AODA compliance for Shopify stores

AODA compliance means meeting the duties of the Accessibility for Ontarians with Disabilities Act, 2005. For an online store the main ones are accessible feedback, accessible formats on request, staff training and, at 50 or more Ontario employees, a website that meets WCAG 2.0 Level AA. Ontario issues no certificate. You attest to it yourself.

The detailed duties are in the Integrated Accessibility Standards Regulation (O. Reg. 191/11, often called the IASR). WCAG (the Web Content Accessibility Guidelines) is the technical standard from the W3C that the website rule points to.

Yes, for every business and non-profit with at least one employee in Ontario. What you must do grows with your Ontario headcount: basic duties from 1 employee, a compliance report every three years from 20, and the website rule and a multi-year plan from 50.

The count is employees in Ontario, not your total. A store based in another province with staff in Ontario counts only those Ontario staff.

Section 14 of the regulation says a large organization's internet websites and web content must meet WCAG 2.0 Level AA. Two success criteria are left out: 1.2.4 Captions (Live) and 1.2.5 Audio Description (Prerecorded). New sites had to meet Level A from January 1, 2014, and all sites have had to meet Level AA since January 1, 2021.

• It covers websites and web content, including web-based applications.
• It covers content you control directly, or through a contract that allows you to modify it. For a Shopify store that means your theme, product pages, images, apps you add and your own pages.
• It covers content published after January 1, 2012.
• If something truly cannot be made accessible, you may still post it, but you must explain why and give a summary when someone asks.

Most WCAG 2.0 AA problems on Shopify stores show up in the same places. Check these first, on a phone and a computer:

• Product images. In your Shopify admin, open each product, select each image and add alt text (a short description of an image for people who cannot see it).
• Colours. In Online Store, Themes, Customize, check text and button colours against the background with our contrast checker.
• Menus and the cart drawer. Open them with only the keyboard (Tab, Enter and Escape) and make sure you can close them again.
• Variant pickers and quantity fields. A screen reader should say what each one is.
• Pop-ups and apps. Newsletter pop-ups, reviews, chat and upsell apps are added on top of your theme. Test them too, because the rule covers content you control or can have modified.

Automated checks find some problems, not all. A person still has to test keyboard use, screen reader output and video captions.

Businesses and non-profits with 20 or more employees file an accessibility compliance report every three years. The next one is due December 31, 2026.

• You file online, in the Accessibility Compliance Reporting Portal.
• You need your legal name, business number and number of employees in Ontario.
• A certifier must sign off. This is a senior officer with the legal authority to attest that the report is complete and accurate.
• The answers are yes or no. Ontario asks for no proof and no certification, so the evidence stays with you.

Organizations with 50 or more employees in Ontario need accessibility policies and a multi-year accessibility plan that sets out how they will meet their duties. Review it at least every five years. For an online store, a plan can be short: the WCAG target, which templates and apps you will fix and when, how you test, and who is responsible.

These duties apply from your first employee in Ontario.

• Feedback (section 11). The ways customers give you feedback must be accessible. Offer more than one, for example an accessible contact form, an email address and a phone number.
• Accessible formats (section 12). When someone asks, provide information in a format they can use, in a timely way and at no extra cost. You must also tell the public that this is available.
• Training. Staff need training on the AODA standards and the Ontario Human Rights Code.

An accessibility statement page on your store is a good place to put the notice and the contact options. In Shopify, add it under Online Store, Pages and link it from your footer menu. Our statement generator drafts the text.

The Government of Ontario. A Director under the Act can review your compliance and issue administrative penalties, and the courts can impose fines for offences. In practice, enforcement has been light and driven by complaints and self-reports.

In 2014 the Licence Appeal Tribunal cut most $2,000 penalties for not filing a report to $500, treating it as a minor contravention. The deadline and customer complaints are the practical reasons to act, not fear of the maximum fine.

The AODA also does not reduce your duties under the Ontario Human Rights Code (AODA section 3). A customer who cannot buy from your store can bring a human rights complaint whatever your size.

Ontario is not the only rule. Manitoba has required WCAG 2.1 AA, a newer version, since May 1, 2025, for any organization with at least one employee in Manitoba. The federal Accessible Canada Act covers only federally regulated businesses such as banks and airlines. Other provinces have no web standard for private stores yet, but every human rights code applies.

If you sell in Quebec, publish your accessibility statement and feedback form in French as well as English, and set the page language correctly. Language settings are part of WCAG too (3.1.1 Language of Page and 3.1.2 Language of Parts).

Our guide to Canadian accessibility laws covers each province, with a table.