Accessibility Standards in Canada: Reviewing Content for AODA and ACA Compliance

Canada has some of the world's strongest accessibility legislation — and it's getting stronger. The federal Accessible Canada Act (ACA) applies to all federally regulated organizations. Ontario's Accessibility for Ontarians with Disabilities Act (AODA) has been in force since 2005 with increasingly strict requirements. Other provinces — British Columbia, Manitoba, Nova Scotia, and Quebec — have their own accessibility legislation at various stages of implementation.

For organizations producing content — websites, documents, communications, forms, and digital tools — accessibility compliance means more than technical HTML standards. It means content that is written in plain language, structured clearly, available in alternative formats, and understandable by people with a range of abilities. Most organizations focus on the technical side (WCAG conformance) and overlook the content side (readability, clarity, and plain language) — leaving a significant compliance gap.

This guide covers what Canadian accessibility laws require for content, where organizations commonly fail, and how to build a review process that addresses both technical and content accessibility.

The Canadian Accessibility Framework

Federal: Accessible Canada Act (ACA)

The ACA applies to federally regulated organizations including banks, telecommunications companies, transportation providers, and the federal government itself.

The Canadian Accessibility Standards Development Organization (Accessibility Standards Canada) is developing enforceable standards under the ACA, including standards for ICT accessibility.

Ontario: AODA

AODA is the most mature provincial accessibility law and applies to all organizations in Ontario with one or more employees.

AODA web content requirements:

• All public websites and web content must conform to WCAG 2.0 Level AA
• Accessible formats must be provided on request (large print, braille, audio, electronic)
• Feedback processes must be accessible
• Organizations with 50+ employees must file accessibility compliance reports

Other Provincial Laws

Content Accessibility Requirements

What "Accessible Content" Actually Means

Accessibility laws require more than WCAG-compliant HTML. They require content that people with disabilities can actually use and understand.

Plain Language Requirements

Both the ACA and AODA require organizations to communicate accessibly. In practice, this means:

• Reading level — target Grade 8-9 (Flesch-Kincaid) for public-facing content
• Clear structure — descriptive headings, short paragraphs, bulleted lists
• Consistent terminology — same term for the same concept throughout
• Defined jargon — technical terms explained on first use
• Active voice — "We will process your application" not "Your application will be processed"
• Alternative formats — content available in large print, audio, braille, or other formats on request

WCAG Content Guidelines

WCAG 2.1 includes specific guidelines for content:

While Level AAA criteria aren't mandatory under AODA, they represent best practice for content accessibility — particularly 3.1.5 (reading level), which directly addresses cognitive accessibility.

Bilingual Requirements

Many Canadian organizations must provide content in both English and French. Accessibility applies to both languages:

• Both language versions must meet WCAG standards
• Language switching must be accessible (keyboard-navigable, clearly labelled)
• Translated content must maintain the same accessibility features as the source
• Reading level should be appropriate in both languages
• Alternative formats must be available in both languages on request

Common Content Accessibility Failures

1. Reading Level Too High

The most pervasive content accessibility failure. Government documents, forms, and public communications written at Grade 12-16 reading level when the target audience includes people with varying literacy levels.

Example — government service page:

Inaccessible (Grade 15): "Applicants who have heretofore been in receipt of benefits under the aforementioned programme may be eligible for transitional assistance provided that the eligibility criteria as delineated in Section 4.2 of the Programme Guidelines are satisfied."

Accessible (Grade 8): "If you received benefits from this program before, you may qualify for transitional help. Check the eligibility criteria in Section 4.2 of the Program Guidelines to see if you qualify."

2. Non-Descriptive Link Text

"Click here," "read more," and "learn more" provide no information about the destination — particularly problematic for screen reader users who navigate by links.

Inaccessible: "For more information, click here."

Accessible: "Read the full accessibility compliance guide."

3. Inaccessible Document Formats

PDFs and Word documents that aren't tagged for accessibility:

• No heading structure (screen readers can't navigate)
• Images without alt text
• Tables without header cells identified
• No reading order defined
• Scanned documents (image-based PDFs) without OCR text layer

4. Forms Without Clear Instructions

Forms that assume users know what's expected:

• No format examples for phone numbers, postal codes, or dates
• Required fields not clearly identified
• Error messages that don't explain what went wrong or how to fix it
• No instructions for complex form sections

5. Inconsistent Terminology

Using different terms for the same thing across a website or document suite — "apply," "submit," "register," and "enrol" all referring to the same action. This confuses all users but is particularly problematic for people with cognitive disabilities.

Building an Accessibility Content Review Process

Step 1: Audit Current Content

Priority order:

1. High-traffic public pages — homepage, service pages, forms
2. Critical user flows — applications, registrations, payments
3. Customer communications — letters, emails, notifications
4. Documents — PDFs, fact sheets, policies published on the website
5. Internal content — intranet, employee communications

For each page/document, assess:

Step 2: Define Review Criteria

For web content:

• Reading level ≤ Grade 9 (Flesch-Kincaid)
• All headings are descriptive (not "Section 1" or "Overview")
• All links describe their destination
• No unexplained abbreviations or jargon
• Active voice predominant
• Short paragraphs (2-4 sentences)
• Lists used for 3+ related items
• Alternative text for all non-decorative images
• Form instructions include format examples
• Error messages identify the problem and suggest a fix

For documents (PDFs, Word):

• Document is tagged for accessibility
• Heading structure is logical and complete
• Reading order is correct
• Images have alt text
• Tables have identified header cells
• Language is identified
• Not a scanned image (must have real text)

Step 3: Implement Review at Content Creation

Build accessibility review into the content creation process rather than retrofitting:

1. Writer drafts content with accessibility guidelines in mind
2. Content reviewed for reading level and plain language
3. Technical accessibility checked (structure, alt text, tagging)
4. Both English and French versions reviewed (if bilingual)
5. Publish when both content and technical accessibility pass
6. Periodic audit of published content

Step 4: Track and Report

AODA requires organizations with 50+ employees to file accessibility compliance reports. Track:

• Number of pages/documents reviewed for accessibility
• Percentage meeting WCAG AA and content accessibility targets
• Feedback received about accessibility barriers
• Actions taken to address barriers
• Alternative format requests and fulfilment

Using AI to Review Content Accessibility

What AI Can Check

• Reading level — instant Flesch-Kincaid scoring for English and French content
• Plain language — flag jargon, complex vocabulary, passive voice, long sentences
• Link text quality — identify non-descriptive links ("click here," "read more")
• Heading quality — check headings are descriptive and informative
• Terminology consistency — flag different terms used for the same concept
• Instruction clarity — check form instructions and error messages for specificity
• Abbreviation usage — flag abbreviations not expanded on first use

What AI Cannot Check

• Whether HTML structure meets WCAG technical requirements
• Whether alt text accurately describes images
• Whether documents are properly tagged for accessibility
• Whether keyboard navigation works correctly
• Whether content is actually usable by people with specific disabilities (user testing required)

Practical Example

In TeamBench, you could configure a reviewer:

Reviewer name: Canadian Accessibility Content Reviewer

System prompt:

You are a content accessibility reviewer for Canadian organizations. Review web content, documents, and communications against AODA Information and Communications Standard requirements, ACA accessibility requirements, and WCAG 2.1 content guidelines. Check for: reading level (target Grade 8-9 Flesch-Kincaid), plain language (no unexplained jargon or abbreviations), link text quality (descriptive, not "click here"), heading quality (descriptive and hierarchical), instruction clarity (form instructions with format examples, error messages that identify the problem), terminology consistency, and active voice. Note whether the content needs bilingual review. Use Canadian English. Flag specific passages with the WCAG guideline or AODA requirement and suggest accessible alternatives.

Evaluation criteria:

• Reading Level (weight: 3) — Grade 8-9 for public content, Grade 7-8 for critical flows
• Plain Language (weight: 3) — No unexplained jargon, abbreviations expanded, active voice
• Clarity (weight: 2) — Instructions, error messages, and labels are unambiguous
• Consistency (weight: 1) — Same terminology throughout
• Structure (weight: 1) — Descriptive headings, short paragraphs, lists for related items

Quality gate: Minimum score: 75.

Upload AODA guidelines, your organization's accessibility policy, and your style guide into a Knowledge Base. Use the readability checker for quick page-level scoring.

Frequently Asked Questions

Does AODA apply to my organization?

AODA applies to all organizations in Ontario with one or more employees, including businesses, non-profits, and public sector organizations. Requirements vary by organization size — organizations with 50+ employees have more extensive requirements including filing compliance reports and maintaining documented accessibility policies.

What WCAG version does AODA require?

AODA currently requires WCAG 2.0 Level AA for web content. However, WCAG 2.1 Level AA is the current industry standard and is expected to be adopted in future AODA updates. Organizations should target WCAG 2.1 Level AA to be compliant now and prepared for future requirements.

Do I need to make all existing content accessible?

Under AODA, all public web content must conform to WCAG 2.0 Level AA. For other content (documents, communications), you must provide accessible formats on request. Practically, prioritize by risk and impact: public-facing, high-traffic content first, then critical user flows, then broader content.

What are the penalties for non-compliance?

Under AODA, individuals can face penalties up to $50,000 per day, and corporations up to $100,000 per day for non-compliance. Under the ACA, penalties can reach up to $250,000. Beyond penalties, inaccessible content excludes potential customers and creates reputational risk.

How do we handle bilingual content accessibility?

Both language versions must meet the same accessibility standards. Don't assume that translating accessible English content automatically produces accessible French content — sentence structure, reading level, and terminology may differ. Review both versions independently for accessibility. Use readability tools that support both English and French.

Is plain language legally required?

The ACA requires communications to be available in plain language. AODA requires accessible formats and communication supports. While neither specifies an exact reading level, the intent is clear: content must be understandable by the broadest possible audience. Plain language at Grade 8-9 reading level is the accepted standard for meeting this requirement.

Key Takeaways

• Canada has layered accessibility legislation — the federal ACA, Ontario's AODA, and emerging provincial laws all impose content accessibility requirements.
• Content accessibility goes beyond WCAG HTML compliance — reading level, plain language, clear instructions, and consistent terminology are equally important.
• Target Grade 8-9 reading level for public-facing content. Most organizational content is written at Grade 12+ — well above what accessibility requires.
• Common failures include high reading levels, non-descriptive link text, inaccessible document formats, unclear form instructions, and inconsistent terminology.
• Build accessibility into content creation, not just post-publication auditing. Review every piece of content for both technical and content accessibility before publishing.
• Bilingual content requires independent accessibility review for both English and French versions.
• AI-assisted review can check reading level, plain language, link text, headings, and terminology consistency, but cannot replace technical WCAG audits or user testing with people with disabilities.
• Track and report accessibility metrics — AODA requires compliance reporting for organizations with 50+ employees.

---

This article provides general information about Canadian accessibility content requirements and is not legal advice. Always consult the Accessibility Standards Canada for ACA requirements and the Government of Ontario for AODA requirements.