In Ontario, designated public sector organizations and businesses or non-profits with 50 or more employees must make the public websites and web content they control conform to WCAG 2.0 Level AA, subject to two media exceptions. The rule covers content published after January 1, 2012, including web-based applications. The January 1, 2021 compliance deadline has passed; it is not a future grace period.
Who has to meet Ontario’s website accessibility rule?
Ontario’s Integrated Accessibility Standards Regulation (IASR) applies the public-website requirement to designated public sector organizations and businesses or non-profits with at least 50 employees. The employee threshold is specific to businesses and non-profits; designated public sector organizations are covered under their own category. Ontario’s website accessibility guidance describes these requirements.
The organization responsible is the one that controls the website or web content. Control may be direct or exercised through a contractual relationship that permits the organization to modify the site or content. Hiring a vendor to build or host a site does not, by itself, settle who is responsible; review the actual control and contract terms.
Small businesses and non-profits
Organizations with fewer than 50 employees are not required under the IASR website rule to meet this particular public-website requirement. Ontario encourages them to make their websites accessible. Do not confuse that website threshold with the separate threshold for filing an accessibility compliance report.
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What WCAG standard and deadline apply?
Covered websites, web content and web-based applications must conform to the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG) 2.0 Level AA. The regulation exempts success criterion 1.2.4, Captions (Live), and criterion 1.2.5, Audio Descriptions (Pre-recorded). Ontario notes that, in most cases, Level A criteria must be met before the required Level AA criteria can be met.
Ontario Regulation 191/11, section 14, sets the scope and standard: Ontario Regulation 191/11. The implementation schedule set January 1, 2021 as the deadline for covered organizations’ internet websites and web content to meet Level AA, with the same two media exceptions. That date is historical: covered organizations should treat the requirement as currently in force.
Which pages and content are covered?
The rule applies to web content published after January 1, 2012, on websites or in web-based applications the organization controls. It reaches more than ordinary public-facing pages: the regulation also names web-based applications. Content hosted or maintained by a contractor can be covered when the organization’s contract gives it power to modify the product.
Older content and new material on an older site
The relevant dividing line is the content’s publication date, not simply the launch date of the website. The rule concerns content published after January 1, 2012. For a site that has been online for years, inventory the covered content rather than treating the entire site as either automatically exempt or automatically covered based only on its original launch.
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Intranets and extranets
Ontario says internal intranets and extranets do not have to meet the public website WCAG 2.0 A/AA requirement. That does not remove the obligation to respond to an individual’s accessibility needs: if someone asks for information in an accessible alternate format, the organization must work with that person to meet their needs. See Ontario’s guidance on when public websites are not accessible.
Are there exceptions?
The regulation says the requirements apply except where meeting them is not practicable. In assessing practicability, an organization may consider factors including the availability of commercial software or tools and a significant impact on implementation timelines planned or started before January 1, 2012. Ontario describes circumstances related to the website requirement in its guidance on website accessibility exceptions.
This is a bounded, fact-specific provision, not a blanket exemption for an old site, a third-party platform, cost, or inconvenience. Document the specific barrier and relevant circumstances, and assess the actual regulation and facts before relying on it.
How to assess and improve a website
- Confirm coverage and control. Identify whether the organization is a designated public sector organization or a business/non-profit with at least 50 employees. Determine which entity controls the site and whether any contractor agreement gives the organization power to make changes.
- Inventory the scope. List public pages, web-based applications and content published after January 1, 2012. Include material hosted or operated by vendors where the organization has the relevant control.
- Assess against WCAG 2.0 Level AA. Use the success criteria to identify barriers, accounting for the two stated media exceptions and the relationship between Level A and Level AA criteria.
- Use automated checks and human review. Automated testing can flag some issues consistently, while manual review is needed for issues that require human judgment or interaction. Ontario’s guidance for beta testing government services recommends both manual and automated testing; it does not say a single scan certifies legal compliance. See Making government services accessible.
- Track remediation. Record the issue, affected page or application, responsible owner, remediation decision and follow-up check. If considering impracticability, record the facts supporting that conclusion rather than relying on a general policy.
- Check reporting separately. Determine whether the organization also has a reporting obligation; the reporting thresholds and cycles differ from the website-conformance rule.
Reporting duties are separate from website conformance
Businesses and non-profits with 20 or more employees must file an accessibility compliance report every three years. Ontario’s current stated deadline is December 31, 2026. This reporting threshold is lower than the 50-employee threshold for the website rule, so some organizations may need to report even though the specific public-website requirement described above does not apply to them. Details are on Ontario’s accessibility rules for businesses and non-profits.
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Designated public sector organizations report every two years. Their 2025 deadline was December 31, 2025; Ontario says organizations that missed it should submit as soon as possible. Consult the province’s accessibility rules for public sector organizations. Filing a report and meeting website conformance are distinct obligations.
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