Canada's federal government published hard new digital accessibility requirements for web pages, mobile apps, and PDF documents in December 2025 — and most Ontario businesses have not heard about them. On December 5, 2025, SOR/2025-255 (Regulations Amending the Accessible Canada Regulations) was registered; it appeared in the Canada Gazette, Part II, Volume 159, Number 26 on December 17, 2025. These are not aspirational guidelines. They are binding regulations under the Accessible Canada Act (ACA) with concrete compliance deadlines in 2027 and 2028.
If your business is federally regulated — a bank, a telecom, a broadcaster, or an interprovincial transport company — these rules apply to you directly and sit on top of what Ontario's AODA (Accessibility for Ontarians with Disabilities Act) already requires. If you're a typical provincially regulated Ontario business, the federal rule doesn't bind you directly, but the standard it embeds is the direction everything is moving — and understanding it helps you stay ahead of the curve.
Key facts
- SOR/2025-255 was registered December 5, 2025 and published in the Canada Gazette, Part II on December 17, 2025 (Canada Gazette, Vol. 159, No. 26).
- It applies to federally regulated entities: federal public sector (departments, agencies, Crown corporations), and private-sector federally regulated employers with 100 or more employees (banking, telecom, broadcasting, interprovincial transport). Private-sector employers with fewer than 100 employees are exempt.
- The embedded standard is CAN/ASC – EN 301 549:2024 — Canada's national ICT accessibility standard, adopted by Accessibility Standards Canada. It covers web pages, mobile applications, and non-web documents (including PDFs and office files). WCAG is embedded inside EN 301 549 at Clause 9 (web) and Clause 11 (mobile) — it is not cited by name, but its requirements flow through.
- The standard is incorporated by reference on an ambulatory basis, meaning it automatically tracks future version updates.
- Compliance milestones: federal public sector web pages by December 5, 2027; private-sector entities with 100 or more employees must conform their web pages and mobile apps by December 5, 2028.
- The rules scale by size: web and mobile conformity applies at 100+ employees, while the heaviest obligations — published accessibility statements, ICT procurement conformity assessments, and non-web document (PDF) accessibility — apply only at 500 or more employees (Canada Gazette, SOR/2025-255). Employee training on digital accessibility applies to covered entities generally.
What does SOR/2025-255 specifically require?
The regulations are not just a reference to a standard — they impose four concrete types of obligation on covered entities.
1. Conformity with CAN/ASC – EN 301 549:2024. Web pages (including web applications and employee-facing intranets) must conform to the standard, and mobile apps are separately covered — both for entities with 100 or more employees. Non-web documents — PDFs, Word documents, spreadsheets, presentations — must also conform, but only for the largest entities (500+ employees), with limited exemptions for heritage content, user-generated content, and maps or technical drawings where conformity is not feasible.
2. Published accessibility statements. Entities with 500 or more employees must publish an accessibility statement that describes the standard it targets, any known non-conformances, and how users can request accessible formats or report a barrier. This is a separate, named obligation — not something that a widget or a generic "accessibility policy" link fulfils.
3. Employee training. Covered organizations must train staff on digital accessibility fundamentals relevant to their role. This is the kind of requirement that tends to surface in regulator audits and accessibility feedback processes.
4. ICT procurement assessments. When procuring ICT products or services (software, platforms, third-party tools), entities with 500+ employees must conduct conformity assessments. This closes a gap that lets organizations buy inaccessible tools and then blame the vendor.
Which Ontario businesses does the new federal rule actually apply to?
The short answer: businesses that are regulated by the federal government, not the provincial government.
Federal regulation applies to banks, credit unions under federal charter, telecom carriers, broadcasters, and companies engaged in interprovincial transportation — including airlines, railways, and trucking companies that cross provincial or international borders. The federal public sector (departments, agencies, Crown corporations, Parliament) is also covered.
Most small and mid-sized Ontario businesses — the Shopify store, the professional services firm, the manufacturing company, the healthcare clinic, the retail chain, the nonprofit — are provincially regulated and owe the AODA, not the ACA. They are outside SOR/2025-255's direct scope.
If you are a federally regulated Ontario business with 100 or more employees, you now owe both regimes at once: the ACA (SOR/2025-255) and the AODA. Here's how to tell which law applies to your business.
What is CAN/ASC – EN 301 549:2024, and how does it compare to WCAG 2.0?
Ontario's IASR (Integrated Accessibility Standards Regulation, O. Reg. 191/11) legally requires public-facing websites for 50+ employee organizations to meet WCAG 2.0 Level AA — a standard finalized in 2008 and now nearly two decades old. WCAG 2.2, published by the W3C in October 2023, added new success criteria around focus visibility, accessible authentication, and touch target sizing. WCAG 2.1 added mobile-relevant criteria before that.
CAN/ASC – EN 301 549:2024 embeds WCAG 2.1 Level AA for web content (through EN 301 549's Clause 9) and also covers mobile, non-web software, hardware, and documents in a single standard. In practical terms, it is a meaningfully higher bar than WCAG 2.0: any organization building toward EN 301 549 conformity will need to address WCAG 2.1's additional criteria — particularly around keyboard navigation in web content, pointer accessibility, and reflow for mobile.
For provincially regulated Ontario organizations, the legal floor remains WCAG 2.0 AA under the AODA. But any organization building a new site, doing a major redesign, or planning for longevity should target WCAG 2.2 AA as the current best-practice standard — it exceeds the AODA floor, satisfies EN 301 549's web requirements for ACA purposes, and is the bar that will age best as standards continue to evolve. Here's a detailed comparison of WCAG 2.0 vs 2.2 for Ontario.
What do the December 2027 and December 2028 deadlines mean in practice?
The structure of the deadlines reflects the complexity of the work:
- December 5, 2027 (24 months from registration): Federal public sector entities must have their web pages conforming to CAN/ASC – EN 301 549:2024.
- December 5, 2028 (36 months from registration): Federally regulated private-sector employers with 100+ employees must have web pages and mobile apps conforming; the largest entities (500+ employees) additionally owe non-web document (PDF) accessibility, published accessibility statements, and ICT procurement conformity assessments.
Thirty-six months seems long. It usually isn't. An organization discovering in late 2025 that it has a meaningful accessibility debt — inaccessible PDFs across dozens of publications, a web application that hasn't been audited, mobile apps with known keyboard failures — is looking at a multi-phase project: audit, prioritize, remediate, retest, document. The earlier a scoped audit begins, the more manageable the remediation cycle. A realistic picture of how long remediation takes is in our six-month timeline guide.
Does an accessibility widget satisfy SOR/2025-255?
No — and it doesn't satisfy the AODA either. The regulation requires conformity with CAN/ASC – EN 301 549:2024, which is a properties-of-the-underlying-code standard. An overlay injected on top of an inaccessible page does not change what the underlying code does; it does not produce conformity.
After the U.S. FTC fined overlay vendor accessiBe $1,000,000 in 2025 for unsupported claims that its product made websites "fully and immediately compliant," leaning on an overlay as your answer to a federal accessibility regulation is the weakest possible position. The accessibility statement requirement alone — which must describe actual conformance level and known gaps — can only be filed honestly after a real audit has been done and the gaps addressed. An overlay vendor's dashboard cannot tell you that.
What about the accessibility statement requirement in particular?
The published accessibility statement is a new, distinct obligation under SOR/2025-255 — applying to the largest entities (500+ employees) — that doesn't have a direct equivalent under the AODA. It must describe: the standard the organization is targeting, any known non-conformances, and the feedback and remediation process. This means covered organizations need to know their actual conformance status — which requires a real audit — and then publish that status publicly. A generic "we are committed to accessibility" sentence is not an accessibility statement in the regulatory sense.
For organizations already producing a VPAT (Voluntary Product Accessibility Template) or an ACR (Accessibility Conformance Report) for procurement purposes, the accessibility statement can draw from that documentation. For context on how an ACR differs from an AODA compliance report, see our ACR vs VPAT explainer.
What this means for your business
If you are a federally regulated Ontario organization with 100+ employees, you are now managing three overlapping accessibility obligations: the ACA (including SOR/2025-255's digital requirements, with a 2028 deadline), the AODA (web standard for 50+ employees, compliance report December 31, 2026), and ADA exposure if you sell into the United States. The cleanest way through all three is the same: one well-built, rigorously tested, documented website conforming to WCAG 2.2 AA — the bar that meets or exceeds each of them on the web content dimension.
If you are a provincially regulated Ontario business, SOR/2025-255 is not your immediate regulation — your date is December 31, 2026 under the AODA. But the federal standard signals the direction Canada's web accessibility floor is moving, and the accessibility statement obligation is a useful model for the kind of documentation that supports a good-faith position under any regime.
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PassProof is a remote-first accessibility-engineering studio serving Ontario. General information, not legal advice.