Accessibility Standards for Websites and Web Content of Large Employers
November 2020 Charity & NFP Law Update
Published on November 26, 2020

By  Luis R. Chacin


By January 1, 2021, pursuant to subsection 14(4) of the Integrated Accessibility Standards (O Reg 191/11) under the Accessibility for Ontarians with Disabilities Act, 2005, designated public sector organizations as well as organizations, including charities and not-for-profits, with 50 or more employees in Ontario, must make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines 2.0 (“WCAG 2.0 Guidelines”), Level AA, except with regard to success criteria 1.2.4 (regarding the use of captions for all live audio content in synchronized media), and 1.2.5 (regarding the use of audio description for all pre-recorded video content in synchronized media). Since January 1, 2014, designated public sector organizations and organizations with 50 or more employees in Ontario are already required to comply with WCAG 2.0 Guidelines, Level A, with regard to any new internet websites such as a website with a new domain name or a website with an existing domain name undergoing a significant refresh, as well as web content on those sites.

It is important to note that, according with subsections 14(5) and (6) of the Integrated Accessibility Standards, this obligation to conform with WCAG 2.0 Guidelines, Level AA by January 1, 2021 applies to websites and web content, including web-based applications, that an organization controls directly or through a contractual relationship that allows for modification of the product, as well as to web content published on a website after January 1, 2012, except where meeting the requirement is not practicable.

The Ontario government has also provided a guidance on “How to make websites accessible: How to make new or significantly updated websites accessible for people with disabilities”, which at the time of writing was last updated on October 19, 2020, including general information regarding who must comply with WCAG 2.0 Guidelines, how to comply and what to do if compliance is not practicable, as well as tips for testing websites for accessibility and for working with web developers.

Charities and not-for-profits with 50 or more employees in Ontario should review their websites for compliance with the Integrated Accessibility Standards and engage web developers under a service provider agreement, as appropriate.


Read the November 2020 Charity & NFP Law Update