The short answer

In Canada, Ontario's AODA requires public sector bodies and organizations with 50 or more employees to meet WCAG 2.0 AA on their public websites, and the Accessible Canada Act covers federally regulated organizations. In the US, the ADA applies to businesses open to the public, and a 2024 DOJ rule requires state and local governments to meet WCAG 2.1 AA, with deadlines now set for April 2027 and April 2028. Businesses selling to EU consumers may also fall under the European Accessibility Act.

Key takeaways

  • WCAG level AA is the common technical benchmark across these laws.
  • Ontario: WCAG 2.0 AA for public sector and organizations with 50+ employees since January 1, 2021.
  • US Title II deadlines moved to April 26, 2027 (50,000+ population) and April 26, 2028.
  • ADA Title III has no fixed technical standard, but lawsuits are common.
  • This is general information, not legal advice. Talk to a lawyer about your situation.

This guide gives a simple overview for businesses in Canada and the US. Laws change, and how they apply depends on your situation, so treat this as a starting point and check with a lawyer. Last reviewed: November 2026.

Canada

Ontario: AODA

The Accessibility for Ontarians with Disabilities Act and its Integrated Accessibility Standards require designated public sector organizations and private and non-profit organizations with 50 or more employees in Ontario to make their public websites and web content conform to WCAG 2.0 level AA. The deadline for all such content was January 1, 2021. Live captions and pre-recorded audio description are excluded from the requirement.

Federal: Accessible Canada Act

The Accessible Canada Act (2019) applies to the Government of Canada and federally regulated organizations such as banks, telecommunications companies and interprovincial transportation. It requires accessibility plans, feedback processes and progress reports, and standards for digital content are being developed.

Quebec

Quebec public bodies follow government web accessibility standards based on WCAG. For private businesses, Quebec’s Act to secure handicapped persons in the exercise of their rights sets general obligations, and language rules mean content aimed at Quebec consumers usually needs to be available in French, including accessibility information.

Other provinces

Manitoba, Nova Scotia, British Columbia and Newfoundland and Labrador have accessibility laws that are building out standards, including for information and communication. Check your province.

United States

ADA Title III: businesses open to the public

The Americans with Disabilities Act covers “places of public accommodation”, and the Department of Justice has stated that this includes the websites of businesses open to the public. There is no specific technical standard in the regulations for Title III, but courts and settlements commonly point to WCAG 2.1 AA. Thousands of website accessibility lawsuits are filed each year, many against small and mid-size online stores.

ADA Title II: state and local governments

In April 2024, the DOJ published a rule requiring state and local governments, including public colleges and universities, to make web content and mobile apps meet WCAG 2.1 AA. On April 20, 2026, an interim final rule extended the deadlines by one year: April 26, 2027 for entities serving 50,000 or more people, and April 26, 2028 for smaller entities and special districts. If you sell web services to these organizations, expect accessibility requirements in contracts.

Section 508

Federal agencies must make their information and communication technology accessible under Section 508 of the Rehabilitation Act, which references WCAG 2.0 AA. Vendors selling to the federal government are often asked for an accessibility conformance report.

State laws

Some states add their own rules. California’s Unruh Civil Rights Act, for example, can allow statutory damages in disability discrimination claims.

Europe: the European Accessibility Act

Since June 28, 2025, the European Accessibility Act applies to many products and services sold to consumers in the EU, including e-commerce, banking services and e-books. It can apply to Canadian and US businesses that sell to EU consumers. Microenterprises (fewer than 10 employees and annual turnover or balance sheet of no more than 2 million euros) that provide services are exempt.

What to do now

  1. Aim for WCAG 2.2 AA. It covers 2.0 and 2.1, which most laws reference.
  2. Scan your site and fix the most serious issues first. Our audit guide shows how.
  3. Keep records: scan history, fixes and dates. Accessible Nord keeps this for you and can export a report.
  4. Publish an honest accessibility statement with a contact.
  5. Do not rely on a widget or overlay for compliance. Read why.

Sources

  1. Ontario Regulation 191/11: Integrated Accessibility Standards (AODA)
  2. Accessible Canada Act (S.C. 2019, c. 10)
  3. ADA.gov: Guidance on web accessibility and the ADA
  4. Federal Register: Extension of compliance dates, ADA Title II web rule (April 20, 2026)
  5. Section508.gov
  6. Directive (EU) 2019/882, the European Accessibility Act

Last reviewed .

Frequently asked questions

Does the ADA apply to Canadian businesses?

It can, if you sell to customers in the US. Courts have considered cases against foreign businesses serving US consumers. Ask a lawyer about your specific case.

Does my small business need to comply with AODA?

The website requirement applies to Ontario organizations with 50 or more employees and the public sector. Smaller organizations still have customer service obligations, and making your site accessible is good practice.

Will using Accessible Nord make me compliant?

No tool can guarantee compliance. Accessible Nord helps you find and fix issues, track progress and document your work, which are the steps that matter. Manual testing and, for high-risk sites, expert review are still needed.

This guide is general information, not legal advice. For your specific obligations, check with a lawyer or your regulator.