AODA and ACA: Canada's Accessibility Laws Explained

Two frameworks, one goal

Canada has approached web accessibility through two distinct legislative frameworks. The Accessibility for Ontarians with Disabilities Act (AODA) operates at the provincial level in Ontario, with specific enforceable technical standards for web content. The Accessible Canada Act (ACA), enacted federally in 2019, applies to federally regulated organizations across Canada.

Understanding which law applies to your organization — and what it actually requires — is the starting point for compliance.

AODA: Ontario’s landmark accessibility law

The Accessibility for Ontarians with Disabilities Act was passed in 2005 with an ambitious goal: a fully accessible Ontario by 2025. It was the first legislation in the world to set a comprehensive government-enforced timeline for full accessibility.

Who AODA covers

AODA applies to every organization in Ontario with at least one employee — public sector, private sector, and not-for-profit alike. If you operate a business in Ontario, hire Ontario staff, or serve Ontario customers through a digital product, AODA almost certainly applies.

What AODA requires for web content

The web content requirements fall under the Integrated Accessibility Standards Regulation (IASR), specifically the Information and Communications Standard. Requirements are phased by organization size and sector:

Large organizations and public sector (more than 50 employees):

New websites and significantly refreshed existing websites must meet WCAG 2.0 Level AA since January 2014
All web content must have met WCAG 2.0 Level AA since January 2021

Small private and not-for-profit organizations (1–49 employees):

New websites and significant refreshes must meet WCAG 2.0 Level AA
All web content must meet WCAG 2.0 Level AA since January 2021

Note that AODA specifically references WCAG 2.0 (not 2.1 or 2.2). However, many accessibility practitioners and compliance programs recommend targeting WCAG 2.1 AA as a baseline, since it addresses additional barriers — particularly on mobile — and represents the current state of best practice.

AODA also provides some specific exceptions, including where conformance would create an “undue hardship” — though this exception has a high bar and requires documentation.

Enforcement

AODA is enforced by the Ontario government through mandatory accessibility reports. Organizations with 20 or more employees must file accessibility compliance reports with the government on a schedule (typically every three years). Failure to file, or filing false information, can result in fines.

Beyond mandatory reporting, the government can conduct compliance audits and investigate complaints. Fines range from $200–$100,000 per day for individuals and $200–$500 per day for organizations (amounts vary based on whether it’s a first or repeated offence). Corporations can face higher fines.

The “Nothing Without Us” philosophy — the principle that accessibility standards should be developed with meaningful involvement from people with disabilities — is embedded in AODA’s structure, and the standards are reviewed periodically to ensure they remain relevant.

The Accessible Canada Act

The Accessible Canada Act (ACA) came into force in July 2019, with the goal of a “barrier-free Canada” by January 1, 2040. Unlike AODA, it operates at the federal level and applies to a specific set of organizations.

Who the ACA covers

The ACA applies to federally regulated entities, including:

Federal government departments and agencies
Crown corporations
Parliament
Banks and federal financial institutions
Telecommunications companies (radio, television, phone, internet providers)
Airlines and federally regulated transportation companies
The postal service (Canada Post)

Importantly, the ACA does not directly cover provincially regulated businesses or municipal governments. If you’re a retail business operating only in Ontario, you’re covered by AODA, not the ACA.

What the ACA requires

The ACA takes a framework approach: rather than prescribing specific technical standards upfront, it requires covered organizations to:

Develop and publish accessibility plans describing how they will identify, remove, and prevent barriers to people with disabilities in their operations
Establish feedback processes allowing people to provide feedback on accessibility
Publish progress reports describing what they’ve done to implement their plans

The ACA also established several new institutions:

Accessibility Standards Canada — develops accessibility standards
Chief Accessibility Officer — advises the responsible minister
Accessibility Commissioner — handles complaints and enforcement

Regulations under the ACA are being developed incrementally. The Canadian Radio-television and Telecommunications Commission (CRTC) and the Canadian Transportation Agency (CTA) have issued specific accessibility regulations within their sectors.

How AODA and ACA interact

For most organizations, one framework applies and the other doesn’t. A bank that’s federally chartered falls under ACA; a retail store that operates exclusively in Ontario falls under AODA.

Some organizations are covered by both. The federal government of Canada itself must comply with AODA when it operates in Ontario, and with ACA in its federal capacity.

If you’re unsure which framework covers your organization, the question to ask is: are you regulated federally (banking, telecom, air travel, broadcasting) or provincially?

What good compliance looks like in practice

Both laws ultimately point to the same practical standard: your web content should meet WCAG 2.1 Level AA. This is the current baseline of best practice, even if AODA technically specifies WCAG 2.0.

Practical compliance includes:

Running regular automated accessibility scans to catch the detectable portion of WCAG failures
Supplementing automated testing with manual review using assistive technology
Publishing an accessibility statement or plan (required under ACA; good practice under AODA)
Establishing a genuine feedback mechanism for users to report barriers
Building accessibility into your development and content workflows so new barriers don’t accumulate

If you operate in Canada and haven’t assessed your current position, a free automated scan is the fastest way to understand where your website stands today.