AODA and Canadian Website Accessibility Requirements

Canada has a multi-layered framework of accessibility legislation at both the federal and provincial levels. This guide covers the key Canadian accessibility laws that include requirements for website and digital accessibility.

Federal: Accessible Canada Act (ACA)

The Accessible Canada Act (ACA) was adopted in 2019 as federal legislation aimed at achieving a barrier-free Canada by 2040. The Act applies to federally regulated organizations, including:

  • Federal government departments and agencies
  • Crown corporations
  • Federally regulated private-sector organizations (banking, telecommunications, transportation, broadcasting)
  • The Canadian Armed Forces and the Royal Canadian Mounted Police

Technical Standards

The ACA does not prescribe a single technical standard, but the federal government has adopted CAN/ASC-EN 301 549:2024 as a National Standard of Canada. For web content, conformance with WCAG 2.1 Level AA is treated as equivalent to meeting the web clauses of EN 301 549.

Proposed Amendments (December 2024)

On December 21, 2024, the Accessible Canada Directorate announced a consultation on proposed amendments to the Accessible Canada Regulations. The proposed changes would require federally regulated private-sector organizations to meet web, mobile, and digital accessibility requirements:

Organization Size Definition Proposed Deadline
Large businesses More than 500 employees June 1, 2028
Medium-sized businesses 100 to 499 employees June 1, 2028

Under the proposed amendments, these businesses would need to ensure all public-facing and internal employee-facing web pages conform to the CAN/ASC-EN 301 549:2024 standard, which includes WCAG 2.1 Level AA requirements.

The proposed amendments also introduce requirements for:

  • Mobile application accessibility
  • Document accessibility
  • Accessibility training for employees
  • Accessibility procurement requirements

Provincial: Ontario (AODA)

The Accessibility for Ontarians with Disabilities Act (AODA) was enacted in 2005 with the goal of creating a fully accessible Ontario by 2025. It was one of the earliest legislative frameworks in Canada to specifically address digital accessibility.

Who Must Comply

The AODA applies to organizations in Ontario, with requirements that vary based on organization size:

Organization Type Requirements
Government of Ontario and Ontario Legislature Full compliance with all standards
Large designated public sector organizations (50+ employees) Full compliance with all standards
Large private and non-profit organizations (50+ employees) Must conform to WCAG 2.0 Level AA
Small private and non-profit organizations (1-49 employees) Must conform to WCAG 2.0 Level AA for new websites

Technical Standard

The AODA requires conformance with WCAG 2.0 Level AA for web content, with the following exceptions:

  • Success Criterion 1.2.4 (Captions - Live) is not required
  • Success Criterion 1.2.5 (Audio Descriptions - Prerecorded) is not required

While WCAG 2.0 Level AA is the legal requirement, organizations are encouraged to adopt WCAG 2.1 or 2.2 to future-proof their accessibility efforts.

Compliance Reporting

Ontario businesses and non-profit organizations with 20 or more employees must file an accessibility compliance report every three years. The next reporting deadline for private organizations is December 31, 2026.

Penalties

Organizations that fail to comply with AODA requirements can face penalties:

  • Corporations: Up to $100,000 CAD per day
  • Individuals and unincorporated organizations: Up to $50,000 CAD per day
  • Directors and officers: Up to $50,000 CAD per day

Provincial: Manitoba (AMA)

The Accessibility for Manitobans Act (AMA) was passed in 2013. Under the AMA, private sector and non-profit organizations in Manitoba are required to meet web content and application accessibility standards.

Key Deadline

Private sector and non-profit organizations must conform to WCAG 2.1 Level AA for web content and web applications by May 1, 2025.

Manitoba is notable for being the first Canadian province to require WCAG 2.1 (rather than WCAG 2.0) as the compliance standard.

Provincial: Nova Scotia

Nova Scotia's Accessibility Act was passed in 2017 with a goal of an accessible Nova Scotia by 2030. The Act establishes a process to create accessibility standards across six areas, including information and communication.

Standards for information and communication technology are under development and will specify digital accessibility requirements when finalized.

Provincial: British Columbia

The Accessible British Columbia Act was adopted in 2021. It establishes a framework for developing accessibility standards in British Columbia, aligned with the federal Accessible Canada Act.

As of 2025, the Act does not apply directly to private businesses, but this may change as standards are developed and adopted.

Summary of Canadian Accessibility Requirements

Jurisdiction Law Web Standard Applies To
Federal Accessible Canada Act (2019) CAN/ASC-EN 301 549 / WCAG 2.1 AA Federally regulated organizations
Ontario AODA (2005) WCAG 2.0 AA All organizations in Ontario
Manitoba AMA (2013) WCAG 2.1 AA All organizations in Manitoba
Nova Scotia Accessibility Act (2017) Under development To be determined
British Columbia Accessible BC Act (2021) Under development Currently public sector only

How WCAG Pulse Helps with Canadian Accessibility Compliance

WCAG Pulse supports compliance with Canadian accessibility requirements:

  • Scan against WCAG 2.0, 2.1, and 2.2 — Test your website against the standard required by your jurisdiction.
  • AODA compliance — Verify conformance with WCAG 2.0 Level AA as required by Ontario's AODA.
  • ACA readiness — Prepare for upcoming federal requirements by testing against WCAG 2.1 Level AA and EN 301 549 web clauses.
  • Manitoba compliance — Verify conformance with WCAG 2.1 Level AA as required by the AMA.
  • Continuous monitoring — Schedule regular scans to maintain compliance as your website content changes.
  • Compliance reporting — Generate reports to document your accessibility conformance for regulatory filings.

Automated testing detects approximately 30-40% of WCAG success criteria violations. For full compliance with Canadian accessibility laws, combine automated scanning with manual expert audits and assistive technology testing.

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