AODA compliance report 2026: where your website fits

If your organization has 20 or more employees in Ontario, it must file an accessibility compliance report by 31 December 2026. The 2026 form is short: a handful of yes-or-no questions, one per accessibility standard. None of them uses the word “website”. But if you have 50 or more employees, your website is covered by the question on the Information and Communications Standards, and answering “yes” means your public website meets WCAG 2.0 Level AA. Check before you tick.

Who has to file, and by when?

Businesses and non-profits with 20 or more employees in Ontario file a report every three years. This round is due 31 December 2026. You file online through the Accessibility Compliance Reporting Portal (ontario.ca, completing your accessibility compliance report).

Organizations with fewer than 20 employees do not file, but they still have to meet the requirements that apply to them. Employees are counted the Ontario way: full-time, part-time, seasonal and contract staff in Ontario count; volunteers and independent contractors do not (ontario.ca, rules for businesses and non-profits). If you are not sure whether you are in scope, start with our explainer, Does the AODA apply to your organization’s website?

What does the 2026 report ask?

We read filed 2026 reports that organizations have published. The questions are short and the same for everyone in each size band.

Employees in Ontario	What the 2026 form asks
20 to 49	Whether you comply with all applicable requirements of the Customer Service Standards.
50 or more	Six questions: compliance with the General Section, the Information and Communications Standards, the Employment Standards, the Design of Public Spaces Standards and the Customer Service Standards, plus whether you provide transportation services.

Each question is a yes or no. The form then asks the person filing to certify that the information is accurate and that they have the authority to bind the organization.

Where does your website fit in?

For organizations with 50 or more employees, the website is inside Question 2: “Is your organization in compliance with all applicable requirements of the Information and Communications Standards?” Those standards include the requirement that public websites and web content published after 1 January 2012 meet WCAG 2.0 Level AA, with exceptions for live captions and pre-recorded audio description (ontario.ca, how to make websites accessible). The form’s own resource links under that question point to the regulation and to WCAG 2.0.

This is a change in presentation, not in the rule. The Ministry’s 2023 guide to the report showed a question that asked directly whether the organization’s websites conform to WCAG 2.0 Level AA (Ministry for Seniors and Accessibility, 2023 guide). The 2026 form folds that into one question about the whole standard. The question got shorter; the requirement did not.

The same question also covers the rest of the Information and Communications Standards, such as providing information in accessible formats when someone asks. A “yes” is a statement about all of it.

For organizations with 20 to 49 employees, the form does not ask about information and communications at all. The duties that apply to you, such as providing accessible information on request, still apply.

Why the “yes” matters

The form says it plainly: it is an offence under the Act to provide false or misleading information in an accessibility report. Under section 37 of the AODA, that offence carries fines of up to $50,000 a day for an individual and $100,000 a day for a corporation (AODA, section 37). Not filing at all can lead to enforcement measures, which Ontario says can include financial penalties.

So the person signing should know the answer is true, not assume it. For the website, that means someone has checked it.

How to check your website before you answer

A full audit is the thorough answer. If you are short on time, these checks catch the most common failures and tell you whether you need one.

Use the keyboard only. Tab through the home page, a form and the menu. Can you reach and use everything, and can you always see where you are?
Check the headings. Each page should have one main heading and a sensible order of sub-headings, not bold text styled to look like headings.
Check images. Images that carry meaning need alt text that says what they show; decorative images should be skipped by screen readers.
Check colour contrast on body text, buttons and links, including text over photos.
Check forms. Every field needs a visible label, and errors should say what went wrong in words, not just in red.
Check documents. PDFs you publish, such as newsletters, minutes and forms, are web content too.
Check video. Pre-recorded video needs captions.
Write down what you checked, when, and what you found. If anyone asks how you answered, you have a record.

Automated checkers are useful for a first pass, but they find only part of the problem. The keyboard test and a look at your PDFs catch much of what they miss.

What if the honest answer is no?

Answer honestly. We cannot tell you how the Ministry will respond to a “no”, and this is not legal advice, but a truthful answer with a plan to fix the gaps is a far safer position than a “yes” you cannot support. If you are unsure how to answer, ask the Ministry or a lawyer before 31 December rather than after.

Then fix what the checks found, starting with the pages people use most: the home page, registration or renewal, contact, and anything with a form.

A timeline for the next three months

October: confirm your employee count and who will certify the report. Run the checks above.
November: fix what you can, and plan the rest with dates.
December: file through the portal before the 31st. Do not leave it to the last week.

If you would like help checking your website before you file, schedule a discussion.

Sources (checked 30 September 2026)