Know what you are certifying before December 31.
Ontario businesses and non-profits with 20+ employees must file an accessibility compliance report. The public website requirement applies at 50+ employees. Those are different thresholds, and they change what your organization needs to verify.
Reports are due December 31, 2026.
For Ontario businesses and non-profits with 20 or more employees.
Designated public sector organizations were due December 31, 2025.
The thresholds in plain language
Employee count determines both the reporting requirement and which accessibility obligations apply. 20 or more employees means you file. 50 or more means you file and the website standard applies.
| Ontario employees | 2026 report? | AODA website requirement? | Multi-year accessibility plan? |
|---|---|---|---|
| 1–19 | No | No specific IASR website requirement | No |
| 20–49 | Yes | No specific IASR website requirement | No |
| 50+ | Yes | Yes · WCAG 2.0 Level AA, with listed exceptions | Yes |
| Designated public sector | Filed by December 31, 2025 | Yes, regardless of size | Yes |
The regulation names WCAG 2.0 Level AA. Test to WCAG 2.2 Level AA as the practical target: it contains every 2.0 criterion, and procurement questionnaires and the US Department of Justice rule have already moved to newer versions.
Sources: Ontario accessibility compliance reporting guidance, Ontario accessibility rules for businesses and non-profits, Ontario website accessibility guidance, and O. Reg. 191/11. Verify your organization’s category and obligations against the official materials or qualified counsel.
It is a self-report, not a badge.
A senior officer or another responsible person with authority to bind the organization certifies that the required information is complete and accurate.
Confirm the employee band
Count the Ontario workforce using the official guidance and confirm whether the website and plan requirements apply.
Read the live portal questions
Do this before answering anything. Identify which policy, training, accessible-format, employment, and website evidence supports each answer.
Verify the public website
If the website requirement applies, a clean automated scan is not enough. Test representative templates and real tasks with keyboard and assistive technology.
Document gaps and ownership
Record what is unresolved, who owns it, and the planned timing. Ask counsel how any unresolved issue should be reflected in the filing.
Filing does not end the obligation.
- The next report in this cycle is due December 31, 2029. The website standard applies every day in between.
- Keep the test records and remediation records behind each answer. They are what you produce if the filing is questioned.
- Keep the accessibility policy, the multi-year plan, and the accessibility statement current as the site changes.
- Re-test after redesigns, platform migrations, and major content changes, not only before the next filing.
If you are also a public company, the investor relations section carries third-party content that a general review misses. See what an IR site review covers.
If you build sites for Ontario clients, a redesign shipping in 2026 is what they will be certifying. See the agency partner engagement.
The questions that change the scope
We have 20–49 employees. Do we still need a website audit for the filing?
You must file the 2026 report, but Ontario’s IASR public website requirement applies to large organizations with 50+ employees and designated public-sector organizations. Other obligations, procurement expectations, or the Ontario Human Rights Code may still be relevant; discuss edge cases with counsel.
Which WCAG version applies under AODA?
The codified Ontario website standard is WCAG 2.0 Level AA, except live captions and pre-recorded audio descriptions. Testing to WCAG 2.2 Level AA covers that bar and the newer criteria procurement and US regulators now name, but the 2.0 AA statement is the current AODA filing bar.
Can a scanner prove our site conforms?
No. Automated tools are useful candidate detectors, but they cannot determine whether many interactions, labels, focus behaviours, error messages, or user tasks work for people using assistive technology.
What if we cannot resolve every barrier before filing?
The truthful answer on the report is a legal and governance decision for your organization. The technical engagement can document what was found and create a remediation plan; counsel should advise on the filing response.
What are the penalties for not filing?
Ontario lists administrative penalties for non-compliance, up to $100,000 per day for corporations in the most serious cases. The amounts and how they are applied are set out on ontario.ca. Whether any of it applies to a given organization is a question for counsel.
Find out what your organization can support with evidence.
Bring the employee band, the public URL, and the person responsible for the filing.