How to talk to your clients about AODA compliance
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Written by:
accessiBe Team
- Last update on
The Accessibility for Ontarians with Disabilities Act (AODA) is the law behind the December 31, 2026 filing deadline your clients may be facing. If you build, manage, or advise on websites for Ontario businesses, understanding what it requires — and how to bring it up — puts you ahead of a conversation your clients will need to have either way.
- Know whether the December 31 deadline applies to a given client
- Open the topic without sounding like you're issuing a compliance warning
- Answer the objections clients actually raise
- Point to the right accessiBe layer for where a client actually stands
- Turn this into a standing service through the partner program
1. Why this conversation matters right now
Ontario’s Accessibility Compliance Report is due December 31, 2026, for private and non-profit organizations with 20 or more employees. It’s a mandatory, self-reported filing confirming where an organization stands on its AODA obligations, covering all five AODA standards, with WCAG 2.0 Level AA as the specific standard for web content.
Private and non-profit organizations with 20 or more employees must file by December 31, 2026, on a three-year cycle. Organizations with 50 or more employees carry additional obligations: a written multi-year accessibility plan and WCAG 2.0 AA conformance evidence for required public content. Missed or unsupported filings become part of an organization’s compliance history, and penalties can reach up to $100,000 per day for corporations.
If you build, manage, or advise on websites for Ontario businesses, this deadline applies to some portion of your client roster whether or not anyone has raised it yet.
2. Spotting which clients are affected
Whether the deadline applies to a client comes down to headcount and sector:
| Client situation | Deadline applies? |
|---|---|
| Private/non-profit, 20+ employees, Ontario | Yes — file by Dec 31, 2026 |
| Fewer than 20 employees | Generally not required |
| Designated public sector | Separate cycle — last due 2025 |
| 50+ employees | Yes, plus written plan + WCAG evidence |
What needs to be ready before filing depends on size:
- 50 or more employees: written accessibility policies, a multi-year plan, and WCAG 2.0 AA conformance evidence.
- 20–49 employees: policies in place, but they don’t have to be written or published, and the WCAG requirement generally doesn’t apply.
3. How the report actually gets filed
Filing happens through Ontario’s Accessibility Compliance Reporting Portal, which replaced the old PDF-based process. In short: an organization signs in, enters its legal name and employee count, answers compliance questions based on its size and sector, and has a senior officer or authorized signer certify the report before submission.
What needs to be ready before filing depends on size. Organizations with 50 or more employees need written accessibility policies, a multi-year plan, and WCAG 2.0 AA conformance evidence. Organizations with 20–49 employees need policies in place, but they don’t have to be written or published, and the WCAG requirement generally doesn’t apply.
The filing process has more steps than fit here — portal registration, certifier requirements, what happens after submission. Our guide – How to file your AODA accessibility compliance report – walks through it step by step.
4. Talking to your client about AODA and the upcoming deadline
Once you know a client falls into scope, the actual conversation doesn’t need to be complicated. One approach worth considering: lead with the deadline itself rather than a technical standard — something like “there’s a filing requirement coming up December 31 that might apply to you, want me to check?” keeps the opener concrete and low-stakes, and positions the check as something you’re doing proactively on their behalf rather than pointing out something they’ve missed.
From there, a handful of questions do most of the work of figuring out where they actually stand:
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Do you know where your website stands against WCAG 2.0 AA?
Most clients haven’t checked this directly, which is often the moment the conversation moves from “does this apply to me” to “what do I actually do about it.”
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Have you filed a report before?
Returning filers may already have documentation or a plan started; new filers are starting from zero, which changes the timeline you’re working with.
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Who owns this internally?
Marketing, IT, and legal often all have a stake but no single owner — identifying who signs off shortens the path from conversation to decision.
Whatever their answers, you’ll usually land in one of two places: a client who’s ready to move, or one who’s going to push back before they do, which is what the next section covers.
5. Objections you might hear
Some clients will push back before they commit, usually with one of a few predictable lines. Here’s how to answer each, grounded in what the AODA report actually asks for, not assumptions about why someone might be hesitant.
Digital accessibility regulation: a timeline
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“We’ve never been sued, so we’re probably fine.”
Litigation history isn’t part of what the report asks. It’s a standalone filing obligation regardless of past legal exposure.
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“Our developer already said the site is fine.”
WCAG 2.0 AA conformance covers things like screen reader compatibility and keyboard navigation, which are hard to verify without dedicated testing.
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WCAG 2.1 published — adds mobile and cognitive criteria
WCAG 2.1 adds 17 new success criteria covering mobile accessibility, low vision, and cognitive accessibility. Becomes the baseline standard for most US and European accessibility requirements.
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“Can’t we just wait and see?”
Missed or unsupported filings become part of an organization’s compliance history, and penalties can reach up to $100,000 per day for corporations.
6. What you can offer as an accessiBe Partner
Once a client’s ready to move, the accessiBe platform gives you a real offering to bring them, not just a warning about a deadline:
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ACCESSERVICES
Expert accessibility audits In-depth reviews of your site – including by people with disabilities
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ACCESSWIDGET
AI-powered remediation Real-time, session-based fixes to align your website with the Web Content Accessibility Guidelines (WCAG)
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ACCESSFLOW
Source code accessibility Enable your dev team fix issues at source code level, directly in your IDE
Every product and service above can be referred or resold. As a referral partner, you earn a commission when a client you bring signs up. As a reseller, you sell and manage the relationship directly at a partner discount. Either way, you’re not just flagging a deadline — you’re the one who closes the gap. Commission structures, tiers, and reseller terms vary, so the fastest way to see what applies to you is to talk it through directly.
Help your clients prepare for the AODA compliance deadline
Talk to a partner manager about commissions, tiers, and how to get set up.
Frequently asked questions
What is the AODA?
The Accessibility for Ontarians with Disabilities Act (AODA) is an Ontario law that sets accessibility standards for businesses, nonprofits, and public sector organizations, covering customer service, employment, and information and communications, including websites.
Who needs to file an AODA compliance report?
Private and non-profit organizations with 20 or more employees must file by December 31, 2026, on a three-year cycle. Designated public sector organizations file on a separate two-year cycle; their most recent deadline was December 31, 2025.
Does the WCAG 2.0 AA requirement apply to every business that has to file?
No. Organizations with 50 or more employees need WCAG 2.0 AA conformance evidence for required public content, along with a written multi-year plan. Organizations with 20–49 employees need accessibility policies in place, but the WCAG requirement generally doesn’t apply to them.
How is the report actually filed?
Through Ontario’s Accessibility Compliance Reporting Portal. An organization signs in, enters its legal name and employee count, answers compliance questions based on size and sector, and has a senior officer or authorized signer certify the report before submission.
What happens if a client misses the deadline?
Missing the deadline can trigger enforcement action. Penalties can reach up to $100,000 per day for corporations and $50,000 per day for directors or officers personally, though these are legal ceilings, not routine outcomes. Missed or unsupported filings also become part of an organization’s compliance history.
Is the compliance report the same as an accessibility audit?
No. The report is a self-reported filing — no one from the province reviews a site before it’s submitted. An organization confirms and submits its own compliance status, which is different from a formal audit that independently verifies where a site actually stands.
