AODA Website Compliance Requirements – Ontario 2021

The Accessibility for Ontarians with Disabilities Act (AODA) has a multitude of requirements that span different entities and organizations.

In this guide, I’ll focus specifically on digital compliance (e.g., websites and web apps).

To keep things simple, I have only focused on the key requirements of the AODA.

Read the full text of the law on the website.


  • Larger entities must establish and maintain an accessibility policy and plan and make it publicly available on their website.  The document should be accessible or, at a minimum, provided in an accessible format upon request.
  • Training shall be provided to employees, volunteers, and those who provide goods and services on behalf of the organization
  • WCAG 2.0 AA is the standard for website compliance
  • Websites and web content including apps (web-based applications) must comply
  • Web content may include podcasts, social media channels, portals, and similar online platforms or hosted content
  • January 1, 2020 was the deadline for compliance for the Government of Ontario and Legislative Assembly
  • January 1, 2021 is the deadline for compliance for public sector organizations and large organizations (50 or more employees)

Compliance Services and Consultants

If your organization needs help with AODA website compliance or training, feel free to contact me at and I’ll respond to you as soon as possible.

We provide website audits, user testing, documents in accessible format (including PDF remediation), accessibility policies and plans, training, and legal support.

Who is Required to Comply?

Besides the Government of Ontario “Gov”, Legislative Assembly, every designated public sector organization “PSO”, this regulation applies to any entity that provides goods, services, or facilities to the public and has one or more employees in Ontario.

Accessibility Policies

Every organization needs to develop, implement, and maintain policies on how they will achieve accessibility through meeting AODA requirements.

These policies must be contained in publicly available documents that, upon request, will be provided in an accessible format.

Other than small organizations (less than 50 employees), obligated organizations must include a statement of commitment to meet accessibility needs of persons with disabilities.

Accessibility Plans

The Gov, Legislative Assembly, PSOs and large organizations must:

  • establish and maintain a multi-year accessibility plan
    • This plan will outline strategy to prevent and remove barriers and meet requirements
  • post the accessibility plan on their website and provide in an accessible format upon request
  • review and update the plan at a minimum of every five years

The Gov, Legislative Assembly, and public sector organizations must:

  • consult with persons with disabilities as they establish, review, and update the plan
    • same if there is an accessibility advisory committee established
  • prepare an annual status report on progress of measures taken to implement the plan and comply with the AODA
  • post the status report on their website and provide it in an accessible format

Procurement and Kiosks

The Government of Ontario, Legislative Assembly, and public sector organizations must incorporate accessibility in procurement of goods, services, facilities, and self-service kiosks.

Large and small organizations shall “have regard” to accessibility when procuring kiosks.

Note: A kiosk means any electronic terminal such as a point-of-sale device that is for public use.


Training must be provided for standards in the AODA and Human Rights Code for all persons who:

  • are an employee or volunteer with the organization,
  • participate in the development of the organization’s policies, and
  • provide goods, services, or facilities on behalf of the organization.

Also, the Gov, Legislative Assembly, PSOs, and large organizations shall keep a record of training.  Records shall include:

  • the dates of training and
  • number of individuals to whom training is provided.

Information and Communications Standards


  • Processes for feedback shall be accessible by providing for accessible formats and communication supports
  • The public shall be notified accessible formats and support exist
  • If a request is made, an organization shall respond in a timely manner
  • The organization shall consult with the person making the request to determine if the format or support is suitable

Web Content

  • The Government and Legislative Assembly both, for internet and intranet sites, shall fully conform to WCAG 2.0 AA (this is already in effect as of January 1, 2020)
  • Public sector organizations and large organizations shall conform with WCAG 2.0 AA other than:
    • success criteria 1.2.4 – live captions
    • success criteria 1.2.5 – audio descriptions
  • This requirement takes effect on January 1, 2021
  • This section applies to:
    • websites and web content, including web-based applications (apps), that an organization controls directly or through a contractual relationship that allows for modification of the product
    • web content published after January 1, 2012

Compliance Report Extension

For businesses and non-profits with 20 or more employees, the deadline to file an accessibility compliance report has been extended to June 30, 2021. (

Solutions and Help

If you need help or have any questions about the AODA, feel free to contact me at