Get a Free Quote

AODA Compliance for Websites: What Ontario Actually Requires

AODA is the Accessibility for Ontarians with Disabilities Act, and the part that catches website owners is short: public facing websites and web content have to conform to WCAG 2.0 Level AA. There is no certificate, no approved vendor list and nobody inspects your site on a schedule. What exists instead is a legal obligation, a reporting requirement, and penalties that are large enough to take seriously. This guide covers what the standard asks for, which failures are most common, how to check your own site honestly, and what the work usually involves on a WordPress build. It is general information and not legal advice, so confirm your own obligations with the Province of Ontario or a lawyer.

What AODA requires of a website

One sentence covers it: public facing websites and web content must conform to the Web Content Accessibility Guidelines, version 2.0, Level AA. The requirement applies to content created or significantly refreshed after 1 January 2012, which in practice means your current site.

Two things make this different from most compliance work. There is no audit you book and pass, so nobody will tell you that you are finished. And the standard is technical rather than procedural, so it cannot be satisfied by writing a policy. Either a keyboard user can complete your contact form or they cannot.

It is worth separating the two obligations that get confused with each other. The technical obligation is to meet WCAG 2.0 AA. The administrative obligation is to file an accessibility compliance report on a three year cycle, which is covered in the AODA compliance report. Filing the report does not make your site accessible, and an accessible site does not excuse a missed filing.

Who it applies to

The website requirement attaches at 50 or more employees. Below that, an organisation still has AODA duties, including an accessibility policy, staff training and providing accessible formats on request, but the WCAG conformance requirement is not among them.

  • 50 or more employees: public facing websites and web content must meet WCAG 2.0 Level AA
  • 20 or more employees: an accessibility compliance report must be filed every three years
  • 1 to 49 employees: policy, training and accessible formats on request still apply
  • Public sector organisations sit under a stricter and separate set of obligations

Count employees in Ontario, and count people rather than full time equivalents. A business that runs on part time staff can pass the threshold without feeling any larger, which is how most organisations discover they were already in scope.

Thinking about a new WordPress website?Get a free consultation and a fixed-scope quote. A senior engineer replies within 24 hours. No obligation.
Get a Free Quote

WCAG 2.0 AA in plain terms

WCAG is organised under four principles. Stripped of the formal language, they ask four questions about your site.

PrincipleThe question it asks
PerceivableCan someone receive the content if they cannot see or hear it?
OperableCan someone use it without a mouse?
UnderstandableIs it predictable, and does it explain its own errors?
RobustCan assistive technology interpret the markup correctly?

Level AA is the middle of three conformance levels and is the one legislation generally references. The practical content of AA, for an ordinary business website, is a fairly short list: text alternatives, keyboard operability, sufficient colour contrast, labelled form fields, visible focus, sensible heading structure, captions on video, and no content that depends on colour alone to make sense.

A note on versions. AODA is written against WCAG 2.0. WCAG 2.1 AA is newer and is referenced by several other regimes, including the standard the federal accessibility regulations point at. If you are paying for this work once, build to 2.1 AA. It covers 2.0 and leaves you in a better position if your obligations widen.

The eight things that fail most

Across ordinary business websites the same failures recur. None of them are exotic and most are cheap to fix once somebody looks.

  1. Images without text alternatives. Decorative images need an empty alt attribute, meaningful ones need a description, and an image of text needs the text.
  2. Low contrast text. Light grey body copy on white is the most common single failure on modern sites, and it usually comes from the theme rather than the content.
  3. Form fields without labels. A placeholder is not a label. It disappears on focus and screen readers treat it differently.
  4. Keyboard traps and invisible focus. Open a menu, press Tab, and see whether you can tell where you are and get out again.
  5. Headings used for size. An h3 chosen because it looked right breaks the outline that screen reader users navigate by.
  6. Link text that says nothing. A page of links all reading "read more" is useless out of context, and out of context is how they are often heard.
  7. Video without captions. Auto generated captions are a starting point, not a deliverable.
  8. Error messages that only use colour. A red border with no text does not tell a colour blind user what went wrong.

If you fix only the first four you will have dealt with the majority of the real barriers on a typical site. Items two and three are also the ones most likely to be systematic, which means a single change to the theme or the form template fixes them everywhere at once.

How to test your own site honestly

Automated tools find the mechanical failures: missing alt attributes, contrast ratios, absent labels, duplicate IDs. They cannot judge whether your alt text is accurate, whether your heading structure makes sense, or whether a keyboard user can actually finish a booking. A clean automated scan is not a pass, and anybody selling you one as a certificate is selling you something else.

Do these four in order. The first takes minutes, the last takes an afternoon, and together they will tell you where you stand.

  1. Run an automated scan on your top ten pages, not just the homepage. Fix what it finds, because it is the cheap half.
  2. Unplug the mouse. Navigate the site by Tab, Shift+Tab, Enter and the arrow keys. Reach the main navigation, open the menu, complete the contact form, close any pop up. Note every point where you cannot see where you are or cannot proceed.
  3. Turn on a screen reader and listen to one page end to end. VoiceOver on macOS and NVDA on Windows are both free. You are listening for whether the page makes sense in order, and whether links and buttons announce what they do.
  4. Zoom to 200 per cent and look for content that disappears, overlaps or requires sideways scrolling.

Step two is the single most informative thing most site owners ever do. It is uncomfortable, it takes ten minutes, and it usually finds a blocker on the page that matters most commercially.

Ready to bring your WordPress project to life?Get a free consultation and a fixed-scope quote. A senior engineer replies within 24 hours. No obligation.
Get a Free Quote

WordPress specifics

Most accessibility problems on a WordPress site come from three places, in this order: the theme, the page builder, and the plugins that output front end markup.

SourceTypical problemWhat fixes it
ThemeContrast, focus styles, heading levels baked into templatesChild theme overrides, or a theme change if it is deep
Page builderDiv soup, headings chosen by size, custom widgets with no keyboard supportRebuild the affected sections with accessible patterns
Forms pluginPlaceholder instead of label, errors shown by colour onlyTemplate overrides, or a plugin that does it properly
Sliders and modalsKeyboard traps, no visible focus, auto advancing contentUsually replace, rarely repair
ContentMissing alt text, link text that says nothingAn editorial standard plus training, not code

The last row is the one people forget to plan for. You can fix every template and be back where you started in a year, because accessibility is partly an editorial practice. Decide who writes alt text, give them a one page standard, and check it as part of publishing. A site that stays accessible needs that more than it needs a one off audit, which is part of what ongoing maintenance and support is for.

One thing worth knowing before you commission work: fixing accessibility often improves other things you are already paying attention to. Proper heading structure, descriptive link text and real labels are also what search engines read, and lighter, better structured markup tends to load faster. It is unusual for compliance work to pay for itself twice, and this is one of those cases.

Why overlay widgets are not a fix

You will be offered a script that promises compliance for a monthly fee. It adds a floating accessibility button with contrast and font size controls, and sometimes claims to repair the page automatically.

They do not work for the purpose they are sold for, for a simple reason: the problems are in your markup and an overlay sits on top of it. A script cannot know what your unlabelled image is of, cannot decide what your button should be called, and cannot make a keyboard trap passable. Users of assistive technology generally report that overlays interfere with the tools they already use well.

  • They do not change your legal obligation
  • They cannot supply missing text alternatives or labels
  • They can conflict with a user's own screen reader or browser settings
  • They create an impression of compliance that delays the real work

If a widget is already on your site, leaving it in place while you fix the underlying issues is a decision you can make. Treating it as the fix is not.

A realistic plan

  1. Confirm your employee count and which AODA obligations apply to you
  2. Run an automated scan across your ten most visited pages
  3. Do the keyboard test on the homepage, your main service page and your contact form
  4. Fix the systematic issues first: contrast, focus styles, form labels
  5. Fix the content issues next, and write the one page editorial standard while you do
  6. Retest by keyboard and with a screen reader, because the scan will not confirm these
  7. Add accessibility to your publishing checklist so it does not regress
  8. Keep a record of what you tested, when, and what you fixed

Step eight matters more than it looks. WCAG conformance is not a certificate, so what you can show is the work: what was tested, what was found, what was repaired and when. That record is also what makes your next compliance report straightforward rather than a guess.

If the keyboard test found a blocker on a page that earns you money, that is the place to start and it is usually a contained piece of work. We fix accessibility issues on WordPress sites, from theme level contrast and focus problems to rebuilding a form or a menu that cannot be operated without a mouse. Send us your URL and we will tell you what we find and what it would take, before you commit to anything.

Hamza Hai

Hamza Hai writes about WordPress development, performance, and growth for businesses.

FAQ

Frequently asked questions

Public facing websites and web content must conform to WCAG 2.0 Level AA. The requirement applies to organisations with 50 or more employees, and covers content created or significantly refreshed after 1 January 2012.

AODA's website requirement is written against WCAG 2.0 Level AA. WCAG 2.1 AA is the more current standard and is what several other regimes reference, so building to 2.1 AA satisfies AODA and leaves you better placed for other obligations.

The WCAG requirement applies at 50 or more employees. Smaller organisations still have other AODA obligations, such as an accessibility policy and staff training, and still have to provide accessible formats on request.

No. Overlay widgets sit on top of the page and cannot repair the underlying markup, so most WCAG failures remain. They also do not change your legal position. Fix the site itself.

Run an automated scan to catch the mechanical failures, then test by keyboard only and with a screen reader, and check colour contrast. Automated tools find a minority of real issues, so a clean scan is not a pass.

Enforcement can include financial penalties, reported at up to $100,000 per day for corporations and $50,000 per day for directors and officers. Confirm the current figures with the Province, and treat the reporting obligation as separate from the technical one.

Have a project?

Let's Build Your Next WordPress Website

Get a free consultation and a fixed-scope quote. No obligations.

  • Free Consultation
  • No Hidden Costs
  • 100% Confidential

Request your free quote

Tell us what you are building. A senior engineer replies within 24 hours.

Please enter your name.

Please enter a valid email address.

Please tell us a little more about your project (10+ characters).

No obligation. Your details are only used to prepare your quote.