Skip to content
Vayle

Accessibility

WCAG 2.0 vs 2.2 in Ontario: The Law vs Best Practice

Ontario's legal floor is WCAG 2.0 AA - but smart businesses build to 2.2 AA. Here's what each version adds and why the gap matters.

· 2 min read

Editorial poster: WCAG 2.0 (legal floor) progressing to WCAG 2.2 (best practice).

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:

  1. 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.
  2. 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.
  3. 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 Vayle

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

If you want a second pair of eyes on your site, send it to me and I will tell you what I would fix first and what it would cost, the same working day.

Related guides


Vayle is a remote-first accessibility-engineering studio serving Ontario. Accessibility-engineering guidance, not legal advice; we work alongside your counsel.