The deadline
The accessibility compliance report for Ontario businesses and non-profit organisations with 20 or more employees is due by 31 December 2026. Reporting runs on a three year cycle, so filing this one sets your next one.
Treat the date as the end of a short project rather than the length of a form. The filing is quick. Confirming that the statements in it are accurate is not always, and the website question in particular has sent plenty of organisations into several weeks of unplanned work. Opening the form in October gives you time to fix what it surfaces. Opening it on 30 December gives you a choice between an inaccurate declaration and a missed deadline.
Who has to file
- 20 or more employees in Ontario: you file the accessibility compliance report
- Fewer than 20 employees: you do not file, but the obligations for small organisations still apply, including an accessibility policy, staff training and accessible formats on request
- 50 or more employees: your public facing website and web content must also meet WCAG 2.0 Level AA
- Public sector organisations: a separate and stricter regime, including a shorter reporting cycle
Count people employed in Ontario rather than full time equivalents. Two thresholds are in play here and they are easy to confuse: 20 for the report, 50 for the website standard. An organisation with 30 employees files a report and is not subject to the WCAG requirement. An organisation with 60 does both.
What the report asks
The report is a declaration. It walks through the requirements that apply to an organisation of your size and asks you to confirm whether you meet each one. It does not ask for evidence at the point of filing, which is exactly why the answers need to be true: you are signing something, and the supporting record is what you would rely on later.
Broadly, the areas covered are the ones AODA sets out for your organisation size.
| Area | What you are confirming |
|---|---|
| Accessibility policy | That you have one, in writing, and that it is available |
| Training | That staff have been trained on AODA requirements and the Human Rights Code as it relates to people with disabilities |
| Accessible formats | That you provide information in accessible formats on request |
| Feedback process | That people can give feedback in accessible ways |
| Employment practices | That recruitment, accommodation and return to work practices meet the standards |
| Websites and web content | At 50 or more employees, that these meet WCAG 2.0 Level AA |
Two of these commonly turn out to be thinner than expected. Training records are often informal, so nobody can say who was trained or when. And the feedback process is frequently a contact form that itself is not accessible, which is a neat demonstration of the problem.
The website question is the one that stops people
If you have 50 or more employees, the report will ask you to confirm that your public facing website and web content conform to WCAG 2.0 Level AA. Most organisations cannot answer that honestly without checking, and most who check find they do not yet conform.
Do the checking before you open the form, not during. The quickest honest assessment is three steps and you can do it yourself in an afternoon:
- Run an automated scan across your most visited pages. This finds missing alt text, contrast failures and unlabelled form fields.
- Put the mouse away and try to use the site with the keyboard alone, including completing your contact form.
- Check your newest content, because the requirement applies to content created or significantly refreshed after 1 January 2012, which is effectively everything you have published.
Whatever that finds is your actual project. AODA compliance for websites goes through the standard, the failures that come up most often, and what the fixes involve on a WordPress build.
If the answer is that you do not conform yet, do not sign a declaration you cannot support. Start the remediation, write down what you tested and what you fixed, and take advice on how to complete the form given where you actually are.
How to prepare, in the order that saves time
- Confirm your Ontario employee count against both thresholds, 20 and 50
- Find your accessibility policy. If it does not exist in writing, that is the first task
- Pull your training records together and identify who has not been trained
- Test your own feedback and contact routes, by keyboard, as a user would
- Scan and keyboard test the website if the 50 employee threshold applies
- Fix what you can before filing, and record the rest with dates
- Open the form with the answers already known
- Diarise the next cycle, three years out, with the work planned rather than remembered
Step six is the part that pays off later. Because conformance is not certified by anyone, what you can demonstrate is your own record: what was tested, when, what was found, what was repaired. That record turns the next filing from an investigation into a confirmation.
If you do not file
Filing is a legal obligation under AODA, and enforcement can include financial penalties. The figures reported are up to $100,000 per day for a corporation and up to $50,000 per day for a director or officer. Confirm the current amounts with the Province, and note that the exposure attaches to individuals as well as to the company.
There is a practical point underneath the numbers. Non-filing is the easiest kind of non-compliance for a regulator to identify, because it is a missing record rather than a technical judgement about your markup. Whatever state your website is in, the filing itself is the part not to skip.
If the website question is what is blocking you, that is the common case and it is fixable. We audit and remediate WordPress sites against WCAG, starting with the failures that actually stop people using the site, and we give you the record of what was tested and fixed. Send us your URL and we will tell you where you stand before you commit to anything.