Accessibility StatementThe AODA compliance report deadline is 31 December 2026. As of 6 November, that is 55 days away. The report is filed online in the Accessibility Compliance Reporting portal by private businesses and non-profit organizations with 20 or more employees in Ontario.
One question on the form stops most filers: does your website meet WCAG 2.0 Level AA? Most organizations are unsure, close the form, and do not submit. That is the worst outcome available.
What does ticking 'no' actually trigger?
It does not trigger a fine. It triggers a request — a phone call or a letter — asking for a plan and a timeline. Enforcement under the Accessibility for Ontarians with Disabilities Act, 2005 is graduated. The sequence runs: reminder, request for evidence, director's order, and only then administrative penalties. On conviction, a corporation faces fines of up to 100,000 dollars for each day the offence continues; a director or officer faces up to 50,000 dollars a day. Organizations that answer honestly and attach a remediation schedule rarely travel that sequence. Organizations that do not file are the ones that get escalated.
Three positions — only one of them requires silence
Most organizations filing in 2026 fall into one of three situations.
- They know the answer is no and have decided not to file until it becomes yes.
- They do not know, because the site has never been tested against any standard.
- They suspect the answer is yes but cannot produce a single document that says so.
None of these three situations requires staying silent. Each one has a corresponding honest answer on the form. An organization that declares unmet criteria and attaches a dated remediation schedule is in a defensible position. One that leaves the form unsubmitted is not.
What counts as a usable record
The real task before 31 December is not to make every WCAG 2.0 AA criterion pass. It is to have a record: what was tested, on which date, against which criteria, what passed, what did not, and when remediation is scheduled. A record of that kind takes roughly a fortnight to produce and it survives a compliance inquiry.
If the answer is already a confident, documented yes, the work is to keep that evidence findable and to submit the form.
Does WCAG apply to your organization at all?
Employee count changes what is required. Organizations with fewer than 20 employees in Ontario have no compliance report to file. Organizations with between 20 and 49 employees are subject to the AODA standards but the web content requirement under section 14 of the Integrated Accessibility Standards Regulation — the WCAG 2.0 AA obligation — does not apply to their website. The WCAG requirement at section 14 applies to organizations with 50 or more employees.
Count full-time, part-time, and seasonal employees who work in Ontario. Contractors, agency staff, and volunteers are not counted. The threshold matters: 20 and 50 are both meaningful numbers with different obligations attached.
If your head office is outside Ontario but you have 20 or more employees working in Ontario, the AODA applies. The test is where people work, not where the company is registered.
The report is a self-certification. It is signed by a senior officer of the organization and submitted in the portal. No external company can file it on your behalf or issue a government certification.
Key points
- The AODA compliance report deadline is 31 December 2026 for Ontario organizations with 20 or more employees.
- Answering 'no' on the WCAG 2.0 AA question triggers a plan request, not an immediate fine; not filing triggers escalation.
- The WCAG 2.0 AA web content requirement under section 14 applies only to organizations with 50 or more employees.
- A dated test record showing what passed, what did not, and when remediation is scheduled is a defensible compliance position.
- Employee count includes full-time, part-time, and seasonal staff working in Ontario; contractors and volunteers are excluded.
Frequently asked questions
What happens if I tick 'no' on the WCAG 2.0 AA question in the AODA compliance report?
Ticking 'no' opens a graduated enforcement process: a reminder first, then a request for evidence, then a director's order. Attaching a dated remediation schedule when you file puts the organization in a defensible position. Not filing at all is what leads to escalation.
Does the WCAG 2.0 AA website requirement apply to organizations with fewer than 50 employees?
No. Section 14 of the Integrated Accessibility Standards Regulation applies the WCAG 2.0 AA web content obligation to organizations with 50 or more employees in Ontario. Organizations with between 20 and 49 employees must file the compliance report but are not subject to the WCAG website requirement.
Who has to file an AODA compliance report by 31 December 2026?
Private businesses and non-profit organizations with 20 or more employees in Ontario. The report is filed online in the Accessibility Compliance Reporting portal and is due every three years.
Can a third-party provider file the AODA compliance report on our behalf?
No. The report is a self-certification signed by a senior officer of the organization. A provider can prepare the documentation and test results, but the officer of the organization submits the report in the portal.
What are the penalties for not filing the AODA compliance report?
On conviction under the Accessibility for Ontarians with Disabilities Act, 2005, a corporation faces fines of up to 100,000 dollars for each day the offence continues. A director or officer faces fines of up to 50,000 dollars per day.
