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Is Your Site Compliant?

This information was extracted from the Integrated Guide and is relevant to the Ontarians with
Disabilities Act (AODA) legislation.

Section 14: Accessible Websites and Web Content

Requirement as Stated in the Regulation

14(1) The Government of Ontario and the Legislative Assembly shall make their internet and intranet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA, and shall do so in accordance with the schedule set out in this section.

(2) Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG)2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.

(3) The Government of Ontario and the Legislative Assembly, for both their internet and intranet sites, shall meet the requirements in this section in accordance with the following schedule:

By January 1, 2012, new internet and intranet websites and web content on those sites must conform with WCAG 2.0 Level AA, other than,

By January 1, 2016, all internet websites and web content must conform with WCAG 2.0 Level AA other than,

By January 1, 2020, all internet and intranet websites and web content must conform with WCAG 2.0 Level AA.

(4) Designated public sector organizations and large organizations for their internet websites shall meet the requirements of this section in accordance with the following schedule:

  • By January 1, 2014, new internet websites and web content on those sites must conform with WCAG 2.0 Level A.
  • By January 1, 2021, all internet websites and web content must conform with WCAG 2.0 Level AA, other than,
    • success criteria 1.2.4 Captions (Live), and
    • success criteria 1.2.5 Audio Descriptions (Pre-recorded).

(5) Except where meeting the requirement is not practicable, this section applies, to websites and web content, including web-based applications, that an organization controls directly or through a contractual relationship that allows for modification of the product; and to web content published on a website after January 1, 2012.

(6) In determining whether meeting the requirements of this section is not practicable, organizations referenced in subsections (1) and (2) may consider, among other things,

  • the availability of commercial software or tools or both; and
  • significant impact on an implementation timeline that is planned or initiated before January 1, 2012.

(7) In this section,

“extranet website”means a controlled extension of the intranet, or internal network of an
organization to outside users over the Internet; (“French”)

“internet website”means a collection of related web pages, images, videos or other digital
assets that are addressed relative to a common Uniform Resource Identifier (URI)and is accessible to the public; (“French”)

“intranet website”means an organization’s internal website that is used to
privately and securely share any part of the organization’s information or operational
systems within the organization and includes extranet websites; (“French”)

“new internet website”means either a website with a new domain name or a website with an
existing domain name undergoing a significant refresh; (“French”)

“new intranet website”means either an intranet website with a new domain name or an intranet
website with an existing domain name undergoing a significant refresh; (“French”)

“Web Content Accessibility Guidelines”means the World Wide Web Consortium Recommendation, dated December 2008, entitled “Web Content Accessibility Guidelines (WCAG) 2.0”;(“French”)

“web page”means a non-embedded resource obtained from a single Uniform Resource Identifier
(URI)using Hypertext Transfer Protocol (HTTP)and any other resources that are used in the rendering or intended to be rendered together with it by a user agent. (“French”)

Intent of this Requirement

The intent of this requirement is that the Government of Ontario, the Legislative Assembly, designated public sector
organizations, as well as private and not-for-profit organizations with more than 50 employees make their websites accessible to people with disabilities by conforming to international standards for website accessibility.

When do Organizations have to Comply

Private and not-for profit organizations with 49 or fewer employees do not have obligations under this requirement.

Government of Ontario and Legislative Assembly

January 1, 2012

New internet and intranet websites and web content on those sites must conform with WCAG 2.0 Level AA other than,

  • success criteria 1.2.4 Captions (Live)
  • success criteria 1.2.5 Audio Descriptions (Pre-recorded).

January 1, 2016

All internet websites and web content must conform with WCAG 2.0 Level AA other than,

  • success criteria 1.2.4 Captions (Live)
  • success criteria 1.2.5 Audio Descriptions (Pre-recorded).

January 1, 2020

All internet and intranet websites and web content must conform with WCAG 2.0 Level AA.

Designated public sector organizations, as well as private and not-for-profit organizations with 50+ employees January 1, 2014

New internet websites and web content on those sites must conform with WCAG 2.0 Level A.

January 1, 2021

All internet websites and web content must conform with WCAG 2.0 Level AA, other than,

  • success criteria 1.2.4 Captions (Live)
  • success criteria 1.2.5 Audio Descriptions (Pre-recorded).

Implementing the Requirement

All obligated organizations’ websites, and the content on those websites, must conform with WCAG 2.0. This
requirement applies to new websites first, and then over the next several years to all websites.

Many organizations control their websites and web content, including web-based applications, either directly or through a contractual relationship. That is, they may develop a website and web content in house or they may hire a consultant. In both cases, the organization has control of the functionality and the appearance of the website, as well as its content. Therefore, the organization has the responsibility and ability to incorporate accessibility.

Terminology

Understanding the terminology is the first step to implementing this requirement successfully.

Organizations should refer to the definitions in Section 14 (7) in the Regulation for more information.

The following is an easy reference list of definitions for other key terms used in this section of the regulation.

What is WCAG?

Web Content Accessibility Guidelines (WCAG) 2.0 is an international standard for making websites and web content accessible to a broader range of users with disabilities.

WCAG was developed by a team of experts from around the world. The first version, WCAG 1.0, was released in 1999. WCAG 2.0 was released in 2008.

What does Level A and Level AA mean?

WCAG 2.0 Level A and Level AA refer to a series of technical checkpoints that make websites and their content increasingly accessible to a broader range of users with disabilities.

Level AA builds on Level A’s checkpoints.

What does new website and content mean?

A new website refers to a site with a new domain name “- a brand new web address. The term does not
refer to a new page or new link on an existing site.

The term also refers to a site with an existing domain name that is undergoing a significant
“refresh”. There is not an industry standard definition for significant refresh. In this context,
“significant refresh”could include, but is not limited to, the following elements:

  • a new look and feel to the website
  • a change in how users navigate around it
  • a major update and change to the content of the website.

Content may include any information that may be found on a web page or web application, including text, images, forms and sounds.

What does practicable mean?

Organizations are required to meet their WCAG 2.0 requirements, unless it is not practicable to do so. Under this requirement, practicability refers to the organization’s ability given all of the circumstances to modify their websites and web content.

Section 14(6) of the regulation states that when organizations are determining whether meeting the requirement is practicable, they may consider the following factors, among others:

  • the availability of commercial software or tools
  • the affect that the deadline would have on the implementation timelines for projects that were planned or initiated before January 1, 2012.

Additionally, transactional applications may have significant refreshes that are on a different cycle than the rest of the website. Organizations may take this into account when considering what is practicable.

Website Information Posted Prior to 2012

Content published on a website before January 1, 2012 is not required to be compliant with WCAG 2.0. However, people with disabilities can still request information to be provided in an accessible format under the Section 12, “Accessible Formats and Communication Supports”.

Website Information Posted After 2012

Web content, including documents such as Word and PDFs, posted after January 1, 2012 will need to be accessible as per the regulation.

Availability of Commercial Software and Tools

Some organizations may have used software, web applications and other tools that pre-date WCAG 2.0 to develop their websites and web content. These tools may have varying ability to create websites and web content that will conform with WCAG 2.0
requirements. As a result, organizations have until 2021 to comply as this will allow them to take advantage of emerging software, web applications and tools to make existing websites and web content accessible.

Technological Capability

Some organizations may be limited by technological capability. For example, there may be technological software limitations in making online maps and complex diagrams accessible to people with visual disabilities. In such cases, an accessible alternate version can be provided if requested.

Projects Planned Prior to January 1, 2012

In determining practicability, the regulation allows organizations to consider projects planned before January 1, 2012 that may be significantly affected by implementing WCAG 2.0 requirements.

However, once updated, websites and web content would need to meet the WCAG 2.0 compliance dates set out in the regulation.

Some of the WCAG 2.0 requirements can improve the accessibility of an application and would not significantly delay implementation. Organizations are required to think about and take reasonable steps to overcome barriers that people with disabilities might encounter when using their websites.

Staggered Timelines for Compliance

The regulation has staggered timelines for designated public sector organizations, as well as private and not-for-profit organizations with 50 or more employees. These organizations must comply with WCAG 2.0, Level A and then with WCAG, 2.0 Level AA, excluding the requirements for live captioning and pre-recorded audio descriptions.

Staggered timelines allow organizations to build accessibility into their regular re-fresh cycles and to implement systematic approaches to increase their web accessibility and to meet the compliance dates. On average, organizations update their website every two or three years; the timelines will allow two or three opportunities for organizations to build accessibility into their regular website update.

By planning for accessibility in advance, organizations may be able to reduce their costs as well as to improve web-based experiences for people with disabilities.