Filing deadline: December 31, 2026

Your accessibility report is due. Your website is the part nobody checked.

Most Ontario organizations know the compliance report is coming. Far fewer have looked at whether their website would survive being asked about — and the website requirement has been in force since January 1, 2021.

Two obligations, two different thresholds

These get conflated constantly, including by vendors selling against them. They are not the same rule and they do not apply to the same organizations.

20 or more employees — the compliance report
Every Ontario business and non-profit at this size files an accessibility compliance report with the province. The next one is due December 31, 2026. It is a self-report, and it asks what you have done.
50 or more employees — the website requirement
Section 14 of O. Reg. 191/11 requires designated public sector organizations and organizations with 50 or more employees to meet WCAG 2.0 Level AA on their websites and web content. The compliance date was January 1, 2021. An organization that has not met it is already years past the deadline, not facing a future one.
What section 14 does not cover
Three limits worth knowing, because they are routinely overstated by people selling against them. The section reaches content published after January 1, 2012, and sites the organization controls directly or through a contractual relationship that allows for modification — so a vendor platform you cannot change sits differently, and the contract is where that gets decided. Two Level AA success criteria are expressly excluded: 1.2.4 Captions (Live) and 1.2.5 Audio Descriptions (Pre-recorded). And the whole section is qualified by except where meeting the requirement is not practicable.
Between 20 and 49 employees
The report is still filed. Section 14 imposes no website obligation at this size — so anyone citing the regulation at you here is overreaching. The argument for fixing the site is the customers you are turning away, and that argument is usually the stronger one anyway.

Name the failure, name the fix

Most accessibility reports hand over a score and leave you to work out what to do with it. A score is not actionable and it is not defensible — it tells a developer nothing and it tells a regulator less.

Every finding in an audit written here names three things: the element, the success criterion it breaches, and the specific change that resolves it — written so the developer who has to make that change can act on it without a specialist sitting beside them.

What the audit covers, per page template

It ends with a prioritized remediation plan and a walkthrough call, so the list arrives explained rather than emailed.

Priced by page template, not by page

A 500-page site built from eight page types is eight units of work. Auditing page 340 of a news archive tells you nothing page 12 did not. Quoting by page count produces a large, frightening number with no relationship to the effort involved — which is why almost everyone does it.

Focused audit

Up to 3 page templates

from $2,200

The critical path — usually a homepage, a form, and the one flow that earns money.

Standard audit

4–8 page templates

$2,500 – $4,500

A whole marketing site with its forms, or a site plus one transactional surface.

Comprehensive audit

9+ templates, or application-heavy

from $5,000

Data tables, custom widgets, maps, multi-step flows — anything with real state in it.

Registered charities, non-profits and community organizations: a sliding scale applies, typically 25–35% below these figures. See how that works →

Two add-ons, priced up front:

Re-test after remediation — 35% of the original audit fee. Same templates, known findings, no discovery to repeat.

Half-day team training or design-system review — $1,000. Auditing at the end catches problems one project at a time. Training the people who set type sizes, choose colours and lay out navigation prevents them across every project that follows.

Remediation itself carries no discount and no published price. It is quoted once the audit is done, at the commercial hourly rate. Scope is unknowable until somebody has looked, and pre-committing a fixed reduction on the one piece of work that can overrun is how fixed-price engagements go bad.

Where this came from

The practice behind this was built auditing and remediating enterprise systems to WCAG 2.1 AA — banking, federal and Ontario government, and health care. Its most useful result was not a report at all: accessibility ended up positioned as a delivery input rather than a pre-launch scramble, with testing moved out of manual review and into an automated pipeline gate.

Twenty years of web work sit behind that, most of the last decade on compliance. Formerly IAAP WAS certified, currently in renewal.

This site is built to the standard it sells. Skip links, aria-current, managed focus, reduced-motion handling — and four accessibility audits that run in CI and block the deploy on failure, including one that resolves contrast through gradients because axe cannot. The tooling is in the repository, not described in a brochure.

Questions worth answering before a call

Does the AODA apply to my organization?

Two different thresholds are often confused. Any Ontario business or non-profit with 20 or more employees must file an accessibility compliance report — the next one is due December 31, 2026. The website conformance requirement in section 14 of O. Reg. 191/11 is separate and applies to designated public sector organizations and to organizations with 50 or more employees. Between 20 and 49 employees the filing is still required, but section 14 does not impose a website obligation.

What is the difference between WCAG 2.0 AA and WCAG 2.1 AA?

Ontario's regulation names WCAG 2.0 Level AA, and expressly excludes two of its criteria — 1.2.4 Captions (Live) and 1.2.5 Audio Descriptions (Pre-recorded). WCAG 2.1 adds success criteria that 2.0 predates, most of them covering mobile, low vision and cognitive access: reflow at 320 pixels, text spacing, orientation, and pointer target behaviour. Audits here are run to 2.1 AA, with anything outside the Ontario requirement marked as such — so you can see what the law asks for and what good practice asks for without the two being blurred together.

Is a finding in the report always a legal failure?

No, and the report says which is which. Section 14 is qualified by except where meeting the requirement is not practicable, it reaches content published after January 1, 2012, and it covers what you control directly or can change under a contract. A finding on a 2009 archive page, or inside a vendor platform you have no right to modify, is real and worth knowing about — but it is not the same thing as a breach, and a report that presents them identically is not much use when you have to decide what to fund.

What does an accessibility audit cost?

A focused audit of up to three page templates starts at $2,200. A standard audit of four to eight templates runs $2,500 to $4,500. Nine or more templates, or application-heavy interfaces, start at $5,000. Registered charities, non-profits and community organizations are quoted on a sliding scale, typically 25–35% below these figures.

Why is the audit priced by page template instead of by page?

A 500-page site built from eight page types is eight units of work. Auditing page 340 of a news archive tells you nothing page 12 did not. Quoting by page count produces a large, frightening number that has no relationship to the effort involved.

How long does remediation take, and what does it cost?

Remediation is quoted after the audit, at the commercial hourly rate, with no discount and no published price. Scope is genuinely unknowable until the audit is finished, and committing a fixed reduction to the one piece of work that can overrun is how fixed-price engagements go bad.

Will an accessibility overlay or widget satisfy the requirement?

No. An overlay runs as JavaScript on the pages where it is installed, so it cannot repair markup on a checkout or booking engine hosted on another domain — which is where a great many transactions actually happen. It also cannot supply a missing form label in a way assistive technology reliably reports. The regulation asks for conformance, not for a widget.

Find out where you actually stand

Twenty minutes, no preparation needed. You will leave the call knowing which of the two obligations applies to you, and roughly what the work looks like.

Book a 20-minute call