Who this applies to
The Accessibility for Ontarians with Disabilities Act sets requirements that vary by organisation type and size. Broadly:
- Public sector organisations carry the most extensive obligations and the earliest deadlines
- Private and non-profit organisations with 50 or more employees carry web accessibility requirements and reporting obligations
- Private and non-profit organisations with fewer than 50 employees carry reduced obligations, though not none
Outside Ontario the specifics differ — other provinces have their own legislation at various stages, and the Accessible Canada Act applies to federally regulated organisations. If you sell into the United States, ADA-related litigation is a separate and more aggressive exposure. This page is not legal advice and the thresholds matter, so confirm your category with counsel rather than inferring it.
What it actually requires
The web requirements reference WCAG at a specified level. In practical terms, the things that most commonly fail an assessment:
- Keyboard access. Everything operable by mouse must be operable by keyboard, with visible focus. This alone accounts for a large share of real barriers.
- Text alternatives. Images that convey meaning need alt text; decorative ones need to be marked as decorative.
- Colour contrast. Text against its background, and — often missed — interface elements and focus indicators.
- Semantic structure. Real headings in order, real lists, real form labels. Visual styling that merely looks like a heading fails.
- Forms. Labels programmatically associated with fields, errors identified in text rather than colour alone.
- Media. Captions for recorded video, and transcripts where relevant.
- Documents. PDFs and other documents published on the site are in scope. Frequently the largest single problem.
A self-assessment you can run today
None of this requires a tool or a consultant, and it will find most of what matters in under an hour.
- Unplug the mouse. Navigate your main pages, complete a form and submit it using only Tab, Shift-Tab, Enter and the arrow keys. Note anywhere focus disappears or you get trapped.
- Look for the focus indicator. As you tab, can you always see where you are? Removed focus outlines are extremely common and a straightforward failure.
- Zoom to 200 percent. Does anything overlap, get cut off, or become unusable?
- Check one form's errors. Submit it wrong. Is the error described in text, near the field, and does it say how to fix it?
- Open your three most-downloaded PDFs. Can you select the text? If not, they're images and they're inaccessible.
- Run an automated scan — but treat it as a first pass. Automated tools catch roughly a third of issues and produce false positives. Anyone selling full compliance from a scan is overstating it.
If the keyboard test fails, stop assessing and fix that first. It's the single largest source of genuine barriers and it usually indicates issues throughout.
The documents problem
Documents are routinely the largest part of the work and the part scoped last. A back-catalogue of annual reports, forms, price lists and specification sheets can exceed the website itself in remediation effort.
Two things reduce it substantially. First, decide what actually needs to remain published — a great deal of what sits on organisational websites has no current purpose. Second, replace documents with web pages where possible; an accessible HTML page is cheaper to produce and easier to keep accessible than a remediated PDF.
Why it lapses, and what prevents it
Most organisations that come to us have been compliant before. Compliance was achieved as a project, signed off, and then content kept being published by people with no training in what breaks it. Within two years the next audit finds most of the same issues.
What prevents it is unglamorous and cheap relative to remediation:
- Train the people who publish. Four people understanding alt text, heading structure and link text prevents more issues than any remediation sprint fixes.
- Put a check in the publishing process rather than relying on memory.
- Re-test periodically rather than waiting for a complaint or a deadline.
- Make it someone's explicit responsibility. Shared responsibility for accessibility reliably becomes nobody's.
This is also why accessibility is included in continuous web management rather than sold as a one-off. Achieved once and then unowned, it degrades exactly like performance and security do.
