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Research report Accessibility · Ontario 8 sources cited

The December 2026 deadline.

Every Ontario business and non-profit with 20 or more employees must file an accessibility compliance report by 31 December 2026.[1] In the same year, the largest survey of web accessibility recorded its first reversal in six years.[5]

CometX · September 2026 · Free to reuse under CC BY 4.0

The number that matters

95.9%

of the top one million home pages had detectable WCAG 2 failures in February 2026 — up from 94.8% a year earlier, reversing six consecutive years of small improvements. Because only automatically detectable failures were counted, WebAIM notes the true rate of full conformance is "certainly lower than 4.1%".[5]

What the law actually requires

The Accessibility for Ontarians with Disabilities Act[3] applies to every organization in Ontario with at least one employee, but the filing obligation scales with size. Businesses and non-profits with 20 or more employees file every three years; their next deadline is 31 December 2026. Designated public sector organizations file every two years, and their most recent deadline — 31 December 2025 — has already passed. Ontario is explicit that a missed report must still be filed.[1]

The report is a self-assessment, certified by a senior officer with legal authority to confirm it is complete and accurate.[1] That certification is the part most often underestimated: an organization attesting to conformance it has not verified is making a formal declaration, not filling in a form.

Worth being precise about

The AODA's Information and Communications Standard requires conformance with WCAG 2.0 Level AA, not the current WCAG 2.2.[4] Meeting the newer standard satisfies the older one, so building to 2.2 is the safer course — but an organization that has been told it must meet 2.2 by law in Ontario has been told something the regulation does not say.

Why the filing year is a bad one to be complacent

WebAIM has evaluated the home pages of the top one million websites every year since 2019. The February 2026 sample found 56,114,377 distinct errors — an average of 56.1 per page, up 10.1% in a single year. Home pages averaged 1,437 elements, a 22.5% rise in twelve months, and users with disabilities would expect to encounter an error on one in every 26 page elements.[5]

The same six failure types have topped the list for seven consecutive years and account for 96% of everything detected:[5]

Failure type20252026Direction
Low contrast text79.1%83.9%Worse
Missing alternative text55.5%53.1%Better
Missing form input labels48.2%51%Worse
Empty links45.4%46.3%Worse
Empty buttons29.6%30.6%Worse
Missing document language15.8%13.5%Better

Source: WebAIM Million 2026.[5]

None of these are obscure. Contrast can be checked in any design tool. Alternative text requires a decision about what an image communicates. A form label is one attribute. That they remain the top six after seven years says the barrier is process, not knowledge.

The finding that should worry anyone buying a rebuild

WebAIM found that home pages using ARIA averaged 59.1 errors against 42 on pages using none — roughly 17 additional potential barriers on pages using the very specification intended to improve accessibility. ARIA usage rose 27% in one year and is now more than six times its 2019 level.[5]

WebAIM is careful here, and so are we: this is correlation. Pages using ARIA are also more complex, and complexity brings errors of its own. The report attributes the broader trend to heavier reliance on third-party frameworks and to "automated or AI-assisted coding practices".[5] The practical implication for a procurement decision is narrower and safer: a modern framework does not make a site accessible, and may make it harder.

Where Canadian and non-profit sites actually sit

Two findings in the 2026 data are directly relevant to Ontario organizations. Home pages on .ca domains averaged 36.0 errors, 35.9% below the million-page average of 56.1. Sites categorised as non-profit or charity averaged 43.0 errors, 23.3% below average, second only to government at 42.4.[5]

That is a genuinely better starting position than the web at large — and it is a long way from conformance. Being a quarter better than an average where 95.9% of pages fail is not a defence in a compliance report.

Who this is actually about

In 2022, 27% of Canadians aged 15 and over — 8.0 million people — had one or more disabilities, up five percentage points from 22% in 2017. The increase is not only population ageing: the largest jump was in mental health-related disabilities among youth and working-age adults.[6]

Among working-age adults aged 25 to 64, 62% of people with disabilities were employed, against 78% of people without. For those with more severe disabilities the rate falls to 42%.[8] Labour Force Survey data put average hourly earnings at $31.95 for employees with a disability against $33.86 for those without.[7]

The longer horizon

Ontario's AODA set a target of a fully accessible province by 2025, a date now passed. Federally, the Accessible Canada Act sets out to make Canada barrier-free by 1 January 2040.[7] An organization filing in December 2026 is filing at the start of that horizon, not the end of one.

What we would do between now and December

This is a research report rather than a service pitch, so the following is deliberately something an organization can do without hiring anyone.

  1. Confirm which category you are in. Twenty or more employees means filing. Ontario counts full-time, part-time, seasonal and contract workers, and excludes volunteers, independent contractors and employees outside Ontario — a distinction that moves some organizations across the threshold in both directions.[2]
  2. Test the six. Contrast, alternative text, form labels, empty links, empty buttons, document language. They are 96% of detected errors and every one is checkable with free tooling.[5]
  3. Check what the certifier is signing. If nobody has tested the site, the senior officer is attesting to something unverified.
  4. Write the multi-year accessibility plan if you have 50 or more employees, and post it publicly.[4]
  5. Fix the process, not just the pages. Seven years of identical top-six failures suggests one-off remediation does not hold. Accessibility checked at design, build and review is the only version that survives the next redesign.

Limits of this report

This is secondary research. We collected no new data. Three limits matter when reading it.

  • WebAIM measures home pages, not whole sites, and only failures an automated tool can detect. WebAIM states plainly that absence of detected errors does not mean a page is accessible.[5]
  • The site-category data was classified using an AI model, per WebAIM's own note, so the non-profit figure carries classification error we cannot quantify.[5]
  • Employment figures come from two different instruments. The Canadian Survey on Disability and the Labour Force Survey use different definitions and reference periods, so their employment rates are not directly comparable with each other.[7][8]

Sources

Every figure above is drawn from one of these eight. All were retrieved in September 2026 and each link goes to the primary publisher.

  1. 1
    Government of Ontario. Completing your accessibility compliance report. Ministry for Seniors and Accessibility. Updated 19 February 2026. ↩
  2. 2
    Government of Ontario. Accessibility rules for businesses and non-profits. Requirements by organization type and size. ↩
  3. 3
    Government of Ontario. Accessibility for Ontarians with Disabilities Act, 2005. The statute itself. ↩
  4. 4
    Government of Ontario. Integrated Accessibility Standards, O. Reg. 191/11. The regulation setting the information, employment and design standards. ↩
  5. 5
    WebAIM. The WebAIM Million: the 2026 report on the accessibility of the top 1,000,000 home pages. Utah State University. Sample taken February 2026, published 30 March 2026. ↩
  6. 6
    Statistics Canada. Canadian Survey on Disability, 2017 to 2022. The Daily, 1 December 2023. ↩
  7. 7
  8. 8