Federal Accessibility Requirements
Accessible Canada Act (ACA)
The Accessible Canada Act came into force in 2019 and applies primarily to federally regulated organizations, including:
- Banks and financial institutions
- Telecommunications companies
- Airlines and airports
- Rail, marine, and interprovincial transportation providers
- Federal government departments and agencies
Organizations covered by the ACA are required to:
- Identify, remove, and prevent accessibility barriers
- Publish accessibility plans
- Establish feedback processes
- Publish progress reports
- Consider accessibility in employment, information and communication technologies (ICT), communications, procurement, transportation, and built environments
Provincial Accessibility Requirements
Ontario – AODA
The Accessibility for Ontarians with Disabilities Act (AODA) establishes accessibility standards for organizations operating in Ontario. Organizations with 1–49 Employees. Requirements include:
- Accessible customer service
- Accessibility training for employees and volunteers
- Accommodation of individuals with disabilities
- Accessible communication upon request
- Compliance with the Ontario Human Rights Code
Website WCAG compliance is not generally mandated for private organizations under 50 employees, but accessible digital services are strongly recommended.
Organizations with 50+ Employees, In addition to the above, organizations must:
- Maintain accessibility policies
- Develop accessibility plans
- File accessibility compliance reports (where applicable)
- Ensure public websites and web content conform to WCAG requirements
- Provide accessible employment practices
Manitoba
The Accessibility for Manitobans Act requires organizations to identify, prevent, and remove barriers related to:
- Customer service
- Information and communication
- Employment
- Transportation
- Public spaces
British Columbia
The Accessible British Columbia Act requires organizations to identify and address accessibility barriers and develop accessibility plans where applicable.
Nova Scotia
The Accessibility Act aims to make Nova Scotia accessible by 2030 through accessibility standards and barrier prevention initiatives.
Human Rights Obligations
Regardless of organization size, businesses must comply with applicable human rights legislation. Organizations should not:
- Deny services because of a disability
- Create unnecessary barriers to accessing information
- Fail to accommodate individuals with disabilities where reasonable
Accessibility is therefore relevant to organizations of all sizes, even when specific WCAG requirements do not apply.
- Small businesses (when applicable under AODA scope)
- Medium and large enterprises
- Non-profits
- Public sector organizations
Accessibility Requirements by Organization Size
Small Businesses (1–49 Employees)
Under Ontario’s Accessibility for Ontarians with Disabilities Act (AODA), private organizations with fewer than 50 employees have accessibility obligations, including:
Required
- Provide accessible customer service
- Train employees and volunteers on accessibility requirements
- Accommodate individuals with disabilities
- Provide accessible formats and communication supports upon request
- Comply with applicable Human Rights legislation
- Make employment accommodations for employees with disabilities
Recommended Best Practices
- Ensure websites conform to WCAG 2.2 Level AA
- Conduct accessibility testing
- Provide accessible PDFs and documents
- Establish an accessibility feedback process
- Publish an accessibility statement
- Websites are created, updated, or significantly modified – Required standard: WCAG 2.0 Level AA (for applicable content)
Medium and Large Organizations (50+ Employees)
Organizations with 50 or more employees have additional legal obligations.
- All Small Business requirements
- Written accessibility policies
- Multi-year accessibility plan
- Accessibility compliance reporting
- Public accessibility documentation
- Accessible recruitment and employment processes
- Emergency response information for employees with disabilities
- Public websites and web content meeting WCAG requirements under AODA
- Accessibility governance and monitoring processes
Federally Regulated Organizations
Organizations regulated by the federal government must comply with the Accessible Canada Act. Examples include:
- Banks
- Telecommunications providers
- Airlines
- Airports
- Rail transportation
- Federal agencies
- Includes municipalities, universities, hospitals, etc.
Required
- Accessibility Plan
- Accessibility Feedback Process
- Progress Reports
- Barrier Identification and Removal
- Accessibility Considerations in:
- Employment
- ICT and Digital Services
- Communications
- Procurement
- Transportation
- Built Environment
What Happens If a Business Fails to File an Accessibility Report?
Failure to comply with AODA reporting requirements can lead to serious legal and financial consequences.
Possible consequences include:
1. Compliance enforcement actions
- Government inspections or audits
- Orders to submit missing reports or fix compliance gaps
- Mandatory corrective action plans
2. Financial penalties
Under the AODA, organizations can face administrative monetary penalties if they fail to comply with accessibility requirements, including website accessibility requirements that reference WCAG.
- Corporations may face fines of up to $100,000 per day
- Directors or officers may face fines of up to $50,000 per day
- Other persons/organizations may face fines up to $15,000 per day
Non-compliance with accessibility laws can expose organizations to substantial financial penalties, legal action, and reputational damage. In Ontario, corporations may face penalties per day for serious AODA violations, in addition to the costs of remediation and potential legal proceedings.
3. Legal and reputational impact
- Public listing of non-compliant organizations
- Increased regulatory scrutiny
- Damage to brand trust and procurement eligibility
4. Ongoing non-compliance escalation
Repeated failure to comply may result in:
- Increased enforcement actions
- Higher penalties
- Legal proceedings under provincial accessibility regulations
Sources
- Ontario Government — Accessibility rules for businesses and non-profits
Accessed context reference: June 24, 2026 - AODA compliance guidance summaries (training and audit interpretations)
Accessed context reference: June 24, 2026 - Manitoba Government – The Accessibility for Manitobans Act
Accessed context reference: June 24, 2026 - Canada Government Accessibility Standards Canada
Accessed context reference: June 24, 2026
Location
WATERLOO, ON N2L 5Y9
CANADA
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