PDF libraries that need captions or conversion
Bilingual sites, since both languages need checking
Page builders that generate messy code

One more cost people forget: maintenance. Every new blog post, image and PDF has to meet the standard too. Train whoever updates your site on alt text, headings and link wording, or the site will drift out of compliance within months.

A simple plan for the next 90 days

Confirm your headcount and obligations. 50+ employees in Ontario means the website rule applies. 20+ means you also file a compliance report.
Run the checklist above on your home page, a service page, your contact form and your most visited page.
Get a manual audit if you find more than a few issues or if your site has booking, payments or a login.
Decide fix or rebuild using the table above.
Publish an accessibility statement and a feedback method (an email or phone number where people can report problems and request alternate formats).
Keep a record of what you fixed and when. Ontario's guidance notes this helps if you are ever asked to show your site meets the standard.

Where PNE fits

Our website design work builds to WCAG 2.2 AA from the first wireframe: contrast-checked colour palettes, keyboard-tested menus and forms, proper heading structure, and bilingual pages with the right language settings. If you have an existing site, we can audit it, tell you plainly whether fixing or rebuilding makes more sense, and do the work.