Data Function

Websites & accessibility

AODA website compliance in 2026: what WCAG 2.0 AA actually requires, and how to check

A practical checklist for Ontario organizations: who the AODA web rules apply to, the WCAG 2.0 Level AA requirements that fail most often, how to test with free tools, and what to put in an accessibility statement.

Dawood Cheema, Founder & CEO, Data Function(updated October 19, 2026)8 min read

The Accessibility for Ontarians with Disabilities Act's Integrated Accessibility Standards Regulation requires public websites and web content of designated public-sector organizations, and of private and non-profit organizations with 50 or more employees, to conform to WCAG 2.0 Level AA (with limited exceptions for live captions and audio description). The rule has been fully in force since January 2021. This checklist covers the failures we see most often and how to find them yourself.

The failures that account for most problems

  • No visible keyboard focus. Tab through your homepage; if you cannot see where you are, that is a failure of 2.4.7.
  • Missing or wrong heading structure. Pages with no H1, or with styled text instead of headings, fail 1.3.1 and make screen-reader navigation painful.
  • Images of text, especially in carousels. Text baked into slides cannot be read by assistive technology, resized or translated.
  • Links and buttons without an accessible name, typically icon-only social links and search buttons.
  • Form fields without programmatic labels, and error messages that are not announced.
  • Colour contrast below 4.5:1 for body text and 3:1 for large text.
  • Pinch-zoom disabled with a maximum-scale viewport setting.

How to check with free tools

  1. Run Lighthouse in Chrome DevTools on five key pages. Any accessibility score below 100 means at least one detectable failure.
  2. Run the axe DevTools browser extension and fix every critical and serious issue.
  3. Put the mouse away and complete your three most important tasks with the keyboard only.
  4. Turn on a screen reader (NVDA on Windows is free; VoiceOver is built into macOS and iOS) and listen to your homepage.
  5. Zoom to 200% and view at a 320-pixel-wide window; nothing should overlap or require horizontal scrolling.

Automated tools find about a third of the problems

A clean axe report is necessary but not sufficient. Reading order, meaningful alt text, focus management in dialogs and menus, and whether error messages actually help all need a person. Build manual checks into every release rather than auditing once a year.

What an accessibility statement should say

  • The standard you target (we recommend WCAG 2.1 AA, which exceeds the AODA requirement).
  • How the site was tested and when.
  • Known limitations and the plan to fix them.
  • How to request content in an alternative format and how to report a barrier, with a response time.

We build every website to WCAG 2.1 AA, test it with axe and by hand, and can supply an accessibility statement and conformance summary at launch. If you would like us to audit an existing site, book a free consultation.

Sources

  1. Integrated Accessibility Standards, O. Reg. 191/11 (Ontario e-Laws)
  2. How to make websites accessible (Government of Ontario)
  3. Web Content Accessibility Guidelines (WCAG) 2.0 (W3C)
  4. Web Content Accessibility Guidelines (WCAG) 2.1 (W3C)

Checked October 19, 2026. Plans, terms and regional availability change, so confirm with the provider before relying on them.

  • AODA
  • WCAG
  • Accessibility
  • Ontario
  • Checklist
Portrait of Dawood Cheema

Dawood Cheema

Founder & CEO, Data Function. Leads architecture and delivery on every Data Function project.

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