Jurisdictions — Americas
AODA website compliance for Ontario businesses: what agencies should actually check
The question Ontario clients are asking
You run an agency or freelance practice with Ontario clients. One of them asks: "Someone mentioned AODA — does our website need to comply? Are we late?" Here is the honest answer, and what an audit should actually cover.
What is true, verified
- The deadline has already passed. Under Ontario's Accessibility for Ontarians with Disabilities Act (AODA) and its Integrated Accessibility Standards Regulation (O. Reg. 191/11), public websites of Ontario businesses and non-profits with 50 or more employees (and public-sector organizations) were required to conform to WCAG 2.0 Level AA by January 1, 2021 (with limited exceptions for live captions and pre-recorded audio description). This is not an upcoming regulation to prepare for — it is an obligation most affected organizations are already measured against.
- The benchmark is WCAG 2.0 AA — check the version. Many tools and agencies test against WCAG 2.1 or 2.2. Ontario's regulation cites WCAG 2.0 Level AA. Testing against a newer version is not wasted work (the criteria largely contain 2.0), but a compliance claim should name the standard the law actually cites.
- Reporting is part of the obligation. Ontario requires affected organizations to file recurring accessibility compliance reports; deadlines run in multi-year cycles. Check the current filing deadline for your category on ontario.ca — it changes by cycle and organization type.
- Non-compliance carries defined penalties. O. Reg. 191/11 sets out administrative penalties, with maximums for corporations reaching six figures per day for major contraventions. Enforcement in practice has favoured compliance assistance over maximum fines — but the penalty schedule is published law, not a scare tactic. Verify the current schedule and enforcement guidance on ontario.ca before repeating a specific number to a client.
How to check a client site yourself
You do not need an enterprise contract for a first pass:
- Accessibility signals: run an automated WCAG checker (axe-core is the open-source standard) on the key templates — home, a product/service page, the contact form. Automated checks don't catch everything, but they catch the mechanical failures that surface first in complaints: missing text alternatives, unlabelled form fields, insufficient contrast.
- Consent posture: load the site cold and watch what fires before any consent. Ontario organizations handling personal information also answer to PIPEDA and, where applicable, Quebec's Law 25 for Quebec users — one honest pass should note what loads pre-consent.
- Broken links and SEO basics: find the 404s, missing titles, absent meta descriptions. Not a legal issue — but if you're auditing anyway, one pass should cover what the client will ask about next.
- Document what you saw. The single most important habit: capture the state of the page behind every finding. An audit that cannot show its evidence is an opinion.
Repeat that across a portfolio of client sites and you'll see why agencies either skip the exercise or pay monitoring-subscription prices for it.
The honest shortcut
We built SiteComply to do exactly the pass above — accessibility signals, consent posture, broken links, SEO basics — in a single $29 audit where every finding points to the exact page state we observed. White-label friendly, built for agency portfolios, and it never claims more than it verified.