AODA and accessible documents: what Ontario organizations do

Where the rules come from

The requirements on this page come from the Information and Communications Standards, which are part of the Integrated Accessibility Standards Regulation (O. Reg. 191/11) under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). Ontario.ca publishes plain-language guidance on each requirement; the regulation's text on e-Laws is the official version.

Every organization: accessible formats on request

Ontario's guidance lists this among the requirements for organizations of every size. In practice:

• Say that you do it. Let the public and your employees know that written information and other communications are available in accessible formats on request: a note on your website or promotional material, a sign, or a bulletin board notice.
• Work with the person. When someone asks, work with them to figure out how to meet their needs.
• Respond in a timely manner. You do not need accessible versions of everything on hand, but you respond in a timely manner that takes the person's accessibility needs into account.
• No extra charge. You cannot charge more for an accessible format than for other formats.
• Unconvertible information. If something cannot technically be converted, explain why and provide a short summary instead. Ontario gives blueprints, maps and complex financial spreadsheets as examples of visual documents that may not convert without losing essential information.

Ontario's guidance points to HTML and structured Microsoft Word files (with heading styles that screen readers can use) as formats that work well. A properly tagged PDF can serve many screen reader users too; an untagged one serves them poorly. See what an untagged PDF means.

Public websites: WCAG 2.0 Level AA

Two groups must make their public websites and web content accessible:

• designated public sector organizations (Ontario's examples include municipalities, school boards, hospitals, colleges and universities, and public transportation);
• businesses and non-profit organizations with 50 or more employees.

Since 1 January 2021, web content posted after 1 January 2012 must meet WCAG 2.0 Level AA, except success criteria 1.2.4 (live captions) and 1.2.5 (pre-recorded audio description). Ontario defines content as "any information that may be found on a web page or web application", including text, images, forms and sounds. A few details from Ontario's guidance matter for documents:

• A document counts as published when "it is finalized and distributed to its intended audience". Documents published before 1 January 2012 do not have to meet WCAG 2.0 A/AA; Ontario's example is bylaws posted in 2009.
• Intranets and extranets do not have to meet WCAG 2.0 A/AA (the Government of Ontario and the Legislative Assembly are held to more), but if someone asks for intranet content in another format, you work with them.
• Websites and content you do not control, directly or through a contract, are outside the requirement.
• Businesses and non-profits with fewer than 50 employees are encouraged, not required, to follow the website requirements.

Ontario's guidance does not mention PDFs by name. Whether a particular posted document is in scope is a question for your accessibility lead.

The 2026 accessibility compliance report

Businesses and non-profits with 20 or more employees file an accessibility compliance report every three years. The current one is due on 31 December 2026. Designated public sector organizations file every two years; their last report was due on 31 December 2025, and Ontario asks those that missed it to file it still.

Filing is online, through Ontario's Accessibility Compliance Reporting Portal: create an account, choose "New Submission" and then "Accessibility Compliance Report". Ontario lists what to have ready: the organization's legal name, its business number (the BN9 from your tax return), the number of employees and the certifier's contact details. If you need the form in another format, Ontario's page gives [email protected].

For the full list of Canadian and other deadlines, see our deadlines page.

What this looks like for a document library

1. Post the accessible-formats notice and decide who handles requests.
2. If your organization is covered by the website requirement, list the documents posted since 2012 that people still use: forms, policies, plans, agendas, reports.
3. Publish new documents in an accessible form from the start; a Word file with real heading styles, exported as a tagged PDF, goes a long way.
4. Repair the documents in use, then check them. How to check a PDF covers the free tools; remediating many PDFs covers large libraries.

Sources

• Ontario.ca: How to make information accessible
• Ontario.ca: How to make websites accessible
• Ontario.ca: When public websites are not accessible
• Ontario.ca: Accessibility rules for businesses and non-profits
• Ontario.ca: Accessibility rules for public sector organizations
• Ontario.ca: Completing your accessibility compliance report
• Ontario.ca: Review of the Information and Communications Standards (2019 recommendations, for where the standards sit)
• O. Reg. 191/11: Integrated Accessibility Standards (e-Laws)