2026 is an AODA reporting year — and your website is part of what you're signing

If you run an Ontario organization with 20 or more employees, there's a filing deadline on your calendar whether you've noticed it or not: December 31, 2026. Accessibility compliance reports are filed every three years, and 2026 is a reporting year.

For organizations with 50 or more employees, part of what you file is a confirmation that your public website and web content conform to WCAG 2.0 Level AA.

That's the part that catches people out. The report is quick. The thing you're confirming may not be true.

The website requirement isn't new

The deadline for WCAG 2.0 Level AA conformance was January 1, 2021 — for public sector organizations of any size, and for private and non-profit organizations with 50 or more employees. It has been in force for years.

What 2026 adds isn't a new standard. It's a moment where you have to put your name to it.

What non-compliance can actually cost

Under the AODA, penalties can reach up to $100,000 per day for corporations. Directors and officers can face personal liability of up to $50,000 per day.

Those are maximums, not typical outcomes, and enforcement in practice has been lighter than the ceiling suggests. But "we've never been fined" is a different statement from "we're compliant" — and only one of them is what you're attesting to on the form.

The honest problem with self-reporting

The compliance report is self-assessed. Nobody audits your site before you file. Which means there are really only three positions to be in come December:

1. 01 You know you conform Because someone actually tested it — by keyboard and screen reader, not just a scanner. File with confidence.
2. 02 You know you don't Uncomfortable, but workable. You have months, a known list of barriers, and a plan.
3. 03 You have no idea The most common position — and the only genuinely risky one, because you're signing either way.

Most organizations we talk to are in the third position. Not evading anything — they simply were never told the website was in scope, and their developer never raised it.

What "conforms" actually requires

Not a plugin. Not a widget. Not a green score from an automated scan — those catch a minority of real barriers, and we've written separately about the failures scanners routinely miss.

It means a person navigating your key templates with a keyboard alone and reaching everything. A screen reader announcing your forms, buttons, and images meaningfully. Contrast that holds up. Focus you can see.

If you're not sure, there's still time

Four and a half months is comfortable for an audit and remediation on a normal marketing site. It gets tight if you wait until November, and it's genuinely difficult in December — which is when everyone remembers.

The useful move now is simply finding out where you stand, so that whatever you file in December is accurate. See Accessibility Audits & AODA Compliance, or send us your URL and how many templates you have and we'll tell you what an audit would involve.

This is a plain-language summary of a regulatory requirement, not legal advice. For questions about your organization's specific obligations, talk to your legal counsel — and confirm filing details on Ontario's accessibility compliance reporting portal.