AODA/WCAG Reality Check: What Ontario Businesses Still Get Wrong

July 25, 2025

Ontario promised a “barrier‑free” province by January 1, 2025. Yet many websites are still tripping over the same avoidable accessibility mistakes—often because teams think they “passed a scan once” or assume the rules don’t apply to them. Meanwhile, fines can hit $100,000 per day, and the next compliance report deadline is already on the calendar. Let’s cut through the noise and look at what the law actually says, where organizations still stumble, and how to fix the most common problems without blowing your budget.

The Rules in 60 Seconds

Since Jan 1, 2021, public websites and web content posted after Jan 1, 2012 must meet WCAG 2.0 Level AA (live captions and audio description are the only exceptions).
Compliance reports: Private and non‑profit orgs with 20+ employees file every three years; the last deadline was Dec 31, 2023; next is Dec 31, 2026.
Penalties: Up to $100,000/day for corporations and $50,000/day for individuals/directors.
Standards evolve: WCAG 2.2 (2023) adds new AA criteria like Target Size (Minimum) and Dragging Movements. AODA still references 2.0, but “future‑proofing” with 2.1/2.2 is smart.
Accessibility is widespread need: 27% of Canadians (8 million) report a disability; in Ontario it’s roughly 1 in 7—and rising.

Seven Painfully Common Mistakes (and How to Fix Them for Cheap)

“We ran an automated scan, so we’re done.” Automated tools catch maybe 30–40% of WCAG failures. They can’t tell if your alt text is meaningful or if a modal traps keyboard focus. Use them for triage, but always add quick manual checks: tab through pages, try a screen reader for five minutes, resize text to 200%.
Low Contrast Text (a.k.a. #AAAAAA on #FFFFFF Isn’t “Fine”) WCAG 2.0/2.1 requires a minimum 4.5:1 contrast ratio for normal text (3:1 for large/bold). Designers often miss this on buttons, placeholder text, or over hero images. Free fix: run a contrast checker and adjust colours in your design tokens once—then reuse everywhere.
No Visible Keyboard Focus If you hit TAB and can’t see where you are, you’re failing WCAG. Browsers give you a default focus ring; CSS resets often wipe it out. Reinstate it with a thick outline or underline that meets contrast requirements. This becomes even more important with WCAG 2.2’s focus‑related criteria.
“Skip to Main Content” Links Are Missing Keyboard and screen reader users shouldn’t have to slog through giant navs on every page. A simple skip link (visually hidden until focused) satisfies WCAG’s “bypass blocks” requirement and takes minutes to add.
Forms Without Proper Labels or Instructions WCAG 3.3.2 says every input needs a clear label or instructions. Place labels adjacent to fields, associate them with for/id, explain formats (YYYY‑MM‑DD), and ensure error messages are programmatically tied to fields. Cheap fix: audit your forms once and bake patterns into your component library.
Untagged, Unfixable PDFs Dumping a scanned, untagged PDF on your site is an accessibility black hole. “Accessible PDF” essentially means “tagged PDF”—headings, lists, reading order. Acrobat Pro and other tools can auto‑tag; you just need someone to verify and tweak. Better yet: publish HTML first, PDF second.
Video Without Captions or Transcripts WCAG 2.0 AA requires captions for prerecorded video and text alternatives for audio‑only content; descriptive transcripts ensure Deaf‑blind users aren’t locked out. YouTube’s auto‑captions are a start—then edit for accuracy. Transcripts cost pennies per minute with modern tools.

WCAG 2.2: The “Nudges” You’ll Wish You’d Built Now

Eight new success criteria landed with WCAG 2.2. Two matter immediately for most sites: Target Size (Minimum) (2.5.8) to make tappable areas at least 24×24 CSS pixels, and Dragging Movements (2.5.7) so actions don’t rely solely on drag‑and‑drop. If you redesign your buttons and draggable widgets now, you won’t be scrambling later.

The Cheap Fix Kit

Here’s a punch list you can hand to your dev/designer today—none of these require a six‑figure budget:

Add or restore keyboard focus styles in your global CSS (outline, border, underline).
Run a contrast sweep; adjust HEX values in your design tokens once.
Insert a “Skip to main content” link as the first focusable element.
Audit forms: ensure every <input> has a programmatic label and clear error messaging.
Caption your top 10 traffic videos; publish transcripts alongside.
Tag legacy PDFs or replace them with HTML; use Acrobat’s auto‑tag then fix reading order.
Remove drag‑only interactions; add click/tap alternatives.

Reporting Isn’t the Finish Line

Filing the ministry’s form every three years is table stakes, not a victory lap. Treat accessibility like security: continuous monitoring, regression checks when you ship features, and spot audits of PDFs, videos, and forms before they go live. That mindset is what AODA’s reporting cadence is trying to force.

Quick Monday Morning Checklist

Pick three representative pages (home, key service/product page, a form). Tab through them. Note every hiccup.
Run axe or WAVE; export the report and sort issues by “low effort/high impact.”
Fix color contrast and focus first—they help everyone and are fast to ship.
Caption your highest-traffic video; publish a transcript next to it.
Schedule a PDF cleanup day—tag the top five downloads.
Drop a calendar reminder for your 2026 report now, and assign an internal owner.

Final Thought

You don’t need a 200‑page audit to make meaningful progress. Most Ontario businesses are a handful of CSS tweaks, captions, and tagged PDFs away from eliminating their biggest risks—and making their sites genuinely better for a huge slice of their audience. Do the small stuff now, build the bigger fixes into your roadmap, and you won’t be sweating the next compliance deadline (or that call from the Ministry).

References & Further Reading

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