What an Ontario non-profit actually owes on its website

# What an Ontario non-profit actually owes on its website

The accessibility compliance report is due December 31 and someone on your board has already asked whether the website has to be fixed before you file it. Filing the report and meeting the web accessibility standard are two different obligations with two different thresholds. The one that reaches your website starts at fifty employees, and that count does not include a single volunteer on your roster.

So for most Ontario non-profits nobody can require your website to meet WCAG 2.0 AA. That is the worst available reason to leave it the way it is.

I rebuilt the site for an emergency shelter in Thunder Bay, and the constraint that outranked everything else was that somebody arriving in a crisis, often on an old phone, finds help in one tap. No inspector was ever going to check that. It was the entire job. The site is on the work page.

Ontario counts the people you pay, in Ontario, and nothing else

Ontario's page on accessibility rules for businesses and non-profits sets out the count. Include full-time employees, part-time employees, seasonal employees and contract workers. Then, in a list of its own: "Do not count: employees outside Ontario, volunteers, independent contractors."

For a lot of organizations that is the difference between two entirely different legal positions. Take a food bank with eleven paid staff and two hundred volunteers: for this purpose it is an eleven-employee organization, under the twenty that triggers a report and a long way under the fifty that brings the web standard.

Ontario says to include "contract workers" and to exclude "independent contractors", and the page does not define the difference between them. If your headcount sits near twenty or near fifty, that distinction decides which side of the line you are on, and the answer should come from somebody who gives legal advice rather than from a web developer. I am the second kind.

There is a condition attached to the exemption. Ontario says you remain "responsible for ensuring the services that volunteers or independent contractors provide on your behalf follow the rules of Ontario's accessibility standards." Your volunteers do not raise your headcount. What they do in your name is still yours.

Source: ontario.ca — accessibility rules for businesses and non-profits (opens in a new window), read September 12 2026.

The report and the web standard are two obligations with two thresholds

Twenty or more employees and you file the compliance report every three years, next due December 31

1. Fifty or more and your public website has to meet WCAG 2.0 Level AA, for content published

after January 1 2012. That requirement came into force January 1 2021. What enforcement actually looks like — who checks, and what a complaint sets in motion — is on the compliance page.

What matters to a budget is the order of the two. The report is a form. The website is a project. Filing in December does not require a rebuilt website, so a proposal that lands on your board with that date on the cover is asking for a rebuild to be approved against a deadline that is not yours.

The person your site is failing is not an inspector

Take the fifty-employee line away and nothing about your website changes. The person who cannot complete your intake form still cannot complete it, and in this sector they are disproportionately the person the organization exists for. A disability services non-profit with nine staff sits under every threshold Ontario sets, and its clients are the ones least able to route around a form that does not work.

[GATE-A PLACEHOLDER — needs the founder interview.] One specific failure found on a real non-profit site: what it was, who it blocked, what it cost to fix. Plus the permission decision on whether the organization can be named or has to be "a community services non-profit in Thunder Bay". Do not draft around this — it is the paragraph that makes the section first-hand.

Conscience is not the only lever. Funders write conformance into agreements, and so does the public sector: Ontario's Broader Public Sector Procurement Directive binds any publicly funded organization that received $10 million or more in public funds last year, and a non-profit on that list is buying under procurement rules regardless of how many people it employs. The statutory threshold is the floor, not the ceiling, and the contract usually sits above it.

The grant calendar does not line up with December 31

The federal Enabling Accessibility Fund is what gets suggested to a non-profit that mentions accessibility and money in the same sentence, and for a website it is a poor fit. Its community and workplace streams run grants up to $200,000 and contributions up to $3,000,000, and the examples the program itself gives are physical — "installing screen reader devices and hearing loop systems." Website work is not among the activities it names. The small projects component currently reads Closed, and the mid-sized component's last published application period ran October 18 to December 13 2023.

Ontario Trillium Foundation is the closer fit, and its calendar is the problem:

otf.ca — grant application deadlines (opens in a new window) and the individual stream pages, read September 12 2026.

Read those dates against December 31. A board that decides in November that your website needs work cannot fund it from any of them in time, and OTF states that applicants are notified "approximately 4-5 months from the deadline date." None of the four names a website as an eligible cost either; the nearest thing is the Seed grant's "building their capacity to plan for future programs and services", and whether a site qualifies is a conversation with a grant officer rather than a given.

Which leaves the answer nobody enjoys. For most non-profits this comes out of operating money, and the only honest way to handle that is to cut the scope to the budget rather than stretch the budget to the scope. What a project at that scope covers is on the development page.

What I will not quote you for

Remediation you do not owe. If you are under fifty paid Ontario employees and no funder has put a conformance clause in your agreement, I will say so before I send a number, and the conversation changes from what the site must pass to what it should do.

A five-page brochure site. A template will serve you better and cost a fraction of what I would charge.

Anything that promises compliance from a script you paste in. The overlay products have attracted lawsuits rather than settled the question, and the accessibility statement they switch on for you is a claim your organization is then answerable for.

Count your paid Ontario staff before you scope any of this. The number is smaller than you think, and it changes what you should be buying.