O. Reg. 191/11 · report due 31 December 2026 · 890 CAD a year
AODA compliance: what it means, what it costs, and what is actually checked.
Compliance under the AODA is not a certificate you buy. It is a set of obligations that scale with the size of your organisation, a report you file yourself, and evidence you hold in case anyone asks. This page sets out which duties apply at which size, what the web requirement really says, what the report asks for, and where a signed external record changes your position.
Signed by Goldman Services INC, Richmond Hill, Ontario.
Duties by organisation size
The single most useful table in this area, because almost every argument about AODA starts with somebody applying the wrong row.
| Duty | Small organisations | 20 or more employees | 50 or more |
|---|---|---|---|
| Accessibility policy | Required | Required | Required and published |
| Multi-year plan | Not required | Not required | Required and published |
| Accessible formats on request | Required | Required | Required |
| Feedback process | Required | Required | Required and accessible |
| Training | Required | Required | Required with records |
| Web content conformance | Good practice | Applies | Applies |
| Compliance report | Not required | Required | Required |
The counting rules matter more than most organisations expect, because part-time staff count and the thresholds are about employees in Ontario rather than worldwide headcount. A company with four hundred people globally and eighteen in Toronto is in a different position from one with twenty-two in Toronto.
What the compliance report asks
Organisations expect a form with attachments and a reviewer. It is neither.
The report itself is short and declarative. You confirm, item by item, that the applicable requirements have been met. There is no upload of evidence, no auditor's signature field, no technical annex.
That design is deliberate and it puts the weight elsewhere: on the accuracy of what you declare, and on your ability to support it afterwards. The Act provides for penalties including for false or incomplete filings, and a director signing a declaration is entitled to ask what it rests on.
So the practical question is not how to fill the form. It is what you would send if somebody asked you to substantiate line four of it eight months later.
The web requirement in one paragraph
Everything the regulation says about websites fits in two sentences, and both of them matter.
Internet websites and web content must conform to WCAG 2.0 level AA, other than the success criteria for live captions and pre-recorded audio description. Web content means what you publish, including documents you upload, forms hosted on a subdomain and pages produced by a booking system operating under your brand.
Testing at WCAG 2.2 AA, as we do, covers 2.0 entirely and adds the later criteria on focus visibility, dragging alternatives, target size, consistent help and accessible authentication. The version detail is on the requirements page, and what those newer criteria change is on the audit page.
Where organisations actually get caught
Ten years of AODA enforcement suggests the risk is not where most compliance budgets go.
Not in the report, which nobody reviews at filing. In three other places.
A job applicant who cannot apply. Recruitment forms are the most common source of formal complaints, because the disadvantage is obvious and documented, and because employment matters attract advice faster than consumer ones.
A customer who cannot complete a service. Booking, payment, account management. The complaint arrives through the feedback process the regulation requires you to have, and the answer you give is the thing that decides what happens next.
A procurement questionnaire. Public bodies and large enterprises in Ontario increasingly ask suppliers to evidence conformance, and an untested declaration is a weak answer when the buyer asks for the report behind it.
What we do, and what stays with you
The division is worth stating in writing before anyone signs anything.
Goldman Services INC, an Ontario corporation registered under number 1000334564 at 175 West Beaver Creek Rd, Unit 10, Richmond Hill, tests your web content and signs the conformance record: pages and flows tested, technology used, date, criteria met and not met, with a public code anyone can verify.
Alongside it: the findings report your team works from, a hosted feedback channel, monthly re-testing for the year and five years of retained records.
What stays with you is the organisational half — the policy, the multi-year plan, training, employment practices, accessible formats, and filing the report itself. No supplier can discharge those, and one offering to is describing something narrower than it sounds.
A timeline that still works
There is enough time before December, but the scarce resource is not ours.
Order now and the record is signed within five business days, describing the site as it is today. Use the findings through the autumn to close the blocking items, which on a typical corporate site number between two and six and are usually hours of work each. Re-test monthly so each fix is confirmed and each regression caught.
By December the declaration rests on a record updated the month before, rather than on an assumption made a year earlier. Leaving it to November has a specific cost that has nothing to do with our capacity: development time in Ontario becomes scarce as the deadline approaches, and a finding that takes two hours in September takes two weeks to schedule in December.
890 CAD a year for the Canadian plan, or 1,990 € if you also need the European statement and the British report on a single renewal date. The federal duties, if they apply to you, are on the Accessible Canada Act page.
The five standards, briefly
Worth ten minutes even if you only own the website, because the rest will arrive on somebody's desk.
The regulation groups obligations into five areas, and most organisations only ever hear about one of them. Knowing the shape prevents the common surprise where a company has spent a year on the website and nothing on the rest.
Information and communications. Websites and web content, accessible formats on request, feedback processes, and emergency procedures published for the public. This is the area we test and sign for.
Employment. Recruitment notices, accommodation during the hiring process, individual accommodation plans, return to work, performance management and redeployment. Almost entirely an HR matter, and the area where a barrier is most likely to be raised formally.
Transportation. Applies to transportation providers and to organisations that provide transportation as part of their service.
Design of public spaces. New construction and major redevelopment of paths, parking and service counters.
Customer service. Historically a separate standard, now folded in: training, service animals, support persons, notice of disruptions.
What we are not selling you
It is worth being blunt, because the market around Ontario deadlines contains a good deal of noise. We do not issue AODA certification, because no private company can: the province does not accredit certifiers. We do not file your report, because the filing is a declaration by your organisation. We do not train your staff, write your multi-year plan or audit your parking lot.
What we do is the part that is testable, documentable and signable: the web conformance record that supports the declaration you file, and the evidence file behind it. If a supplier tells you they can make you AODA compliant end to end, ask them which of the five standards they intend to deliver, and how.
Ontario in a wider picture
Relevant if Ontario is one of several markets rather than the only one.
Many organisations that fall under the AODA also sell into the United States, into Europe, or both, and the temptation is to treat each as a separate project with a separate supplier and a separate calendar. The testing underneath is the same in every case: a person working through the site with a keyboard and a screen reader, against WCAG.
What differs is the document at the end. Ontario needs a conformance record supporting a self-declaration. The European Union needs a public statement written to Annex V and signed by an entity established in the Union, described on the EAA page. The United Kingdom needs a dated report against WCAG 2.2 AA that procurement can read, set out on the UK page. American buyers typically ask for a conformance report in the template their procurement team knows, covered on the VPAT page.
Running one audit and producing the documents each market expects is both cheaper and safer than running three, because three suppliers produce three sets of findings that will eventually contradict each other in public. That is the reasoning behind the global plan and its single renewal date.
If the deadline is close and nothing has been done
Start with the scan today, order the audit the same day, and publish nothing until the record is signed. Five business days later you have a document describing the site as it actually is, with the open items named, which is a lawful and defensible position even if the fixes are still pending.
Then triage. Fix the blocking items first, because those are the ones that stop a person completing a task and the ones a complainant will describe. Hand the content list to whoever publishes pages. Let the moderate items wait for the next release; nobody is served by delaying the declaration until the site is perfect, and no site ever is.
Compliance questions
What does AODA compliance mean in practice?
Meeting the standards in O. Reg. 191/11 that apply to your organisation, and filing the compliance report when you are above the employee threshold.
Who has to comply?
Organisations with employees in Ontario. Duties scale with size, and the reporting duty starts at 20 employees.
What is the next deadline?
31 December 2026 for the compliance report.
Which standard applies to websites?
WCAG 2.0 level AA, excluding live captions and pre-recorded audio description.
Is WCAG 2.2 acceptable?
Yes, and it exceeds the requirement, since 2.2 contains everything 2.0 requires.
Do we need an external audit?
The report is a self-declaration. External testing is what makes the declaration defensible.
Does AODA apply to companies outside Ontario?
Yes, if they have employees in the province, regardless of where the head office is.
Are non-profits covered?
Yes, on the same employee thresholds as businesses.
What else does the regulation require?
An accessibility policy, a multi-year plan for larger organisations, accessible formats on request, a feedback process, training and employment practices.
Can you file the report for us?
No. Filing is done by the organisation. We prepare and sign the web conformance record behind it.
What are the penalties?
The Act provides for administrative penalties, including for failing to file.
What happens if we miss the deadline?
File as soon as possible and be able to show the work. Evidence of testing matters more than the exact date of filing.
How long does the testing take?
Five business days from a complete form.
What does the Canadian plan cost?
890 CAD a year, including the audit, the signed record, the feedback channel, monthly re-testing and five years of records.
Do you cover the federal side too?
The Accessible Canada Act is separate; it is covered on its own page.
What if our site fails?
The record describes what was found and you get the prioritised fix list. That is a better position before a deadline than an untested declaration.
Do you fix the website?
No. We test, document and sign; your team implements.
Where do we start?
Free scan, then the order form.