Canadian Website Accessibility Laws: Complete Guide

Canada has built out a web accessibility compliance framework through both federal and provincial legislation. Understanding which law applies to your organization, what it requires, and when deadlines fall is the starting point for building a compliant website.

Overview: Two Primary Frameworks

Federal: Accessible Canada Act (ACA)

• Enacted: July 11, 2019
• Scope: Federally regulated organizations (banks, telecoms, airlines, Crown corporations, Parliament, federal government)
• Approach: Proactive planning and annual reporting on barrier removal
• Web standard: WCAG 2.1 AA (federal government); sector-specific standards in development
• Key 2026 deadline: Annual progress reports due June 2026

Provincial: AODA (Ontario)

• Enacted: 2005; web standards effective 2021 for private sector (50+ employees)
• Scope: Ontario organizations with 50+ employees; all Ontario public sector
• Approach: Meet WCAG 2.0 AA, file compliance report every 3 years
• Web standard: WCAG 2.0 AA (legal minimum); WCAG 2.1 AA recommended
• Key 2026 deadline: Compliance reports due December 31, 2026

Reference: Accessible Canada Act, S.C. 2019, c. 10 | AODA, S.O. 2005, c. 11

Federal Law: The Accessible Canada Act

Who It Covers

The ACA applies to entities under federal jurisdiction:

• All federal government departments and agencies
• Parliament and Crown corporations
• Banks and federally regulated financial institutions (the "Big 6" Canadian banks and others)
• Telecommunications and broadcasting companies licensed by the CRTC
• Airlines and airport authorities
• Interprovincial transport providers regulated by the Canadian Transportation Agency
• The Canadian Forces and RCMP

The ACA does not cover provincially regulated businesses, provincial governments, or organizations operating solely within a single province.

What It Requires

The ACA does not prescribe a single technical standard in the legislation. Instead it requires covered organizations to:

1. Publish an accessibility plan identifying barriers and describing how they will be removed (first plans due June 1, 2023; updated every three years)
2. File annual progress reports describing what was done to implement the accessibility plan (first reports due June 1, 2024)
3. Establish a feedback process for receiving input about accessibility barriers
4. Consult with people with disabilities in developing plans and reports

For web and digital content (information and communication technology), the practical standard is WCAG 2.1 AA. The Government of Canada's Standard on Web Accessibility explicitly requires WCAG 2.1 AA for federal websites. Accessibility Standards Canada is developing sector-specific standards for banks, telecoms, and transport that are expected to align with WCAG 2.1 or 2.2 AA.

Enforcement

The Accessibility Commissioner (Canadian Human Rights Commission) receives complaints and conducts audits. Administrative monetary penalties can reach CAD $250,000 per contravention. The CRTC has parallel authority for broadcasting and telecom entities.

Ontario Law: AODA

Who It Covers

Public sector: All Ontario government organizations, municipalities, school boards, hospitals, universities, public libraries — regardless of size. Private and non-profit: Organizations operating in Ontario with 50 or more employees. Employee count includes all Ontario employees, not just those who work on the website.

What It Requires

The Integrated Accessibility Standards Regulation (O. Reg. 191/11) requires:

• Websites and web content to conform to WCAG 2.0 Level AA
• New websites and significantly refreshed content to meet this standard
• Compliance reports filed every three years

The specific WCAG 2.0 AA requirements cover alt text, form labels, page language, keyboard accessibility, skip navigation, color contrast, page titles, and other criteria.

Enforcement

The Ontario Ministry for Seniors and Accessibility enforces AODA. Fines reach CAD $100,000 per day for corporations and CAD $50,000 per day for individuals. The ministry can conduct inspections and issue compliance orders.

Other Provincial Laws

Manitoba: Accessibility for Manitobans Act (AMA)

Enacted 2013. The Customer Service Standard and Information and Communication Standard apply to websites. The Customer Service Standard has been in effect since 2015; web content requirements apply to public-facing websites. Contact the Manitoba Accessibility Office for current requirements.

Nova Scotia: Accessibility Act (2017)

Nova Scotia's accessibility legislation is developing standards through the Accessibility Directorate. Organizations subject to the Act should monitor standard development.

British Columbia: Accessible British Columbia Act (2021)

BC's Act requires public sector organizations and regulated entities to establish accessibility committees and develop accessibility plans. Web-specific standards are under development.

Quebec

Quebec's Act to Ensure the Exercise of the Rights of Persons with Disabilities includes obligations relevant to digital accessibility for government-funded organizations. Quebec government websites are also subject to the Web Standards for the Quebec Government, which references WCAG requirements.

The 2026 Canadian Compliance Landscape

Two major deadlines fall in 2026 for Canadian organizations:

December 31, 2026 — AODA compliance reports: Large private sector and non-profit organizations in Ontario that last filed in 2023 must file their next compliance report by December 31, 2026. This report confirms WCAG 2.0 AA conformance across the organization's websites. June 2026 — ACA progress reports: Organizations on the standard ACA reporting cycle file their annual progress report in June 2026. This report documents what the organization did in the past year to remove accessibility barriers, including digital barriers.

Organizations subject to both laws — major banks, telecoms, and other federally regulated businesses with Ontario operations — have compliance obligations in both the first and second halves of 2026.

WCAG: The Technical Common Ground

Both the ACA and AODA reference the Web Content Accessibility Guidelines (WCAG), published by the World Wide Web Consortium (W3C). WCAG 2.0 AA is AODA's explicit standard. WCAG 2.1 AA is the Government of Canada's standard. WCAG 2.2 AA (published October 2023) is the current version.

The difference between versions is incremental. WCAG 2.1 added 17 success criteria to 2.0, primarily focused on mobile accessibility and users with cognitive and low-vision disabilities. WCAG 2.2 added 9 more criteria. Meeting WCAG 2.1 AA satisfies WCAG 2.0 AA, since 2.1 is backward compatible.

Common WCAG 2.0 AA requirements that both laws effectively require:

Practical Compliance Steps

Whether your organization is subject to the ACA, AODA, or both, the practical steps are similar:

1. Audit your current state: Run automated scans across your websites. Identify what violations exist and where. This establishes your baseline.

1. Prioritize by severity: Fix critical violations (missing alt text, unlabeled forms, missing skip nav) before moderate ones. These are what auditors and automated tools flag first.

1. Conduct manual testing: Automated tools catch 30-50% of WCAG violations. Test with keyboard-only navigation. Use NVDA (Windows) or VoiceOver (Mac) for basic screen reader testing.

1. Document everything: For AODA compliance reports, you need to confirm compliance. For ACA progress reports, you need to demonstrate what you did. Keep records of audits, remediation work, and testing.

1. Build in ongoing monitoring: New content, site updates, and third-party integrations can introduce new violations. Monthly or quarterly automated scanning catches regressions.

Scan your website free to see your current WCAG compliance score and violation list. Results in under 60 seconds. Related reading:

• AODA Website Compliance Guide 2026
• Accessible Canada Act: What Your Website Needs
• ADA Compliance Checker: How to Test Your Website