Canada website accessibility law: the Accessible Canada Act, the new digital rules and Ontario's AODA

This page covers federal law and Ontario in detail, with a short note on other provinces. For other countries, see web accessibility laws worldwide, or use which accessibility laws apply to my website.

Which rule applies to you

The Accessible Canada Act

The Accessible Canada Act (S.C. 2019, c. 10) applies to organizations under federal responsibility. The government's summary of the Act and its regulations names federal bodies, the Canadian Forces and the RCMP, Parliamentary entities, and "certain businesses like banks, airlines, and grain elevators". An organization that is not under federal responsibility is outside the federal Act.

Covered organizations must publish an accessibility plan, updated every three years after consulting persons with disabilities, set up a feedback process and describe it on their website, and publish progress reports. The first plans were due by December 31, 2022 for the federal government, June 1, 2023 for businesses with 100 or more employees, and June 1, 2024 for businesses with 10 to 99 employees. Businesses with 9 or fewer employees do not have to publish plans, progress reports or feedback descriptions.

Penalties under the Act

The maximum administrative monetary penalties are:

• Minor violations: up to $75,000
• Serious violations: up to $150,000
• Very serious violations: up to $250,000

The summary notes lower amounts for small businesses and individuals, and a 10% reduction for paying within 15 days.

Digital Technologies Phase 1: the new federal digital rules

Amendments to the Accessible Canada Regulations add specific digital requirements. The government's Digital Technologies Phase 1 guidance describes them; the regulations themselves are the authoritative text.

The standard

Accessibility Standards Canada adopted the European standard EN 301 549 as CAN/ASC-EN 301 549:2024. The rules apply:

• clauses 4 to 7 and 9 to web pages, including web applications;
• clauses 4 to 7 and 10 to digital documents, such as PDFs;
• clauses 4 to 7 and 11 to mobile applications.

Our page on EN 301 549 explains the European versions of the standard.

Who is covered

• Public sector: government departments and agencies, Crown corporations, the Canadian Armed Forces, the RCMP and parliamentary entities.
• Private sector: medium-sized organizations averaging 100 to 499 employees and large organizations averaging 500 or more, measured over the preceding three calendar years.
• Exempt: private organizations averaging 99 or fewer employees. First Nations Band Councils are exempt until December 31, 2033.

The two compliance dates

Web page and document requirements apply only to content newly published or updated on or after each date; existing public-facing mobile apps need a conformity assessment with gap analysis, not full conformance.

Two groups follow a modified schedule, mostly limited to employee-facing web pages: transportation service providers (TSPs), regulated by the Canadian Transportation Agency, and broadcasting or telecommunications organizations (BTOs), regulated by the Canadian Radio-television and Telecommunications Commission (CRTC). Check the guidance for your category.

Statements and exemptions

Organizations with a statement duty must publish at least one accessibility statement covering the areas they must meet, update it every 12 months, and keep each version for four years. Medium-sized private organizations are not listed as having a statement duty. Heritage content, user-generated content the organization does not own or contract for, and employee-facing collaborative workspaces are exempt from all Phase 1 requirements. Our accessibility statement generator produces a structured first draft.

Ontario: the AODA website rule

Under the Accessibility for Ontarians with Disabilities Act's Integrated Accessibility Standards (O. Reg. 191/11, section 14), Ontario's guidance on how to make websites accessible says that, as of January 1, 2021, public websites must meet WCAG 2.0 Level AA if the site belongs to:

• a designated public sector organization; or
• a business or non-profit organization with 50 or more employees.

Two criteria are excluded: 1.2.4 (live captions) and 1.2.5 (pre-recorded audio descriptions). The requirements apply to websites and web content published on a website after January 1, 2012.

Internal websites (intranets and extranets) do not have to meet WCAG 2.0 A or AA, except those of the Government of Ontario and the Legislative Assembly of Ontario. The organization that controls the website, directly or through a contract, is responsible.

AODA penalty amounts are not covered on this page.

Other provinces

Other provinces have their own accessibility laws. One example with a website rule: Manitoba's Accessible Information and Communication Standard Regulation requires WCAG 2.1 Level AA, at minimum, for new web content or content needed to access an organization's goods and services, and for new or significantly updated web applications. Its compliance dates were May 1, 2023 for the Manitoba government, May 1, 2024 for public sector organizations, libraries and educational institutions, and May 1, 2025 for private sector and non-profit organizations and small municipalities, according to the province's AccessibilityMB fact sheet, which notes that the regulation itself prevails. For the other provinces, start with the W3C's list of web accessibility laws and policies, which the W3C describes as not a comprehensive or definitive listing, and check the province's own legislation.

What to do now

1. Work out which rule reaches you

   A federally regulated organization, such as a bank, an airline or a grain elevator, looks to the Accessible Canada Act. An Ontario business or non-profit with 50 or more employees looks to the AODA.

2. Build to WCAG 2.2 Level AA

   Each WCAG version keeps the older criteria, so meeting WCAG 2.2 AA also meets the WCAG 2.0 AA rule in Ontario. For the federal rules, also check any clauses of CAN/ASC-EN 301 549:2024 that go beyond WCAG. See which WCAG version you need, our WCAG 2.2 checklist and all 86 WCAG 2.2 criteria.

3. Find what is broken

   Start with a free scan, then the contrast checker, heading checker and PDF checker for the documents the 2028 rules reach.

4. Check what needs judgment

   Rule-based scanners cannot tell whether alt text is accurate. Our alt text checker and deep audit compare the image with its description; why rule scanners miss issues explains the gap, and overlays and the FTC explains why a widget is not a shortcut.