Does the AODA apply to your non-profit's website?

If your organization has at least one employee in Ontario, the AODA applies to it, and that includes non-profits and charities. The rule that your public website must meet WCAG 2.0 Level AA is narrower: it applies to businesses and non-profits with 50 or more employees in Ontario. Below 50, you still have duties that reach your website’s content, such as providing information in an accessible format when someone asks. At 20 or more, you must also file an accessibility compliance report by 31 December 2026.

The details matter, because the most common answers online stop at “yes, it applies” and leave out the thresholds. Here is how to work out where your organization sits.

Who does the AODA apply to?

Ontario’s rules for businesses and non-profits cover every organization that is not part of the designated public sector and has at least one employee in Ontario. That includes associations, charities, leagues and clubs, as well as private firms. An organization with no employees in Ontario is exempt (ontario.ca, accessibility rules for businesses and non-profits).

Public sector organizations, such as municipalities, school boards and provincial agencies, have their own, stricter set of rules. This article is about everyone else.

How do you count employees?

This is where many small organizations get it wrong in both directions. Ontario counts:

Included: full-time, part-time and seasonal employees, and contract workers.
Not included: employees outside Ontario, volunteers, and independent contractors.

So a sports league run by 200 volunteers with three part-time staff counts three. A national association with 60 staff, 40 of them in Ontario, counts 40.

One caution: volunteers do not count toward the number, but the organization is still responsible for making sure its volunteers and contractors follow the accessibility requirements that apply to it. If a volunteer posts the newsletter as an inaccessible PDF, it is still the organization’s newsletter.

What does the AODA require of your website, by size?

Employees in Ontario	What applies
None	Exempt from the business and non-profit rules.
1 to 19	Accessibility policies, training, accessible customer service, accessible employment practices, and accessible information: providing information in an accessible format or with communication supports when someone asks. The website itself is not required to meet WCAG.
20 to 49	Everything above, plus an accessibility compliance report every three years. The next one is due 31 December 2026.
50 or more	Everything above, plus documented policies, a multi-year accessibility plan, and public websites that meet WCAG 2.0 Level AA.

Source: ontario.ca, updated 16 June 2026.

For organizations with 50 or more employees, the website requirement covers public websites and web content published after 1 January 2012. Two success criteria are excepted: live captions (1.2.4) and audio descriptions for pre-recorded video (1.2.5). The requirement falls on whoever controls the website “either directly or through a contractual relationship”, so hiring a web company to run the site does not move the obligation to them (ontario.ca, how to make websites accessible).

Which standard: WCAG 2.0, 2.1 or 2.2?

The AODA names WCAG 2.0 Level AA. The current version of the guidelines is WCAG 2.2, published by the W3C on 5 October 2023, with nine success criteria added since 2.1 (W3C, What’s new in WCAG 2.2).

Meeting 2.2 AA covers what 2.0 AA asks, with one technical footnote: the W3C removed an old criterion on HTML parsing (4.1.1) in 2.2. In practice, a site built to 2.2 AA is ahead of the Ontario requirement, not beside it. We build every site to WCAG 2.2 AA for that reason, whatever the organization’s size.

What happens if you do not comply?

The honest picture is less dramatic than many vendor pages suggest, and more serious than ignoring it.

Enforcement starts with the ministry. A director appointed under the Act can inspect, and can order an organization to comply with a standard by a set date. The director can also require an administrative penalty (AODA, section 21).
The large fines are for offences. Section 37 sets fines of up to $50,000 a day for an individual and $100,000 a day for a corporation. Those apply to specific offences: giving false or misleading information in an accessibility report, failing to comply with a director’s order, or intimidating someone who seeks enforcement. They are not an automatic charge for having an inaccessible page.
Not filing the compliance report can lead to enforcement measures, which Ontario says can include financial penalties (ontario.ca, completing your accessibility compliance report).

In short, the realistic risk for most organizations is an order to fix things on a deadline, and a penalty if they do not.

We have fewer than 50 employees. Should we bother?

You are not legally required to make the website meet WCAG, but there are practical reasons to do it anyway.

Your members already include people who need it. Screen reader users, people who zoom to 200 per cent, people using a keyboard instead of a mouse.
You still owe accessible information on request. It is far easier to meet that duty when the website is accessible to begin with than to produce alternative formats one request at a time.
Organizations grow. Crossing 50 employees brings the website rule in, and fixing an old site is usually harder than building it right.
Accessible sites are easier for everyone to use. Clear headings, readable contrast and forms that explain their errors help every visitor.

Where to start

Count your Ontario employees the way Ontario counts them, above.
If you have 20 or more, file the compliance report by 31 December 2026 through the Accessibility Compliance Reporting Portal.
If you have 50 or more, check your public website against WCAG 2.0 AA, including PDFs and forms, and fix what fails.
Whatever your size, write down how someone can ask for information in an accessible format, and make sure the answer reaches a person.
Brief whoever edits the site, staff or volunteers, on the basics: real headings, alt text on images, link text that says where it goes, and accessible PDFs.

This article is general information about Ontario’s rules, not legal advice. Other provinces have their own accessibility laws, and federally regulated organizations such as banks, telecoms and transportation companies fall under the Accessible Canada Act instead.

If you would like a second pair of eyes on where your website stands, schedule a discussion.

Sources (checked 30 September 2026)