Website Accessibility Law in Canada: AODA, ACA, Manitoba

If you sell or take bookings from customers in Canada, a website that people using screen readers or keyboards cannot use is both a legal and a commercial problem. This article explains the three rules you are most likely to meet, what each one requires, the penalties the law allows and a practical plan to work through. It covers Ontario, Manitoba and the federal framework. Other provinces and territories are not covered here. For the overview, see our Canada compliance page.

Which Canadian rules apply to your website?

Canadian accessibility law works in layers. Provincial laws apply to organizations in that province, and federal law applies to federally regulated sectors. The table gives you a first picture. Check the details for your own situation before you act on them.

Ontario AODA: WCAG 2.0 AA for organizations with 50+ employees

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its Integrated Accessibility Standards Regulation (O. Reg. 191/11) set accessibility rules for Ontario organizations. For websites, the rule is specific. Businesses and non-profits with 50 or more employees must make their internet websites and web content conform to WCAG 2.0 Level AA. This has applied since 1 January 2021.

Ontario's guidance lists two exceptions: live captions (criterion 1.2.4) and pre-recorded audio description (criterion 1.2.5). A 2020 government review committee recommended removing these exceptions. We could not confirm that this has happened, so check the current regulation text before you rely on them.

Ontario also requires an accessibility compliance report. Businesses and non-profits with 20 or more employees file every three years, and the next deadline is 31 December 2026. Some businesses therefore have a reporting duty before the website standard applies to them.

Accessible Canada Act: federally regulated organizations

The Accessible Canada Act (ACA) applies to federally regulated organizations such as banks, telecommunications companies, transport operators and broadcasters. Provincially regulated retail, health, education and manufacturing businesses are generally outside it. Covered organizations must publish an accessibility plan, report on progress every cycle and run a feedback process whose messages they must acknowledge.

The digital rules are new. In December 2025, the federal government registered amendments (SOR/2025-255) that make CAN/ASC-EN 301 549 the mandatory ICT standard. That standard is based on WCAG 2.1 AA. The rules are not yet in force. Federal public sector web pages must comply from 5 December 2027. Federally regulated private organizations that employ, on average, 100 or more people over the previous three years must comply for web pages from 5 December 2028. Mobile apps and digital documents apply to organizations with 500 or more employees on the same timetable. Private businesses with 99 or fewer employees are exempt.

Manitoba: WCAG 2.1 AA for organizations of any size

Manitoba's Accessible Information and Communication Standard Regulation (M.R. 47/2022), made under the Accessibility for Manitobans Act, requires websites and web applications to meet WCAG 2.1 Level AA. According to the province, the standard applies to all organizations in Manitoba with one or more employees. Private sector organizations and non-profits had until 1 May 2025 to comply, so that date has now passed.

The province's guidance says that new or significantly updated web content must meet WCAG 2.1 AA. Existing web content that people need in order to obtain your goods or services must also meet it, at a minimum. We could not confirm the current status or amounts of Manitoba's penalty rules, so this article does not state them.

What the penalties allow

The penalty figures below are maximums. They are not typical outcomes, and the amount in a given case depends on the violation.

• Ontario AODA: according to legal summaries of the Act, the maximum fine is up to CA$100,000 per day for a corporation and up to CA$50,000 per day for an individual, with similar exposure for directors and officers in some cases.
• Accessible Canada Act: section 91(2) sets a maximum penalty of CA$250,000 per violation. The Regulations set the ranges for each type of violation.
• Manitoba: penalty amounts are not stated here (see the section above).

Fines are not the only cost. A customer who cannot complete a checkout, a booking or a contact form is a lost sale, whatever the legal outcome.

A practical plan for Canadian businesses

Work through these steps in order. Each one narrows down what you actually need to do.

1. 1Confirm which rules apply. Note where your head office, staff and customers are. Find out whether your business is federally regulated. The answers decide which regime you are under.
2. 2Check your headcount against each threshold. Ontario: 20 employees for the compliance report and 50 for the website standard. Manitoba: one employee. Federal: 100 and 500 for the digital rules from 2028. Check how each regime counts employees in its own regulation.
3. 3Scan your key pages. Run an automated audit of your homepage, product or service pages, checkout or booking flow and contact forms. Test against WCAG 2.1 AA. This covers the WCAG 2.0 AA criteria that Ontario uses, and it matches the Manitoba requirement.
4. 4Test by hand. Automated tools catch only part of the issues. Use the site with the keyboard alone, and check it with a screen reader such as NVDA on Windows or VoiceOver on Mac and iPhone.
5. 5Fix the templates, not just the pages. Most problems come from shared components, such as menus, forms and colour choices. Fix them there, so new pages do not repeat the same barriers.
6. 6Provide a feedback route. Give visitors a clear contact for accessibility problems and requests for accessible formats. The ACA requires a feedback process for federally regulated organizations, and it is good practice for everyone else.
7. 7Calendar your deadlines. Put 31 December 2026 in the diary if you have 20 or more employees in Ontario. Note the December 2027 and December 2028 dates if you are federally regulated. Re-test after each major site release.
8. 8Keep dated records. Save each audit, each fix and the date it was made. These records help with any compliance report and show what you did and when.

This article is general information, not legal advice. For advice on your obligations, speak to a qualified Canadian lawyer.