The short version
- Ontario businesses and non-profits with 20 or more employees must file an accessibility compliance report by December 31, 2026.
- It's filed online, takes most businesses well under an hour, and has to be certified by a senior officer.
- If you have 50 or more employees, one of the things you're confirming is that your public website meets WCAG 2.0 Level AA.
- Under 20 employees? You don't file, but the AODA still applies to you in other ways.
Every three years, Ontario asks larger businesses and non-profits to confirm in writing that they're following the province's accessibility law. 2026 is one of those years, and the deadline is the end of December, right in the middle of the holidays when nobody wants to deal with paperwork.
The report itself isn't hard. The part that catches people off guard is what they're actually signing off on, especially the website question. This guide walks through both.
Who has to file the 2026 report?
Under the Accessibility for Ontarians with Disabilities Act (AODA), you need to file if you're one of these:
- A business or non-profit with 20 or more employees in Ontario. These organizations file every three years, and the current report is due December 31, 2026.
- A designated public sector organization (municipalities and other listed bodies). These file every two years and had their own deadline at the end of 2025.
If you have fewer than 20 employees, you generally don't file a report. That doesn't mean the AODA ignores you. Smaller organizations still have obligations, like customer service accessibility, they just don't have to report on them.
If you're close to 20 employees and not sure which side of the line you're on (part-time and seasonal staff can make this fuzzy), check the province's guidance on counting employees before you decide you're exempt.
How to file it (it's quicker than you think)
The report is filed online through the province's Accessibility Compliance Reporting Portal. For a typical small business, the process looks like this:
- Gather the basics. Your organization's legal name, your 9-digit business number (BN9), your number of Ontario employees, and the name and contact details of the person who will certify the report.
- Pick your certifier. It has to be a senior officer with the legal authority to confirm the report is complete and accurate. For most small businesses, that's the owner or president.
- Create an account on the portal and start a new submission for the accessibility compliance report.
- Answer the questions. They're mostly yes or no questions about whether you're meeting your AODA requirements: training, policies, customer service, employment, and information and communications (which is where your website comes in).
- Submit it and keep a copy of the confirmation for your records.
Most businesses can get through the form in well under an hour. The time sink is when you hit a question and realize you don't actually know the answer, which brings us to the website.
The website question: does WCAG apply to you?
This is the part people skim, and it's the part that matters most for anyone with a website.
If your organization has 50 or more employees, the AODA has required since January 1, 2021 that your public website, and web content posted after January 1, 2012, meets WCAG 2.0 Level AA. (Live captions and pre-recorded audio descriptions are the two exceptions.) When you file the compliance report, you're confirming that you meet that requirement.
If you have 20 to 49 employees, the website requirement doesn't apply to you, but you still file the report for everything else.
WCAG (the Web Content Accessibility Guidelines) is an international standard. Level AA covers things like:
- Text with enough contrast to read, including for people with low vision
- Alt text on images, so screen readers can describe them
- Menus, forms and pop-ups that work with a keyboard alone
- Form fields with proper labels and clear error messages
- Headings that are actually headings, so the page structure makes sense
- Captions on pre-recorded video
Most small business websites we look at fail at least a few of these. Usually it's nothing dramatic, just light grey text, missing alt text, a contact form built without labels, or a menu that only works with a mouse. But "mostly fine" isn't the same as compliant, and the report asks you to confirm compliance.
What if your website isn't there yet?
Be honest on the report. It's certified by a senior officer, and the province does audit organizations. A false "yes" is a bigger problem than an honest "not yet."
The better move is to use the next two months to close the gap:
- Get your site checked. An automated scan catches some issues, but not all of them. A proper check also means someone using your key pages with a keyboard and a screen reader. Our AODA accessibility service does both and gives you a plain-English list of what to fix.
- Fix the high-traffic pages first. Your homepage, main service pages, contact form and anything people book or buy through. That's where real customers run into problems.
- Deal with PDFs. Menus, price lists and forms posted as PDFs count as web content. Often the easiest fix is turning them into normal web pages.
- Add an accessibility statement and a simple way for visitors to tell you about problems.
Many small sites can be brought up to WCAG 2.0 AA in a few weeks. If your site is very old or built on a page builder that fights you at every step, a redesign that's accessible from day one can end up faster and cheaper than patching. That's also worth knowing if you're under 50 employees but growing.
Skip the overlay widgets
You've probably seen ads for accessibility toolbars you can add to your site with one line of code. They promise instant compliance. They don't deliver it.
Overlay widgets sit on top of your site and don't fix the underlying code or content. Disability advocates have spoken out against them, and in some cases they make things worse for people using screen readers. Fixing the actual site is the only real route to WCAG AA.
What happens if you don't file?
The province says organizations that don't complete the report can face enforcement measures, which can include financial penalties. The province also audits and inspects organizations to check compliance. Filing on time is the easiest way to stay off that list.
If you missed a past deadline, file the current report anyway. Filing late is better than not filing.
A simple plan for November and December
- Confirm your Ontario employee count (20+ means you file, 50+ means the website rule applies).
- Decide who will certify the report and make sure they have time before the holidays.
- If you're 50+, get your website checked against WCAG 2.0 AA now, not in December.
- Fix the key pages and PDFs, and add an accessibility statement.
- File through the portal before December 31, 2026 and save your confirmation.
Want a straight answer on your website?
Send us your web address and your number of Ontario employees. We'll tell you whether the website rule applies to you, what the biggest issues are, and give you a fixed quote to fix them.See our AODA accessibility service →