O. Reg. 191/11 · WCAG 2.0 level AA · 20+ employees in Ontario
What Ontario actually requires from a website, in plain terms.
The regulation is short on the web point and long on everything around it, which is why so many organisations read the wrong part. This page separates the two: what the standard demands of your website and web content, and what the surrounding obligations are — policy, plan, formats, training and the report you file. It also says clearly what we prepare, what we sign and what stays with you.
Signed by Goldman Services INC, Richmond Hill, Ontario.
The web requirement, exactly
The regulation asks that internet websites and web content conform to WCAG 2.0 level AA, other than the criteria for live captions and pre-recorded audio description. That is the whole web obligation in one sentence, and two details in it matter more than the rest.
First, it says web content, not home page. Content published on your site is covered, which includes documents you upload, forms hosted on a subdomain and pages produced by a booking system operating under your brand. Second, it names a version: WCAG 2.0. Testing against 2.2, as we do, covers 2.0 entirely and adds the later criteria, so an organisation tested at 2.2 AA is comfortably above the Ontario line.
Everything else the standard asks for
| Obligation | What it means in practice | Who does it |
|---|---|---|
| Accessibility policy | A written statement of commitment and how you meet it, made public | You, with our wording if useful |
| Multi-year plan | What will be done and when, published and reviewed | You, informed by our findings |
| Accessible formats and supports | Provide information in another format on request, in reasonable time, at no extra cost | You |
| Feedback process | A route to report barriers, accessible itself | Hosted by us if you want |
| Training | Staff trained on the standard and the Human Rights Code as it relates to disability | You |
| Employment practices | Recruitment, accommodation and return-to-work processes | You |
| Web conformance | WCAG 2.0 AA on websites and web content | Tested, documented and signed by us |
| Compliance report | Filed with the province on the legal cycle | You file; our record is the evidence behind it |
We say this plainly because the confusion costs money: a vendor who implies they can discharge the whole standard for you is selling something that does not exist. The web line is ours. The rest is organisational and belongs inside your company.
Are you above the threshold?
- Do you employ 20 or more people in Ontario, counting part-time staff on the regulation's rules?
- Do you operate a public-facing website or web content for customers or members?
- Is any of that content newer than the dates that brought existing content into scope?
- Are you a designated public sector organisation, in which case lower thresholds and additional duties apply?
- Do you already have an accessibility policy and a published multi-year plan?
- Have you filed a compliance report in a previous cycle, and can you find it?
Three yeses in the first four lines put the web requirement squarely on you, and the report deadline of 31 December 2026 is described in detail on the AODA 2026 page.
Self-declaration, and why evidence still matters
The Ontario model is self-declaration: nobody audits you before you file, and the form does not ask for a test report. It is tempting to read that as permission to declare and move on. The exposure arrives afterwards, from two directions. A director can be asked to substantiate the declaration, because the Act provides for administrative penalties including for false or incomplete filings. And a customer who meets a barrier can complain, at which point the declaration you filed becomes the document you have to defend.
An organisation with a dated, external, signed record is in a straightforward position: here is what was tested, here is what was found, here is what was fixed and when. An organisation with a declaration and nothing behind it has to reconstruct a year of history under pressure.
What we prepare and sign
Goldman Services INC, an Ontario corporation, number 1000334564, based at 175 West Beaver Creek Rd, Unit 10, Richmond Hill, tests your site and signs the web conformance record. The record states the pages and flows tested, the assistive technology used, the date, the criteria met and the criteria not met, and it carries a public code anyone can verify without contacting you.
Alongside it you receive the findings report for your developers, the hosted feedback channel, monthly re-testing for the year and five years of record keeping. If you also sell into the European Union or the United Kingdom, the same testing supports the documents described on the EAA checklist and the UK page, with one renewal date on the global plan.
A timeline that still works before the deadline
There is enough time, but not an unlimited amount, and the sequence matters. Order the audit 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. Re-test monthly, so each fix is confirmed and each regression caught. By December the declaration you file rests on a record that was updated the month before, not on an assumption made a year earlier.
Leaving it to November has a specific cost: development capacity in Ontario gets scarce as the deadline approaches, and a finding that takes a developer two hours in September takes two weeks to schedule in December. The testing is the fast part. The queue for the fix is not.
How the web requirement is usually misread
Five beliefs come up in almost every first conversation with an Ontario organisation. None of them is unreasonable, and all of them are wrong in a way that costs time later.
“Our site was built accessible in 2019, so we are covered.” A site built carefully in 2019 was probably compliant in 2019. Since then it has had a theme update, a new booking widget, a cookie banner, three campaign landing pages and a chat button. Each was added in good faith and none was tested. The regulation applies to the site as it is today, not as it was at launch.
“The PDF menu is not part of the website.” Uploaded documents are web content. An untagged brochure that carries information available nowhere else is a barrier, and it is the kind an inspector notices immediately because it is trivial to check.
“Our booking system belongs to a supplier.” It operates under your brand, in your customer journey. The supplier may owe you a contractual remedy, but the obligation in Ontario sits with the organisation providing the service to the public.
“We have fewer than 50 employees so the web rule does not apply.” The employee bands affect some duties under the standard, not the existence of the web conformance requirement for organisations above the small-organisation threshold. Check the counting rules rather than the folklore.
“We put an accessibility widget on the site.” A script does not change the structure assistive technology reads, and no Ontario provision recognises one as conformance. The reasoning is set out in full on the overlay page.
What a barrier costs an Ontario employer
The compliance conversation usually stops at the report, but the standard sits inside a broader duty that has teeth in Ontario: the Human Rights Code. A job applicant who cannot complete an online application, a member of the public who cannot book a service, an employee who cannot use an internal portal after an accommodation request — each of those is a situation the Code addresses, and none of them is resolved by the compliance report having been filed on time. The website is simply the place where the encounter happens.
That is why we test the careers path and any logged-in area you ask us to cover, and why the findings name what a person could not do rather than which criterion number failed. A ticket that says the application form cannot be submitted with a keyboard gets fixed. A ticket that cites a success criterion by number gets deferred.
What testing a corporate site involves here
An Ontario corporate site is usually less complex than a shop but broader: many pages, several templates, a careers section, a document library and often an application form for a service. Testing covers one instance of each template plus every unique interaction, and the careers path gets particular attention, because employment obligations sit in the same regulation and an inaccessible application form is a barrier with two legal dimensions rather than one.
The output is the same in every case: findings written in plain language, ordered by what they stop a person doing, with the change to make and a severity that helps you plan. That, and a record signed in Ontario that you can attach to your file the day the declaration is due.
Ontario questions, answered directly
Which Ontario rule covers websites?
The Integrated Accessibility Standards Regulation, O. Reg. 191/11, made under the Accessibility for Ontarians with Disabilities Act, 2005.
Which conformance level is required?
WCAG 2.0 level AA for internet websites and web content, with two stated exceptions.
What are the two exceptions?
Live captioning and pre-recorded audio description are excluded from the requirement.
Who has to comply?
Organisations with 20 or more employees in Ontario, and designated public sector organisations under their own thresholds.
Does it matter where my company is based?
No. What matters is that you have employees in Ontario. Foreign companies with staff in the province are covered.
How are employees counted?
People employed in Ontario, including part time, on the counting rules set out in the regulation and its guidance.
What is the reporting duty?
Organisations above the threshold file an accessibility compliance report with the province on the legal cycle; the next deadline is 31 December 2026.
Does the report require an audit?
It is a self-declaration. You declare compliance, and the evidence behind it is yours to hold and produce if asked.
Can you file it for us?
No. Filing is done by the organisation. We prepare and sign the web conformance record that supports the declaration.
What else does the standard require beyond the website?
Accessible formats and communication supports, an accessibility policy, a multi-year plan, employment practices and training. The web requirement is one part.
What about the multi-year plan?
Larger organisations must have one, publish it and review it. It sits alongside the statement rather than replacing it.
Are there penalties?
The Act provides for administrative penalties for failure to comply, including failure to file.
Is WCAG 2.2 acceptable instead?
Yes and it is stronger: 2.2 includes everything 2.0 requires plus later criteria, so meeting 2.2 AA exceeds the Ontario minimum.
What about the federal Accessible Canada Act?
It applies to federally regulated organisations and runs separately, with its own plans and feedback duties.
We are a non-profit. Does it apply?
Yes, non-profits are covered on the same employee thresholds.
What does your Canadian plan cost?
890 CAD a year, including the audit, the signed record, the feedback channel, monthly re-testing and five years of records.
How long does it take?
Five business days from a complete form.
What if we are not compliant yet?
The record describes the tested state honestly and you receive the prioritised fix list. That is a better position before a deadline than an untested declaration.