AODA Compliance Checklist | Ensure Website Accessibility

01. Confirm what applies to you

Count your employees in OntarioObligations scale with headcount. Organizations with 20 or more employees must file a compliance report. At 50 or more, the requirements widen to include a written multi-year accessibility plan and WCAG 2.0 Level AA conformance for public-facing websites.

Check how you're countingEmployee counts include full-time, part-time, and seasonal employees in Ontario. Confirm your method before you assume which band you're in; organizations sitting near a threshold are the ones most likely to get this wrong.

Find your last filingThe previous reporting deadline was December 31st, 2023. Pull that submission and read what was claimed. If your headcount has crossed a threshold since then, your obligations have changed.

Why this matters Requirements are tiered, and the tiers are easy to misjudge. An organization that grew past 50 employees since its last filing has picked up website obligations it may not know about.

02. Know what you're attesting to

Read the actual form before you start gathering evidenceThe report is a series of confirmations of compliance with the Integrated Accessibility Standards Regulation – accessible customer service, employment practices, information and communications, training, and the multi-year plan. Know the questions before you answer them.

Identify the certifying officerThe filing requires the name and contact information of a senior officer who certifies the report. Confirm who that is early, and make sure they see the evidence rather than just the final form.

Map every answer to something you can produceFor each confirmation, know which document, training record, plan, or test result supports it. If you can't point to the evidence, treat the answer as unresolved.

Why this matters This is a self-assessment, not an audit performed by someone else. A signature attests that the answers are accurate. “We understood it was covered” is not evidence.

03. Establish where your website stands

Define what counts as yoursList your public-facing sites, subdomains, web applications, customer portals, and embedded third-party tools. Scope creep in either direction is a problem; untested properties and properties you don't control both need to be identified.

Test against WCAG 2.0 Level AAThat's the standard referenced in the regulation for organizations with 50 or more employees. Ontario has signaled movement toward a newer version of WCAG in future cycles, so build for the standard rather than the minimum.

Separate what a scan found from what a scan can't detectAutomated testing reliably surfaces certain categories of issues: missing alt attributes, contrast ratios, and some structural issues. Keyboard operability, focus order, whether alt text is actually meaningful, error handling in forms, and whether a task can be completed end-to-end need human review.

Why this matters Automated testing covers a portion of WCAG success criteria. Attesting to conformance based on a clean scan leaves the largest and most consequential categories unverified.

04. Handle what you find

Triage by whether it blocks a taskStart with anything that stops someone from completing a core flow: logging in, submitting a form, applying, paying, booking. Cosmetic and low-impact issues come after.

Write a dated plan for what you can't finishAnything not fixable before December 31st should have an owner, a scope, and a target date recorded. A documented plan is a defensible position; an undocumented gap is not.

Resolve or record third-party componentsFor embedded tools, plugins, and vendor-supplied interfaces, either get the fix or document the limitation, its user impact, and the vendor's commitment and timeline.

Why this matters Nobody remediates a full site in a few weeks. What separates a reasonable position from an exposed one is whether the gaps were identified, prioritized, and recorded, or simply overlooked.

05. File and keep the record

Submit through Ontario's reporting portal before December 31, 2026Filing is done through the Government of Ontario's Accessibility Compliance Reporting portal. Don't leave it to the final week; portal issues in late December are predictable.

Keep the evidence togetherTest results, remediation plan, training records, multi-year accessibility plan, accessibility policy, feedback process documentation, and vendor correspondence. One file, one owner.

Set a review cadence, not a reminder, for 2029Accessibility drifts with every content update, template change, and redesign. Organizations that treat this as a filing event rediscover the same problems at the next deadline.

Why this matters The report is a moment. The obligation is continuous. What gets examined if a complaint or enforcement action follows is whether you had a process, not only whether you submitted the form.

The AODAcompliance checklist