Accessibility Statement23 October. Sixty-nine days to 31 December 2026.
Statistics Canada, 2022: one in four people in Canada reports a disability. That is not a minority to be accommodated at the margin. It is a quarter of the people who try to use your website, and most of them will never tell you when it fails them.
Three situations. One of them is yours.
A) Your analytics look fine, conversion is steady, and nothing suggests a problem exists.
B) Someone mentioned accessibility once, it was logged as a nice-to-have, and nothing followed.
C) You suspect there are problems but have no idea which ones or where.
A is the one worth sitting with, because "no complaints" is the most misleading signal in this whole subject.
Three barriers, as they actually appear:
A payment field with no label. The screen reader announces it as "edit text, blank". The person has no way to know whether that box wants their card number or their postcode. WCAG 3.3.2, Labels or Instructions. Found by a person, not by a crawler.
A focus outline removed, usually because a designer thought it looked untidy. The keyboard user can no longer see where they are on the page. They are navigating blind through your checkout. WCAG 2.4.7, Focus Visible.
An error shown only in red. Invisible to anyone who cannot distinguish red — which is a meaningful share of men in any audience. The form says something is wrong and gives no other indication of what or where. WCAG 1.4.1, Use of Colour.
Here is why none of this ever reaches you. It does not appear in your analytics. There is no event for "could not complete". Nobody writes in to complain. They leave, and the session looks like any other bounce.
What a signed record does — and the limit matters: it does not fix your code. It writes down what is broken and where, with the criterion, the page and the element, so somebody can act on it. The fixing is your team's or your agency's work.
And the part that costs us: with fewer than 20 employees in Ontario you have no filing obligation at all. Between 20 and 49, the website conformance requirement under s. 14 does not apply either. None of which changes the fact that a quarter of your customers still cannot use the form — the legal question and the commercial one are genuinely separate, and only one of them has a deadline.
Write A, B or C in the comments. I read each one and answer personally with which of the three barriers is most likely sitting on your site right now.
Then send this to whoever designed your checkout. The focus outline was almost certainly their decision, and they will want to know.
