There's a lot of confusion about "which WCAG" Ontario requires. Here's the precise version.
The legal floor: WCAG 2.0 AA
Under Ontario's IASR (the regulation behind the AODA), the legal minimum for covered organizations' public websites and content is WCAG 2.0 Level AA — with two exemptions: 1.2.4 (live captions) and 1.2.5 (audio description for pre-recorded video).
That's the letter of the law. It hasn't been updated to a newer WCAG version in the regulation itself.
Best practice: WCAG 2.2 AA
WCAG has moved on since 2.0 (published 2008). The web is now mobile-first and the guidelines caught up:
What WCAG 2.1 (2018) added — mostly mobile & low-vision:
- Orientation (works in portrait and landscape)
- Reflow (usable when zoomed/narrow without horizontal scrolling)
- Pointer/touch target considerations
- Content on hover/focus behavior
What WCAG 2.2 (2023) added — focus, motor & cognitive:
- Focus Appearance / Not Obscured — you can always see where keyboard focus is
- Dragging Movements — drag actions have a single-pointer alternative
- Target Size (Minimum) — tap targets large enough for motor impairments
- Accessible Authentication — no cognitive puzzles to log in (no forced memory tests)
- Consistent Help — help is in a predictable place
Why build to 2.2 if the law says 2.0?
Three reasons:
- Your customers are on phones. 2.0 predates the mobile era; 2.1/2.2 cover the experience most of your traffic actually has. Building to 2.0 only can leave real mobile barriers in place.
- Future-proofing. Regulations trend toward newer versions over time (the U.S. and EU already reference 2.1). Building to 2.2 now means you're not re-doing this in two years.
- Stronger position. "We exceeded the legal floor and built to current best practice" is a better story than "we did the bare minimum" — both to customers and, if it ever comes up, to a tribunal.
How we frame it at PassProof
Plainly: the IASR legal floor is WCAG 2.0 AA; we build and test to 2.2 AA as current best practice (which also covers mobile and cognitive accessibility). You get compliance and a site that works for the way people actually browse today. We don't claim 2.2 is "the law" — it isn't — we recommend it because it's the smart target.
See where your site lands today — free
The PassProof Report scans your site and shows your WCAG 2.2 AA gaps in ~30 seconds, with what's legally required for your size and a fixed-price path.
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PassProof is a remote-first accessibility-engineering studio serving Ontario. Accessibility-engineering guidance, not legal advice; we work alongside your counsel.