Who do the AODA website rules apply to?

Two different thresholds

The thresholds get confused constantly because there are two of them. Fifty or more employees in Ontario triggers the requirement to conform to WCAG 2.0 Level AA on public websites and on web content published after January 1, 2012. Twenty or more employees triggers a separate obligation to file an accessibility compliance report with the province, on a three-year cycle.

Ontario counts full-time, part-time, and seasonal employees and contract workers, at the peak of the past twelve months, and leaves out outside contractors. A business with thirty employees therefore files a report but has no WCAG obligation for its site. That surprises people in both directions.

What applies at any size

Every organisation with at least one employee in Ontario has some duties under the regulation, including providing information in accessible formats on request and making its feedback process accessible. Those apply regardless of headcount, and they are the ones small businesses most often do not know about.

Why the threshold is the wrong thing to plan around

More than one in four people in Ontario aged fifteen and over reported a disability in Statistics Canada's 2022 survey, and the share rises with age. A site that fails contrast or cannot be operated by keyboard is turning away customers whether or not the regulation names the business. Human rights complaints about inaccessible services are also not bounded by the fifty-employee line.