Accessibility Statement21 October. Seventy-one days to 31 December 2026 — except the last useful day is not 31 December.
Read the deadline backwards and it moves.
31 December: filing closes.
Mid-December: your officer certifies in the portal. That part takes minutes, but it cannot happen before the document exists.
Five working days before that: the record is signed and the public code goes live.
The day after you book: the scope questions get answered, ten minutes of your time.
Today: free check, then decide.
Count it and the real last date is somewhere in the first half of December, which is three weeks earlier than the number on the calendar suggests.
Three situations. One of them is yours.
A) You have a date in mind for December and have not worked backwards from it yet.
B) You are waiting for a developer to finish fixing things before you start the paperwork.
C) You are not sure anyone in the organization has actually been made responsible for this.
B is the one worth stopping on. The fixing and the record are not the same track and they do not have to be sequential. The record documents what is true on a date, including what is not yet fixed, with the remediation schedule attached. Waiting for a perfect site before starting the paperwork is how December disappears.
What actually lands in your inbox: the AODA compliance report answers, the accessibility policy with the multi-year plan, and the signed web conformance record with a public code anyone can verify. Three documents, each tied to its own provision of O. Reg. 191/11.
The honest limits: fewer than 20 employees in Ontario and you file nothing at all. Between 20 and 49, the website conformance requirement does not apply — the report, the policies, the training records and the feedback process do. And if your developer can clear the barriers in a fortnight, a single audit from anyone competent will serve you; the recurring part only earns its place on a site that keeps changing.
Book in October, file in December without rushing. That is the whole argument.
Write A, B or C in the comments. I read each one and reply personally with the backwards date for your situation — the one you actually have to hit.
Then send this to whoever has the December holiday calendar. They know when the building empties.
