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WCAG 2.2 vs AODA

WCAG 2.2 (Web Content Accessibility Guidelines 2.2, Global (referenced by most national accessibility laws), 2023) and AODA (Accessibility for Ontarians with Disabilities Act, Ontario, Canada, 2005) are two of the most-referenced accessibility frameworks in digital compliance. This guide compares them side by side — jurisdiction, scope, conformance approach, penalties, and how a single audit can cover both simultaneously.

Riya Krishnan · IAAP CPWA · NVDA-certified tester3 min readPublished · Updated

What is WCAG 2.2?

WCAG 2.2 (pronounced 'wuh-cag 2.2') is the World Wide Web Consortium's globally adopted standard for web accessibility, published October 2023, defining 87 testable success criteria organised under four principles: Perceivable, Operable, Understandable, Robust.

Maintainer

World Wide Web Consortium (W3C)

Jurisdiction and enforcement

Global (referenced by most national accessibility laws). Referenced by ADA, EAA, Section 508, AODA and many others.

What is AODA?

The Accessibility for Ontarians with Disabilities Act (AODA) is a 2005 Ontario law that mandates accessibility for the public, private, and not-for-profit sectors operating in Ontario — including a digital requirement that public-facing websites conform to WCAG 2.0 Level AA.

Maintainer

Government of Ontario

Jurisdiction and enforcement

Ontario, Canada. Accessibility Directorate of Ontario.

WCAG 2.2 vs AODA — the key differences

The principal difference is jurisdictional: WCAG 2.2 applies in Global (referenced by most national accessibility laws), while AODA applies in Ontario, Canada. WCAG 2.2 is maintained by World Wide Web Consortium (W3C); AODA is maintained by Government of Ontario. The standards differ on scope, conformance grading, and penalty structure — but a well-designed accessibility programme can satisfy both simultaneously by adopting the strictest applicable requirement and cross-mapping findings.

Scope

WCAG 2.2 covers: Web content, Mobile web, Web applications, PDF documents (with PDF/UA), EPUB publications. AODA covers: Public-facing websites and web content, Documents (PDF/Word), Customer-service communications.

Penalties

WCAG 2.2: United States: civil penalties under ADA Title III; demand letters typically settle at $3,000–$25,000; litigated cases can reach $50,000+ in attorney-fee awards. AODA: C$50,000/day for individuals or unincorporated organisations.

How to comply with both at once

Adopt the stricter applicable conformance level — typically WCAG 2.2 Level AA — as your engineering baseline. Audit against that baseline once, then cross-map findings to both WCAG 2.2 and AODA specific requirements. A single Accessibility Conformance Report (ACR) using VPAT 2.5 INT can document both.

When you might need just one

If you operate exclusively in Global (referenced by most national accessibility laws) and have no cross-border procurement exposure, you may only need WCAG 2.2. The same applies in reverse for AODA. For organisations selling cross-border, into the EU or US public sector, the safer default is to plan to both simultaneously.

Sources

FAQ

Frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

  • Is WCAG 2.2 stricter than AODA?

    Neither standard is uniformly "stricter" — they cover different regulatory domains. WCAG 2.2 is more prescriptive about web content; AODA about public-facing websites and web content. For organisations exposed to both, a unified WCAG 2.2 AA baseline typically satisfies the technical requirements of both.

  • Can a single audit satisfy WCAG 2.2 and AODA?

    Yes. Both standards ultimately reference WCAG-aligned criteria. A combined audit with cross-mapped findings can produce documentation acceptable to both regulators.

  • Which jurisdictions enforce WCAG 2.2?

    Global (referenced by most national accessibility laws). Referenced by ADA, EAA, Section 508, AODA and many others.

  • Which jurisdictions enforce AODA?

    Ontario, Canada. Accessibility Directorate of Ontario.

  • What happens if I am not compliant with WCAG 2.2?

    United States: civil penalties under ADA Title III; demand letters typically settle at $3,000–$25,000; litigated cases can reach $50,000+ in attorney-fee awards European Union: fines under EAA national transpositions vary by member state, up to €1,000,000 in some jurisdictions Canada (AODA): C$50,000–C$100,000 per day per violation in Ontario

  • What happens if I am not compliant with AODA?

    C$50,000/day for individuals or unincorporated organisations C$100,000/day for corporations

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