In Ontario, WCAG 2.0 AA is a legal deadline you missed

The claim

Accessibility is filed under "nice to have" in most Ontario businesses' backlogs. It has not been optional since January 1st, 2021. Under the Integrated Accessibility Standards Regulation of the AODA, designated public sector organisations and private organisations with 50 or more employees must make their public websites and web content conform to WCAG 2.0 Level AA, with narrow exceptions for live captioning and pre-recorded audio description. The deadline has passed. Most sites do not conform.

What conformance actually requires

The regulation applies to internet websites and web content published after January 1st, 2012, which in practice means everything you currently serve. The good news is that a large share of typical failures come from a small number of causes, and they are cheap to fix.

Find your failures in twenty minutes

Automated tools catch roughly a third of issues — not all of them, but a third is a real start and it costs nothing:

npx @axe-core/cli https://example.ca --exit
npx @axe-core/cli https://example.ca/products https://example.ca/contact

Then do the two manual checks that find most of what tooling misses:

1. Unplug the mouse. Tab through a complete task — find a product, add it to the cart, check out. Watch for the focus indicator. If you cannot see where you are, or if focus disappears into a modal you cannot escape, that is a failure with real consequences for real users.
2. Zoom to 200%. Content must remain readable and functional. Horizontal scrolling and overlapping text are common and immediately visible.

The five failures we find most often

• Contrast below 4.5:1 on body text. Usually light grey on white, chosen because it looked elegant in the design file. Fixing it is a variable change.
• Form inputs with no programmatic label. A placeholder is not a label — it disappears on focus and screen readers may not announce it.

  <label for="email">Email address</label>
  <input id="email" name="email" type="email" autocomplete="email">

• Images with empty or decorative alt text carrying real meaning. A product photograph with alt="" tells a screen reader user nothing about what they are buying.
• Divs used as buttons. A div with a click handler is not reachable by keyboard and is not announced as a control. Using a real button element solves several failures at once.
• Missing or invisible focus styles. Someone removed the browser's default outline because it looked untidy and replaced it with nothing.

What automated tools cannot tell you

A clean axe report is not conformance. Tooling can verify that an image has alt text; it cannot verify that the alt text is useful, and alt="image1.jpg" passes the check while helping nobody. The same applies to heading structure, link text, and error messages: a page can pass every automated rule while being incomprehensible in a screen reader. Treat the automated pass as the floor you clear before the real review begins, not as the result.

The compliance obligation beyond the code

Organisations with 20 or more employees must file an accessibility compliance report with the province, and the requirement to have a multi-year accessibility plan is separate from the technical conformance itself. Meeting WCAG on the website does not discharge the reporting obligation, and filing the report does not make a non-conforming site conforming. They are two separate things and businesses routinely do one and assume it covers the other.

The argument that does not depend on the law

Roughly one in five Canadians reports a disability, and the proportion rises sharply with age. Every fix above also helps people with a broken arm, a cracked phone screen, a bright sunlit patio, or a slow connection. Semantic markup and real labels improve how assistive technology, search crawlers, and autofill all interpret your pages — the same accessible form is the one that fills itself in correctly on a phone.

Where to start on Monday

Run axe against your five highest-traffic pages. Fix contrast and form labels first, since they are usually a day of work combined and they account for a large share of automated findings. Then tab through your checkout without a mouse and fix whatever stops you. Book a review with someone who uses a screen reader daily for anything past that — a two-hour session with an experienced tester finds more than a week of internal guessing, and the findings arrive as a specific list rather than an anxiety.