AODA & ACA Compliance

Overview

Guides compliance with Canadian accessibility laws: the Accessibility for Ontarians with Disabilities Act (AODA) at the provincial level and the Accessible Canada Act (ACA) at the federal level. Covers technical standards, deadlines, reporting, and penalties.

Instructions

When conducting a Canadian accessibility review:

1. Determine which law applies:

   • AODA — any organization with 1+ employees in Ontario
   • ACA — federally regulated organizations (banking, telecom, transport, federal government)
   • Both may apply simultaneously

2. Identify the technical standard:

   • AODA requires WCAG 2.0 Level AA (with exceptions for 1.2.4 and 1.2.5)
   • ACA requires CAN/ASC-EN 301 549:2024 (= EN 301 549 v3.2.1, incorporating WCAG 2.1 AA)

3. Evaluate digital properties against the applicable standard

4. Check reporting obligations — both laws require periodic accessibility plans and reports

5. Provide remediation guidance referencing specific WCAG criteria or EN 301 549 clauses

AODA (Ontario)

Who Must Comply

All organizations with 1+ employees in Ontario: private businesses, non-profits, public sector.

• Small organizations (1–49 employees): fewer reporting requirements
• Large organizations (50+ employees): full compliance and reporting

Five Standards

1. Customer Service — accessible customer service policies
2. Information and Communications — accessible websites, documents, feedback
3. Employment — accessible hiring, accommodation, return-to-work
4. Transportation — accessible transit (public transit providers)
5. Design of Public Spaces — accessible built environment

Technical Requirements (Digital)

WCAG 2.0 Level AA, excluding:

• 1.2.4 Captions (Live)
• 1.2.5 Audio Description (Prerecorded)

Deadlines

Obligation	Date
Public-facing web content meets WCAG 2.0 AA (50+ employees)	January 1, 2021
All AODA standards fully met	January 1, 2025
Next compliance report (designated public sector)	December 31, 2025
Next compliance report (20+ employees)	December 31, 2026

Penalties

• Individuals: up to $50,000/day
• Corporations: up to $100,000/day
• Typical fines: $500–$15,000 depending on severity
• Directors and officers face personal liability

ACA (Federal)

Who Must Comply

Federally regulated entities: banks, telecom, transportation, broadcasting, federal government, Crown corporations.

Technical Standard

CAN/ASC-EN 301 549:2024 — Canada adopted EN 301 549 v3.2.1 as a national standard in May 2024. This is broader than WCAG alone and covers:

• Web content (WCAG 2.1 AA)
• Non-web documents (PDFs, Office files)
• Mobile applications
• Software and hardware

Deadlines (Phase 1 Regulations)

Obligation	Date
Federal public sector — new/updated web pages conform to CAN/ASC-EN 301 549	December 2027
Large/medium private businesses — new/updated web pages conform	December 2028
Mobile apps and digital documents — phased rollout	2028–2029

Reporting Requirements

• Accessibility plans — published, updated every 3 years, developed in consultation with persons with disabilities
• Annual progress reports — between plan updates
• Feedback mechanism — public process for receiving accessibility feedback
• Accessibility statement — standard used, conformance level, contact for barriers

Penalties

Administrative monetary penalties (AMPs) classified as "minor" for ICT non-conformance. Focus is on promoting compliance, not punishment.

Comparison: AODA vs ACA

	AODA	ACA
Scope	Ontario only	Federal jurisdiction
WCAG version	2.0 AA	2.1 AA (via EN 301 549)
Beyond web	No	Yes (documents, apps, hardware)
Enforcement	Active, fines	AMPs, compliance-focused
Physical spaces	Yes (Design of Public Spaces)	No (ICT focus)
Reporting	Periodic compliance reports	3-year plans + annual reports

Examples

Example: Ontario Business Website

Input: "We're a 30-person company in Ontario, what do we need?"

Response approach:

1. AODA applies — small organization (under 50)
2. Audit website against WCAG 2.0 AA (minus 1.2.4 and 1.2.5)
3. Note that the January 1, 2025 full-compliance deadline has passed
4. Recommend targeting WCAG 2.1 AA for future-proofing
5. Check if filing obligations are met

Example: Federal Bank

Input: "Our bank needs to comply with Canadian accessibility law"

Response approach:

1. ACA applies — banking is federally regulated
2. If Ontario-based, AODA also applies
3. Audit against CAN/ASC-EN 301 549:2024 (broader than WCAG alone)
4. Check documents, mobile app, and software — not just website
5. Verify accessibility plan and feedback mechanism are published
6. Note December 2027 deadline for web page conformance

Guidelines

• Always determine AODA vs ACA applicability — many organizations are subject to both
• AODA references WCAG 2.0 but recommend targeting 2.1 AA for ACA alignment
• ACA uses EN 301 549 which is broader than WCAG — covers documents, apps, software
• Note that AODA enforcement has historically focused on reporting failures, not technical compliance
• Ontario's "fully accessible by 2025" goal was aspirational — enforcement continues beyond 2025

References

• AODA: https://www.ontario.ca/laws/statute/05a11
• Accessible Canada Act: https://laws-lois.justice.gc.ca/eng/acts/A-0.6/
• CAN/ASC-EN 301 549:2024: https://accessible.canada.ca/creating-accessibility-standards/canasc-en-301-5492024-accessibility-requirements-ict-products-and-services
• WCAG 2.0: https://www.w3.org/TR/WCAG20/
• WCAG 2.1: https://www.w3.org/TR/WCAG21/