The 2026 AODA Compliance Report: Who Files, What It Asks, and What Website Compliance Actually Means

Every business and non-profit in Ontario with twenty or more employees has a legal filing due this year: an accessibility compliance report under the Accessibility for Ontarians with Disabilities Act, submitted through the province’s new online portal by 31 December 2026. It is a short form. Answering it truthfully is not always short, because one of its questions is whether your website complies with a technical standard most organizations have never had tested.

This guide covers who files, what the report asks, what “website compliance” means in law, and how to reach a truthful answer between now and December. Everything here is drawn from the regulation and the province’s own guidance, linked at the end.

1. Who files, and when #

Employee count is what it sounds like: the people on your Ontario payroll, full-time, part-time, seasonal and contract, at the time you file. If you are near the line, count carefully, because the report is a legal declaration.

Reports are filed through the Accessibility Compliance Reporting Portal. The previous PDF form is retired; a report sent any other way is not accepted as filed. Organizations with several corporate entities can file for up to twenty at once from one account.

2. What the report asks #

The report is a set of yes-or-no declarations across the standards that apply to your organization: customer service, information and communications, employment, transportation where relevant, and the design of public spaces. A director or officer certifies it. There is no attachment of evidence — the province may ask for it later, and a complainant may ask for it sooner.

For most organizations the questions that give pause are in information and communications: whether your public website and web content meet the required standard, whether you provide accessible formats and communication supports on request, whether your feedback processes are accessible. The rest of this guide is about the first of those.

3. What “website compliance” means in law #

The requirement is in section 14 of the Integrated Accessibility Standards Regulation. Since 1 January 2021, every designated public sector organization and every business or non-profit with fifty or more employees must make its public websites and the web content published on them conform to WCAG 2.0 Level AA, with two exceptions: success criteria 1.2.4, live captions, and 1.2.5, pre-recorded audio description.

Four details decide more cases than the standard itself:

• Web content published after 1 January 2012 is in scope. That includes documents: a PDF, a Word file or a slide deck linked from your site is web content. For municipalities and agencies, documents are the larger half of the obligation.
• Public means public. Intranets and extranets are exempt, though an employee who needs an accessible format is still entitled to one.
• Control, not ownership, decides responsibility. The organization that controls the website, directly or through a contractual relationship, must meet the standard. A vendor-built site is still your obligation.
• Fifty is the website threshold; twenty is the reporting threshold. An organization with thirty employees files a report but is not bound by the website standard. It still faces the Human Rights Code’s duty to accommodate, and increasingly its funders’ and customers’ expectations, which is why most choose to meet the standard anyway.

4. WCAG 2.0, 2.1 or 2.2: which one? #

The regulation names WCAG 2.0. The current version of the guidelines is 2.2, published in 2023, and 2.1 sits between them. Each version contains the previous one entirely, so a site that meets 2.2 AA meets 2.0 AA. The additions in 2.1 cover mobile use, low vision and cognitive disabilities — orientation, reflow, text spacing, target size — which are precisely the barriers a 2016-era standard did not anticipate and a 2026 audience meets daily.

Our practice is to test to WCAG 2.1 AA and report the 2.2 criteria separately. The report then answers the legal question, the practical one, and the one the next revision of the regulation is likely to ask.

5. How to reach a truthful answer #

The compliance report asks whether your site conforms. Nobody can answer that from a home page and a good feeling. The checklist below is what a defensible answer rests on; the first three items can be done in a week.

1. Crawl every page with an automated checker such as ACHECKS. Automation finds roughly a third of failures — missing alternative text, contrast, structure — but finds them everywhere.
2. Walk the key journeys with a keyboard only. Enquiry, application, payment, login, search. If a journey cannot be completed without a mouse, the site does not conform, whatever the scan says.
3. Walk the same journeys with a screen reader — NVDA on Windows is free — and listen for what is unnamed, out of order, or silent.
4. Sample the documents. Take ten PDFs residents or customers actually download and check them with PAC, the free PDF Accessibility Checker. Untagged documents fail before the first sentence.
5. Check forms and errors. Labels, instructions, and an error message that says what is wrong and where.
6. Check media. Captions on pre-recorded video; a transcript for audio.
7. Zoom to 400% and turn on high contrast. Content must reflow without sideways scrolling and remain readable.
8. Read your accessibility statement and feedback process. The regulation requires the process; the statement is where people find it.
9. Keep a register. Every barrier found, its criterion, its fix and its status. This is the evidence behind the declaration and the record you show if asked.
10. Decide what the answer is. If the register is empty after honest testing, the answer is yes. If not, see the next section.

An accessibility audit is this list done by people who do it every week, with assistive-technology testing and a report ranked by harm. For a site of any size it is the fastest route to an answer you can sign.

6. If the answer is “not yet” #

Most organizations testing for the first time find barriers. That is not a crisis; it is the reason the report exists. Between now and December the sequence is:

1. Audit — know what is wrong and how much of it there is.
2. Fix the template-level barriers first. A heading structure, a focus style, a form component fixed once is fixed on every page. This is where most sites make most of their progress, quickly.
3. Remediate the documents residents actually use, and fix the templates that produce new ones. Our document remediation page explains both halves.
4. Re-test and close the register. Remediation is not done when the ticket is closed; it is done when the barrier is gone for the person who met it.
5. File truthfully. If the site conforms by December, say so. If it does not, the report is still due; file it accurately and keep the plan and the register that show the work in motion.

7. After December #

The report recurs — three years for businesses and non-profits, two for the public sector — and websites regress between filings: new pages, new plugins, new editors. The organizations that find the next report easy are the ones that kept the register open and let a monitor watch the site. That is what ACHECKS is for, and it is why our audits end with a plan rather than a score.

If you would like the answer to your own report’s website question, the panel below reaches the people who will find it.

Sources #

• Government of Ontario, Completing your accessibility compliance report — deadlines, the portal, who must file.
• Government of Ontario, How to make websites accessible — the section 14 requirement in plain language.
• Ontario Regulation 191/11, Integrated Accessibility Standards, section 14.
• W3C, Web Content Accessibility Guidelines 2.2.