Accessibility guide for Ontario stores
AODA website compliance: what Ontario online stores must do
Guide summary
- Author:
- Misha Gavura
- Technical review:
- Stanislav
- Published:
- Last reviewed:
- October 16, 2026
- Reading time:
- 9 min
- Summary
- Who AODA’s website rule covers, what WCAG 2.0 AA means for a Shopify store, how to file the December 31, 2026 accessibility compliance report, what the penalties really are, and a 10-point checklist.
In this article · 9 sections
Short answer
Under Ontario's AODA (O. Reg. 191/11, s.14), organizations with 50 or more employees in Ontario must make their public websites meet WCAG 2.0 Level AA, except live captions and pre-recorded audio description. Separately, businesses and non-profits with 20 or more employees must file an accessibility compliance report by December 31, 2026 through Ontario's Accessibility Compliance Reporting Portal.
Who wrote and checked this guide
- Written by
- Misha GavuraCo-founder, Growth & Technology
- Technical review by
- StanislavLead Developer
- Last reviewed
EVDEV is a Shopify development agency, not a law firm. This page is general information, not legal advice. If you've received a demand letter or lawsuit, consult an attorney.
Who does AODA's website rule apply to?
Since January 1, 2021, AODA's website rule has covered two groups: the public sector, and organizations with 50 or more employees in Ontario, according to Ontario's guide to accessible websites. The compliance report starts lower, at 20 employees.
| Organization | Website rule (WCAG 2.0 AA) | Compliance report (businesses and non-profits) |
|---|---|---|
| 1–19 employees | Not required | Not required |
| 20–49 employees | Not required | Every 3 years; next due December 31, 2026 |
| 50+ employees | Required for public websites since January 1, 2021 | Every 3 years; next due December 31, 2026 |
| Public sector | Required since January 1, 2021 | Separate public sector rules (see ontario.ca) |
Sources: How to make websites accessible; Accessibility rules for businesses and non-profits; Completing your accessibility compliance report.
What does an AODA-compliant website need?
An AODA-compliant website meets the WCAG 2.0 Level AA success criteria, with two exceptions: 1.2.4 (live captions) and 1.2.5 (pre-recorded audio description), under O. Reg. 191/11, s.14. WCAG is the W3C's web accessibility standard. Level AA covers things like text contrast, keyboard access, form labels, alt text and video captions.
- Which content. The rule applies to websites and web content published after January 1, 2012 (ontario.ca). Older content is out of scope.
- Which sites. The organization that controls the site "either directly or through a contractual relationship" must meet the requirements (ontario.ca).
- Your theme and your apps count. Product pages, the cart drawer, filters, popups and review widgets are all part of your public website.
- Shopify's checkout is not a free pass. Shopify's own checkout conformance report (March 2026) lists 13 WCAG criteria as "Partially Supports" and says merchants are responsible for assessing their online store.
The December 31, 2026 accessibility compliance report
Ontario businesses and non-profits with 20 or more employees must file an accessibility compliance report every three years. The next one is due December 31, 2026, according to Ontario's filing guide. It covers all AODA standards, not only your website.
How to file in the portal
- Open the Accessibility Compliance Reporting Portal from Ontario's filing guide.
- Select "New Submission", then choose "Accessibility Compliance Report".
- Answer the questions for every AODA standard that applies to you, not only the website rule.
The report asks about the 5 AODA standards: customer service, information and communications, transportation, employment, and design of public spaces. The website rule sits inside information and communications. Ontario's filing guide walks through the rest of the process.
What EVDEV does and doesn’t do here. We test and fix the website part. We don’t file your report, we don’t sign it, and we don’t certify anything. Your report is your organization’s statement.
What are the AODA penalties?
On conviction, the AODA (s.37) allows fines of up to $50,000 a day for individuals and directors and up to $100,000 a day for corporations. Those are ceilings a court can impose, not standard fines.
Ontario can also issue administrative penalties under O. Reg. 191/11 (s.83). Those reach the daily maximum only when both the impact of the contravention and the organization's history are rated "major". "$100,000 a day" is the top of the scale, not what a typical store faces.
Does AODA apply to a Shopify store outside Ontario that sells into Ontario?
Possibly, but nobody can answer it for you from a web page. The regulation is written for organizations that provide goods or services in Ontario and counts Ontario employees (O. Reg. 191/11).
If your team is outside Ontario and you sell to Ontario customers, ask a lawyer whether you are covered. Whatever the answer, testing your store against WCAG reduces risk in every market you sell to, including the US.
AODA vs. ADA vs. Accessible Canada Act
A Canadian store that sells into the US can face three different regimes. They differ in who they cover, which standard they name, and how they are enforced.
| Law | Who it covers | Web standard | Deadline | Penalties |
|---|---|---|---|---|
| AODA (Ontario) | Ontario public sector; businesses and non-profits with 50+ employees (website rule) | WCAG 2.0 AA, except 1.2.4 and 1.2.5 | In force since January 1, 2021; compliance report due December 31, 2026 (20+ employees) | Up to $100,000/day for corporations and $50,000/day for individuals, on conviction |
| ADA Title III (United States) | Businesses open to the public; federal courts are split on websites, and the 9th Circuit requires a link to a physical place | No DOJ web regulation; DOJ guidance (March 18, 2022) calls WCAG and Section 508 "helpful guidance" | None set for private businesses | Private plaintiffs get injunctive relief and attorneys’ fees, not damages; state laws such as California’s Unruh Act add a minimum of $4,000 per offense |
| Accessible Canada Act digital rules (federal) | Federal public sector and federally regulated businesses (banks, telecom, transport) with 100+ staff; not typical Shopify stores | CAN/ASC-EN 301 549 | December 5, 2027 (federal public sector); December 5, 2028 (federally regulated businesses) | $250 to $75,000 |
AODA website checklist for Shopify
These 10 checks cover common WCAG 2.0 AA problems on Shopify themes. They are a starting point, not a full audit. Deque's axe found 57% of issues by count in Deque's own audits (Deque, 2021), so automated scans alone miss a lot. Test by hand too.
- Alt text on product and content images (1.1.1)Describe what the image shows. Decorative images get empty alt text.
- Text contrast of 4.5:1 (1.4.3)Check sale badges, placeholder text, buttons over images and light grey body copy.
- Everything works with a keyboard (2.1.1)Menus, variant pickers, filters, quantity steppers, the cart drawer and popups.
- No keyboard traps (2.1.2)A visitor can tab into and out of the cart drawer, search and newsletter popups.
- Visible focus (2.4.7)Every link and button shows where keyboard focus is.
- Labels and clear errors on forms (3.3.1, 3.3.2)Contact, newsletter, account and gift-card forms name every field and explain errors in text.
- Captions on pre-recorded video (1.2.2)Product and brand videos with speech need captions. Live captions are exempt under AODA.
- Page titles and heading order (2.4.2, 1.3.1)One H1 per page and headings that follow the structure of the content.
- Text resizes to 200% (1.4.4)Zoom the store to 200% and check that nothing is cut off or overlaps.
- Custom widgets announce their name, role and state (4.1.2)Swatches, sliders, accordions and app widgets must work with a screen reader.
WCAG 2.2 added 4 new AA criteria, including a 24×24px minimum target size. AODA doesn't require them, but they help mobile shoppers.
Common AODA myths, corrected
- "AODA requires WCAG 2.1 or 2.2."
- The legal standard is WCAG 2.0 Level AA (ontario.ca). Meeting 2.1 or 2.2 is fine and covers more, but it isn't the minimum.
- "AODA's website rule applies to every Ontario business."
- It applies to the public sector and to organizations with 50 or more employees in Ontario (ontario.ca).
- "AODA fines are $100,000 a day."
- That is the maximum for a corporation on conviction (AODA, s.37), not a standard fine.
- "The Accessible Canada Act covers all Canadian ecommerce."
- Its digital rules cover federally regulated sectors such as banks, telecom and transport, not typical Shopify stores (canada.ca).
- "An accessibility overlay makes my site compliant."
- EcomBack counted 496 US website lawsuits (24.25%) in the first half of 2026 against sites that already had a widget installed (EcomBack). In 2025 the FTC ordered accessiBe to pay $1 million and barred it from claiming its automated products can make a site WCAG-compliant without evidence.
AODA website compliance FAQ
What makes a website AODA compliant?
It meets the WCAG 2.0 Level AA success criteria, except 1.2.4 (live captions) and 1.2.5 (pre-recorded audio description), for web content published after January 1, 2012 (ontario.ca).
What are the 5 AODA standards?
Customer service, information and communications, transportation, employment, and design of public spaces (ontario.ca). Website accessibility is part of the information and communications standard.
Does WCAG 2.1 or 2.2 satisfy AODA?
Yes. WCAG 2.1 and 2.2 build on 2.0, so a site that meets 2.2 AA also covers the 2.0 AA criteria AODA names. The legal minimum is still WCAG 2.0 AA.
Is there an AODA certificate for websites?
No. Ontario doesn't issue an official AODA certificate for websites. An “AODA certified” badge is a vendor's own label.
Do I need to file a compliance report if I have 20–49 employees?
Yes. Businesses and non-profits with 20 or more employees file every three years, and the next report is due December 31, 2026 (ontario.ca). The website rule itself starts at 50 employees.
Page accessibility tested with axe-core against WCAG 2.2 AA rules on 16 October 2026, with known limitations.
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