Website accessibility in Quebec and Canada: who really has to comply

Digital accessibility means everyone can use a website: a blind person using a screen reader, someone who can’t use a mouse, someone who struggles with low contrast or needs to enlarge the text. For a long time, the topic was left to governments and very large companies.

Since the summer of 2025, though, our clients have been asking about it often, partly because Europe tightened its rules and we work on both sides of the Atlantic. Is my website affected? What’s the risk? Where do I start? Here is where things stand in Canada, law by law.

In Quebec: an obligation for the state, a principle for everyone

Public bodies

Quebec government departments and public bodies must comply with the Standard sur l’accessibilité des sites Web (SGQRI 008 3.0), in force since April 29, 2024. It is based on the international WCAG 2.1 guidelines, Level AA, and adds several criteria from WCAG 2.2. It applies to new content from the design stage and to existing content when it is significantly modified. If you build websites or tools for a public body, this is the reference to know.

Private businesses

No Quebec law currently imposes a specific web accessibility standard on private businesses. On this point, the Quebec act securing the rights of persons with disabilities targets government departments and public bodies.

That doesn’t mean there’s no risk. The Quebec Charter of human rights and freedoms prohibits discrimination based on a disability or the use of any means to palliate a disability (section 10), including in access to goods and services ordinarily offered to the public (section 12). As far as we know, no published decision has yet dealt with a business website in Quebec. But the principle exists, and an online service that part of your clientele can’t use could raise the question.

In Ontario: the clearest obligation in the country

The Accessibility for Ontarians with Disabilities Act (AODA) requires businesses and non-profits with 50 or more employees to make their public websites meet WCAG 2.0, Level AA, since January 1, 2021, for content published after 2012. Two criteria are excluded: live captions and audio descriptions for pre-recorded video.

Organizations with 20 or more employees must also file an accessibility compliance report every three years. The next deadline is December 31, 2026. Fines under the act can reach $100,000 a day for a corporation.

One point many Quebec businesses don’t know: according to the Ontario government’s guide, an organization with at least one employee in Ontario must comply with the rules for its size. Only employees in Ontario count toward the threshold. A Montreal company with a 60-person office in Ottawa is therefore covered by the website requirement.

Federally: federally regulated businesses

The Accessible Canada Act, in force since July 2019, covers the federal government and federally regulated private businesses: banks, telecommunications, broadcasting, air transportation and interprovincial transportation. Since 2023 and 2024, those with 10 or more employees have had to publish an accessibility plan, set up a feedback process and produce progress reports. Penalties can reach $250,000 per violation.

For the web, a regulation published in December 2025 makes the CAN/ASC-EN 301 549 standard mandatory, the Canadian version of the European standard. For private businesses with an average of 100 or more employees, web content will have to comply starting December 5, 2028. Mobile apps and certain documents follow higher thresholds. Transportation providers already have to make their websites and apps meet WCAG, Level AA.

Elsewhere in Canada

In Manitoba, the information and communication standard, based on WCAG 2.1 AA, has also applied to the private sector and non-profits since May 1, 2025. British Columbia and Nova Scotia have passed their own laws, which for now mostly target the public sector.

Selling to Europe? The European law applies to you

Since June 28, 2025, the European Accessibility Act has required websites and apps that sell to consumers in the European Union to be accessible. The directive covers any provider offering services to consumers in the Union, whether or not it is established in Europe. A Quebec online store that ships to France or Belgium is therefore covered.

Microenterprises providing services are exempt: fewer than 10 people and annual turnover or balance sheet of 2 million euros or less. In France, where we also have clients, fines can reach 7,500 euros per violation for a company, and on June 4, 2026, a court ordered the retailer Carrefour to make its website fully accessible within six months, with a penalty of 500 euros for every day of delay.

What Canadian courts have said

The landmark case is more than ten years old. In 2010, the Federal Court ruled in favor of Donna Jodhan, a blind consultant who couldn’t apply for federal jobs online or fill out certain forms: the government’s inaccessible websites violated her equality rights under the Canadian Charter. The Federal Court of Appeal upheld that finding on May 30, 2012. The case involved the government, but it set a clear principle: an inaccessible online service can be a form of discrimination.

What you need to comply with

Whatever the law, the technical reference is the same: WCAG, Level AA, in version 2.0, 2.1 or 2.2 depending on the text. The CAN/ASC-EN 301 549 standard, published in May 2024, is also based on these guidelines. Among the issues we find most often on the websites we audit:

• images with no alternative text, or with text that describes nothing;
• insufficient contrast between text and background;
• menus or buttons that can’t be used with a keyboard;
• forms without labels, with incomprehensible error messages;
• poorly structured headings that make it impossible to navigate the page with a screen reader;
• videos without captions;
• a cookie banner or payment step that can’t be completed without a mouse.

Where to start

1. Check which rules apply to you. Do you have employees in Ontario or Manitoba? Are you federally regulated? Do you sell online to consumers in Europe? Do you work for public bodies? Write down the answers and keep them.
2. Get an audit. Automated tools only catch some of the problems. The rest requires human testing, with a keyboard and a screen reader (NVDA on Windows, VoiceOver on Mac and iPhone).
3. Fix the key journeys first. Quote requests, bookings, cart, payment: that’s where compliance is decided, and that’s where you lose customers.
4. Publish an accessibility page explaining what you’ve done and how to report a problem.
5. Check again every time the site changes. A new plugin, a new banner or a new page can break what used to work.

A constraint that pays off

Accessibility is often presented as a constraint. In practice, an accessible website is clearer for everyone: on mobile, in bright sunlight, for a customer in a hurry or an older person. Search engines read a well-structured page better. And new AI agents, like Meta’s Muse, already available in Canada, navigate websites using the same information as screen readers.

If you have an online store, a booking system or customers outside Quebec, we can audit your website and tell you exactly what’s blocking. And if a redesign is planned, now is the time to start from an accessible foundation. Contact us.

This article is for information purposes only. It is not a substitute for legal advice on your situation.

Sources

• Government of Quebec, Standard sur l’accessibilité des sites Web (SGQRI 008 3.0) (in French)
• Charter of human rights and freedoms, LégisQuébec
• Government of Ontario, how to make websites accessible
• Government of Ontario, guide to accessibility compliance by industry
• Government of Canada, summary of the Accessible Canada Act
• Canada Gazette, SOR/2025-255, December 17, 2025
• Accessibility Standards Canada, CAN/ASC-EN 301 549:2024
• Accessibility Manitoba, information and communication standard
• Directive (EU) 2019/882 on accessibility requirements
• Federal Court of Appeal, Canada (Attorney General) v. Jodhan, 2012 FCA 161