If you are an organization with 50 or more employees in Ontario
– other than the Government of Ontario or a designated public
sector organization – you meet the definition of a
"large organization" as outlined in s. 2 of the
Integrated Accessibility Standards Regulation 191/11 (IAS).
In accordance with the IAS, large organizations in Ontario will
soon be required to make their internet and intranet websites and
web content accessible, according to the Web Content Accessibility
Guidelines (WCAG) 2.0 created by the World Wide Web Consortium
(W3C). The requirements are set out in the Accessibility Standard
for Information and Communications under Part II of the Integrated
Accessibility Standards Regulation 191/11 of the Accessibility
for Ontarians with Disabilities Act, 2005.
Employers in Ontario will already be familiar with the Customer
Service Accessibility Standard, which required organizations to
ensure policies, practices and procedures governing the provision
of goods or services to persons with disabilities were established
and implemented as of January 1, 2012.
The Information and Communications Standard, set out in Part II
of the IAS, will require large organizations to begin making their
websites accessible for all Ontarians. For example, if an employer
has an explanatory video on its website, the video will have to
have closed captioning to accommodate individuals with hearing
The following is a summary of the requirements and the timelines
for implementation for large organizations:
January 1, 2014: New internet websites and web content 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 criteria 1.2.4 (captions)
and 1.2.5 (pre-recorded audio descriptions).
The requirements apply to websites and web content, including
web-based applications and to web content published on a website
after January 1, 2012.
This web accessibility requirement will be phased in for large
organizations starting January 1, 2014. However, organizations
should note that all content posted from January 2012 on will
eventually be required to meet the Level AA WCAG 2.0 standard.
Therefore, it is in an employer's best interest to begin
implementing a compliance strategy to ensure that all web content
that is posted going forward is meeting the standard to ease this
transition. Further, any planned website redevelopment should be
done with software that will meet the Level AA WCAG 2.0 standards
when full compliance is required in 2021. Organizations should
begin a dialogue with their IT personnel to discuss a compliance
strategy as soon as possible.
What is WCAG 2.0?
WCAG 2.0 is an internationally accepted standard for web
accessibility developed by the W3C, which sets out guidelines for
organizations to follow to make their websites more accessible for
people with disabilities. The guidelines cover things like writing
web content in clear language, providing alternative text for
images and making sure someone can navigate your website with just
a keyboard. Each guideline has three levels of accessibility: A, AA
The Government of Ontario has provided a compliance wizard to
assist employers in understanding their obligations under the
Integrated Accessibility Standards, which can be found here.
In addition to meeting the website accessibility standards, the
Information and Communications Standards requires additional
information and communications to be provided in accessible
formats, including but not limited to:
Provide accessible formats and communications supports in a
timely manner and at a cost that is no more than the regular cost
charged to other persons, when a person with a disability asks for
them. In effect for large organizations on January 1, 2016.
Make feedback processes accessible by providing accessible
formats and communications support when requested and notify the
public about the availability of accessible formats and
communication support. In effect for large organizations on January
Make public emergency information accessible when requested, if
the organization prepares emergency procedures, plans or public
safety information and makes the information available to the
public. In effect since January 2012.
In addition to large organizations, other obligated
organizations, such as the Government of Ontario, public sector
organizations and small organizations (less than 50 employees),
will also be required to comply with the Information and
Communications Standards in accordance with timelines specified in
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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