Key takeaways
Under the AODA, Ontario businesses and non-profits with 50 or more employees must make their websites meet WCAG 2.0 Level AA, apart from live captions and pre-recorded audio descriptions, and the organization that controls the site is responsible even if a contractor built it. Businesses with 20 or more employees must file an accessibility compliance report by December 31, 2026. On Shopify, test the real templates with a keyboard, a screen reader and automated tools, fix the path to purchase first and keep a record.
- Ontario businesses with 50 or more employees must meet WCAG 2.0 Level AA on their websites, except live captions and pre-recorded audio descriptions.
- Businesses with 20 or more employees must file an accessibility compliance report by December 31, 2026, and every three years after.
- The business that controls the site is responsible, even when an agency or app vendor built it.
- Test real templates with a keyboard, a screen reader and automated tools; scores alone don’t establish compliance.
- Selling to EU consumers can bring in the European Accessibility Act, with an exemption for microenterprises.
Who must do what in Ontario
The Accessibility for Ontarians with Disabilities Act sets different obligations by organization size. For businesses and non-profits, the two that concern an online store are the website requirement and the compliance report.
| Employees | Accessibility compliance report | Website must meet WCAG 2.0 Level AA |
|---|---|---|
| 20 to 49 | Yes: due December 31, 2026, then every three years | No |
| 50 or more | Yes: due December 31, 2026, then every three years | Yes, for websites and web content published after January 1, 2012 |
The website requirement excludes two WCAG success criteria: live captions (1.2.4) and pre-recorded audio descriptions (1.2.5). Captions for pre-recorded video are still required.
Your agency built it; you still own it
Ontario’s guidance is direct: the organization that controls the website, either directly or through a contractual relationship, must meet the accessibility requirements. A theme developer, an app vendor or an agency can do the work, but the obligation stays with the business.
Put accessibility into the contract and the acceptance criteria rather than assuming it. Name the standard, WCAG 2.0 Level AA at minimum, say which templates and flows will be tested, and agree what evidence is handed over at launch and who fixes defects found later. The same applies to every app that adds something shoppers see.
What WCAG 2.0 AA means on a Shopify store
WCAG is written in general terms, so translate it into the parts of a store where shoppers get stuck.
- Keyboard access: menus, drawers, filters, variant pickers, quantity controls and carousels must work without a mouse, with no keyboard trap.
- Visible focus: someone using a keyboard must be able to see where they are on every page.
- Contrast: body text at a contrast ratio of at least 4.5:1, including sale prices, badges and text over images.
- Text alternatives: meaningful alt text for product images that carry information, and empty alt text for decoration.
- Forms: labelled fields and error messages that say what went wrong, for newsletter sign-up, contact forms and account pages.
- Structure: one clear page heading, logical headings below it and link text that makes sense out of context.
- Media: captions for pre-recorded video with speech, and a way to pause video or carousels that move on their own.
Test the templates customers actually use
Test real pages rather than a theme demo: the home page, a collection with filters applied, a product with variants, the cart drawer, search, customer account pages and the path into checkout. Use each on a phone as well as a desktop.
Combine three methods. A keyboard-only pass finds focus and trap problems quickly. A screen reader, such as VoiceOver on a Mac or iPhone or NVDA on Windows, shows whether labels, announcements and headings make sense. Automated tools such as Lighthouse or axe catch contrast, missing labels and similar issues at scale, but they cannot judge whether alt text is meaningful or whether a flow is usable.
Shopify’s Theme Store sets useful floors for themes it lists: an average Lighthouse accessibility score of at least 90 across home, collection and product pages, keyboard access to every part of a page including dropdown navigation, visible focus states, 4.5:1 contrast for body text and touch targets of at least 24 by 24 CSS pixels. A theme that meets those floors can still fail once it is customized, filled with content and extended with apps.
Apps and content are part of the site
Many accessibility defects on Shopify stores arrive through apps: review widgets, pop-ups, chat, quizzes, bundles and upsell blocks. Test each one in place and ask vendors for their own testing results. An app that cannot be closed with a keyboard or that traps focus in a pop-up can block a purchase.
Content editors matter as much as developers. Size charts delivered as images, promotional banners with text baked in and PDFs without structure all create barriers. Give editors a short checklist: alt text, headings, link text and no important information inside images alone.
An overlay widget does not change the underlying templates. WCAG applies to the page itself, so test and fix the page rather than adding a layer on top.
Selling into the EU adds the European Accessibility Act
Since June 28, 2025, the European Accessibility Act has applied to e-commerce services provided to consumers in the European Union. Its definition of a service provider includes anyone who makes offers to provide such a service to consumers in the Union, which can include a Canadian store selling to EU customers.
Microenterprises providing services are exempt: businesses with fewer than 10 people and an annual turnover or annual balance sheet total of no more than €2 million. If you sell to EU consumers and are above that size, include the Act in your accessibility plan and get advice on what applies to you.
Filing the 2026 compliance report
Ontario businesses and non-profits with 20 or more employees file an accessibility compliance report every three years through the government’s Accessibility Compliance Reporting Portal. The current deadline is December 31, 2026, and the report confirms that you have met your current requirements under the AODA.
The report covers more than the website, so start collecting evidence now: the audit results for your store, the fixes made and their dates, your accessibility policies and training records. Being able to show the testing behind an answer is more useful than a single score.
Fix in order of harm
Start with anything that stops a purchase: a variant picker that can’t be reached by keyboard, an add-to-cart button without a name, a cart drawer that traps focus or errors that are never announced. Then fix navigation, search and filters, then content.
Keep it fixed. Add an accessibility check to every theme change and app installation, re-test the key templates after each release and keep a dated log. Accessibility regresses quietly when nobody owns it.
An accessibility checklist for this year
- Confirm your employee count and which obligations apply, including the December 31, 2026 report.
- Test home, collection, product, cart, search, account and the checkout path with a keyboard and a screen reader.
- Run automated checks on the same templates and log every issue with a severity.
- Test each storefront app in place and ask vendors for their accessibility testing.
- Fix purchase blockers first, then navigation and filters, then content.
- Give content editors an alt-text, headings and link-text checklist.
- Add accessibility acceptance criteria to contracts with agencies and app vendors.
- Keep a dated record of audits and fixes for your compliance report.
Frequently asked questions
Does the AODA apply to my Shopify store?
If your business or non-profit has 50 or more employees, its website must meet WCAG 2.0 Level AA for content published after January 1, 2012, except live captions and pre-recorded audio descriptions. With 20 or more employees, you must also file an accessibility compliance report by December 31, 2026.
Is my Shopify theme accessible out of the box?
Themes in Shopify’s Theme Store must meet minimum accessibility requirements, including an average Lighthouse accessibility score of at least 90, keyboard access and visible focus. Your store’s compliance still depends on your customizations, apps and content, so test the live templates.
Will an accessibility widget make my store compliant?
An overlay widget doesn’t change the underlying templates, and WCAG applies to the page itself. Test the store with a keyboard, a screen reader and automated tools, and fix the issues in the theme, apps and content.
Who is responsible if our agency built the site?
Ontario’s guidance says the organization that controls the website, either directly or through a contractual relationship, must meet the requirements. Your agency can do the work, but the obligation stays with your business, so write accessibility into the contract.
Sources and further reading
- Government of Ontario: how to make websites accessible
- Government of Ontario: accessibility rules for businesses and non-profits
- Government of Ontario: completing your accessibility compliance report
- W3C: Web Content Accessibility Guidelines 2.0
- Shopify developer documentation: Theme Store requirements
- EUR-Lex: European Accessibility Act, Directive (EU) 2019/882
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