31 December 2026 · 20+ employees in Ontario · self-declaration
The 31 December 2026 deadline, and what to do with the months before it.
Deadline pages usually consist of a countdown and an invitation to panic. This one is a plan: what is actually due, who files it, what the declaration rests on, why starting in September costs a fraction of starting in November, and what a realistic autumn looks like for an organisation that has not begun.
Record signed within five business days by Goldman Services INC, Ontario.
What is due, precisely
Less than most organisations imagine, and the difference matters for planning.
An accessibility compliance report, filed by the organisation, confirming that the applicable requirements of the Integrated Accessibility Standards Regulation have been met. It is a declaration: nobody audits it at the point of filing, nothing is uploaded, and no external signature is requested.
That is the whole obligation on the date. Everything else this page discusses concerns what the declaration rests on, which is where the actual exposure sits.
Why September costs less than November
The same work, started at four different moments, produces four different positions on the day of the filing.
| Starting | Testing | Development scheduling | Position on 31 December |
|---|---|---|---|
| September | Five business days | Fits the normal sprint cycle | Blocking items closed, record updated monthly |
| October | Five business days | Competes with year-end releases | Most items closed, honest statement for the rest |
| November | Five business days | Queue is full, agencies are booked | Record signed, fixes scheduled for the new year |
| December | Five business days | Nothing ships before January | Declaration rests on untested assumptions |
The testing time never changes. What changes is the queue for a developer to spend two hours on a focus style, and in Ontario that queue lengthens every week of the fourth quarter.
An autumn plan that works
Six steps, spread across three months, none of them requiring a dedicated team.
- This week: scan and order. Two minutes for the scan, ten for the scope questions. Testing starts the same day.
- Week two: record signed. The findings arrive, the conformance record is signed, and you know exactly where you stand rather than guessing.
- Weeks three and four: content items. Alternative text, link wording, headings, tables trapped in images. No developer required; usually a third of the list closes here.
- October: blocking items. Two to six, hours of work each. This is the part that stops people completing tasks, and the part a complainant would describe.
- November: re-test and confirm. Fixes verified, record reissued, moderate items scheduled into normal releases.
- December: file. The declaration rests on a record updated the month before, with any remaining items honestly documented.
Six steps, four of them yours, and none of them requiring a project plan or a dedicated team. The requirements behind each step are on the Ontario requirements page.
What the declaration exposes you to
Worth understanding before somebody signs it, because the signature is the easy part.
Filing is quick and consequence-free on the day. The consequences, when they come, arrive from two directions.
The first is a request to substantiate. The Act provides for administrative penalties, including for false or incomplete filings, and a director who has signed a declaration is entitled to ask what supports it. An organisation with a dated external record answers in an email; one without spends a fortnight reconstructing a year.
The second is a complaint. Somebody could not apply for a job, book a service or complete a purchase, and the declaration you filed becomes the document you have to reconcile with their experience. Here too, an honest record naming open barriers is a far better position than a clean declaration contradicted in two minutes.
Common questions from the boardroom
The four that come up in every approval conversation.
“Can we just file and deal with it later?” You can, and many will. The risk is not the filing, it is signing a statement about software nobody examined. The cost of examining it is fixed, known and small relative to the exposure.
“How bad is our site, realistically?” Unknown until tested, but the distribution is stable: two to six blocking items, a few dozen moderate ones, and a content list that needs no developer. Most organisations are relieved rather than alarmed by the first report.
“Is there a certificate we can show?” Not from the province and not from any private company, because Ontario does not accredit certifiers. What exists is a signed record with a public code that anyone can verify, which is what buyers and authorities actually ask for.
“What does it cost per year?” 890 CAD for the Canadian plan, or 1,990 € if you also need European and British documents on a single renewal date. The breakdown is on the cost page.
After the deadline
December is a milestone on a recurring cycle, not the end of anything.
The report is filed on a recurring cycle, so December 2026 is a milestone rather than an endpoint. What changes afterwards is the standard of proof: once an organisation has declared compliance, every subsequent complaint is read against that declaration.
That is the argument for monthly re-testing rather than another audit in three years. Each run is compared with the previous one, regressions surface within weeks, and the record is reissued when something material moves. Over a cycle this produces a dated history of what was tested, found and fixed — which is the only thing that answers a substantiation request without a fortnight of archaeology.
890 CAD a year covers all of it for the Canadian plan. If you also sell into Europe or answer British tenders, the same testing supports those documents too, as described on the EAA page and the UK page.
Who inside the organisation should own this
A structural point that decides more than any technical decision.
The filing is usually assigned to whoever has the login for the provincial service, which is rarely the person who can answer for the website. That mismatch is the single most common reason declarations get filed without anybody knowing what they rest on.
A workable arrangement has three names against it. Someone in operations or legal owns the filing and the calendar. Someone in marketing or digital owns the website and receives the content half of the findings. Someone in engineering, or at the agency, owns the technical half. The three of them need one conversation in September and a short email each month, which is considerably less coordination than most compliance obligations demand.
What does not work is assigning it to a committee. Accessibility findings are small, specific and easy to act on individually, and they die in forums designed for strategy.
The careers page deserves its own line
If the autumn budget stretches to exactly one flow, this is the one.
If your autumn budget only stretches to one flow, make it the job application. Employment obligations sit in the same regulation, the disadvantage is documented the moment a candidate cannot submit a form, and employment complaints in Ontario attract advice faster than consumer ones.
It is also usually the easiest win in the report, because application forms are built once and rarely revisited: a missing label, an error message that is only red, a file upload with no keyboard route. Two hours of work, and the highest-risk barrier in most corporate sites disappears.
If your last report was filed three years ago
A situation common enough to deserve its own section.
Many organisations are on their second or third cycle, and the pattern we see is consistent: the first report was filed carefully, the site was rebuilt twice since, and nobody re-checked whether the declaration still describes reality. The website of 2023 and the website of today share a domain and little else.
The useful exercise is not to repeat the previous work but to test what exists now. New templates bring new components, new plugins bring new focus behaviour, and the criteria themselves moved with WCAG 2.2. A site that genuinely conformed in 2023 can carry three blocking items today without anybody making a mistake — that is simply what happens when software changes and nothing checks it.
The second audit is also cheaper in effort than the first, because the structural fixes made last time are still in the shared code. What surfaces is the drift, and drift is quick to close.
Filing honestly when items remain open
The question that keeps compliance managers awake, with a clearer answer than expected.
This is the question organisations agonise over and it has a clearer answer than people expect. The declaration concerns whether the applicable requirements have been met. If some have not, the honest position is to complete the remediation before declaring, or to declare and document precisely what remains and when it closes.
What is not defensible is declaring compliance while knowing about a barrier and having no record of intending to fix it. That is the situation where a complaint turns into something more serious, and it is entirely avoidable: the same testing that reveals the barrier also produces the dated plan that shows you acted on it.
Speak to your own counsel about the declaration itself; that is a legal judgement and not ours to make. What we can supply is the factual basis for it, tested, dated and signed by a company established in Ontario.
Deadline questions
What is due on 31 December 2026?
The accessibility compliance report, filed with the province by organisations with 20 or more employees in Ontario.
Who has to file?
Businesses and non-profits with 20 or more employees in Ontario, and designated public sector organisations on their own cycle.
How are employees counted?
People employed in Ontario, including part-time, on the counting rules in the regulation and its guidance.
Where is it filed?
Through the province's online reporting service, by the organisation itself.
Do we need an audit to file?
No. The report is a self-declaration. External testing is what makes the declaration defensible afterwards.
What if we miss the date?
File as soon as possible. The Act provides for penalties including for failure to file, and being able to show work in progress matters.
What happens after filing?
Nothing immediate. Exposure appears later, through a complaint or a request to substantiate the declaration.
Does the report cover the website only?
No. It covers the applicable requirements across the standards; the web conformance is one part of it.
What web standard must we meet?
WCAG 2.0 level AA, excluding live captions and pre-recorded audio description.
Is WCAG 2.2 acceptable?
Yes, and it exceeds the requirement.
How long does testing take?
Five business days from a complete form.
Can you file for us?
No. Filing is the organisation's declaration. We prepare and sign the web conformance record behind it.
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.
When should we start?
Now rather than November: testing is fast, but development capacity in Ontario tightens as the deadline approaches.
What if our site fails?
The record says what was found, you get the prioritised list, and you file with an honest position rather than an assumption.
Is there a trial?
Seven days free, no card, with cover from day one.
Do you fix the website?
No. We test, document and sign; your team implements.
Where do we start?
Free scan, then the order form.