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Lunarlink Solutions, Toronto
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Two provinces set a web standard a private business has to meet. Ontario requires WCAG 2.0 Level AA under the AODA for organizations with fifty or more employees. Manitoba requires WCAG 2.1 Level AA under its Accessible Information and Communication Standard, and applies it to any employer with at least one employee.
This is a plain-language summary, not legal advice. Rules change and thresholds get revised, so confirm anything you are relying on against the regulator's own page.
The Accessible Information and Communication Standard reached private businesses and non-profits on 1 May 2025, and the threshold is one employee rather than Ontario's fifty. It asks for WCAG 2.1 Level AA on newly published web content and on any web content needed to reach the goods and services the business sells.
The practical result is that a five-person shop in Winnipeg carries a web accessibility obligation that the same shop in Toronto does not, and to a newer version of the standard. Almost every accessibility article written for a Canadian audience is about Ontario, which is why this keeps catching Manitoba owners out.
The Accessible British Columbia Act has been in force since 2021 but currently reaches public sector organizations: municipalities, school districts, health authorities, post-secondary institutions, and police boards. Those bodies build accessibility committees, plans, and feedback processes. Standards that would extend to private business are still being developed.
Nova Scotia, Newfoundland and Labrador, and Saskatchewan each have framework legislation with standards in progress, and Quebec has no private-sector web standard at all. In none of those is there a WCAG requirement on an ordinary business today.
The Accessible Canada Act covers banks, telecommunications and broadcasting, airlines, rail, and interprovincial trucking, along with the federal government itself. It requires a published accessibility plan, a feedback process, and progress reports on a set schedule.
The Act does not name a WCAG level the way the provincial standards do, but WCAG Level AA is the benchmark those plans are almost always written against, and a complaint about an inaccessible website is measured against it in practice.
WCAG 2.1 Level AA is the sensible floor everywhere. It satisfies Manitoba, exceeds Ontario, and holds if the business hires across a border or if a province updates its standard, which several are expected to do.
It is also the version of the argument that does not depend on a regulator. Real contrast, keyboard access, labelled form fields, alt text, and captions are the same things that make a site usable on a phone in direct sunlight, by someone driving, or by a customer who is sixty-eight. The legal case is the smaller half of it.
| Jurisdiction | Law | Standard on a private business |
|---|---|---|
| Ontario | AODA, Information and Communications Standard | WCAG 2.0 Level AA, at 50 or more employees |
| Manitoba | Accessible Information and Communication Standard | WCAG 2.1 Level AA, at one or more employees |
| British Columbia | Accessible British Columbia Act | None yet. Public sector organizations only, standards in development |
| Nova Scotia, Newfoundland and Labrador, Saskatchewan | Provincial accessibility acts | None yet. Standards in development |
| Quebec | No private-sector web standard | None. Public bodies follow the province's own SGQRI standards |
| Federally regulated sectors | Accessible Canada Act | An accessibility plan, feedback process, and progress reports rather than a named WCAG level |
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