Look at the last promo you put on your homepage. The "SUMMER SALE - 40% OFF" splashed across the hero. The price list a designer sent back as a tidy graphic. The store hours sitting inside a nice branded rectangle. To you they read as text, because your eyes turn the pixels back into words without effort. To a screen reader, and to a customer who zooms the page to 300%, a lot of that "text" is not text at all - it is a picture of text, and the difference is exactly the kind of thing an Ontario business trips over without ever noticing. WCAG has a name for it, and unlike some of the newer rules, this one already sits inside the standard the province mandates.
Key facts
- 1.4.5 Images of Text is a Level AA success criterion in WCAG (Web Content Accessibility Guidelines) 2.0, published by the W3C in 2008. It says: when the technology can produce the same visual result, use real text rather than an image of text to present information (W3C).
- There are two narrow exceptions: a logotype (text that is part of a logo or brand name), and text the user can fully customize, or where a specific presentation is essential to the meaning (W3C).
- Ontario's IASR (Integrated Accessibility Standards Regulation, O. Reg. 191/11, s.14) mandates WCAG 2.0 Level AA - which includes 1.4.5 - for organizations with 50 or more employees (ontario.ca).
- The next ACR (Accessibility Compliance Report) is due December 31, 2026 for organizations with 20 or more employees (ontario.ca).
- AODA (Accessibility for Ontarians with Disabilities Act) has no private right of action; the individual route is a complaint to the HRTO (Human Rights Tribunal of Ontario) under the Ontario Human Rights Code (ontario.ca).
What counts as an "image of text," and why does it fail?
Real text is the characters your browser draws from HTML and styles with CSS. You can select them with your cursor, a screen reader can read them, a translation tool can translate them, and they stay sharp at any zoom. An image of text is a picture - a JPG, PNG, or a flattened graphic - with the letters painted into the pixels. It looks identical on your screen and behaves nothing like text underneath.
The usual offenders in a small-business site are predictable:
- A hero banner with the headline and offer baked into the image.
- A price list, menu, or table of hours exported as a single graphic because it "looked cleaner."
- An infographic or promo tile with paragraphs of copy inside it, often the same asset posted to social.
- A testimonial or quote saved as a screenshot.
Here is why that breaks for real people. A screen reader reads text, not pixels, so without help the message is simply silent. Someone with low vision who enlarges the page keeps real text crisp, but an image of text turns to a blur - the very problem behind text resize and reflow. A person who needs a particular font, wider spacing, or a high-contrast theme can restyle real text and cannot restyle your JPG. And browser translation, which quietly serves a lot of Ontario's customers, works on text and skips the words trapped in an image. A photo of your storefront is fine - the rule is about text presented as an image, not about having images at all.
Does Ontario actually require this?
This is where I usually add a caveat, because several of the criteria worth writing about are WCAG 2.2 additions that Ontario does not mandate yet. Not this one. 1.4.5 is Level AA in WCAG 2.0, which is the exact version the IASR points at. For a covered organization, presenting information as a picture of text when real text would do sits inside the standard the province already requires, not some future best-practice bar.
The honest flip side is that the rule is narrower than it first sounds, so do not over-correct into a panic. Your logo is fine; a logotype is explicitly exempt. Text that is genuinely customizable, or where the precise visual presentation is essential to the meaning, is exempt too. What is left is the ordinary stuff - your offer, your prices, your hours, your body copy - which should be real text. And the point of getting it right is not the criterion number. Nobody files an HRTO complaint citing "1.4.5"; a real customer using a screen reader hits your "SALE" banner or your hours and cannot read a word, and that person is who the complaint process is about.
How do you find it and fix it?
Finding it is free and takes a minute. Try to select the words with your cursor. If you can highlight the letters one by one, it is real text; if the whole block selects as a single image, the text is baked in. Then zoom the page to 200-400% and watch what blurs, and run a screen reader over the section to hear what actually gets announced. A scanner will catch some of this, but the judgment call of "is this an image of text or a legitimate graphic" is one of the reasons a real audit beats a raw scan.
Fixing it is a build decision, not a widget. Rebuild the banner as real HTML text set over a background image or a CSS gradient, so the headline is an actual heading styled with CSS - web fonts give you any typeface you want without flattening letters into pixels. Where a genuinely graphical asset is unavoidable, give it accurate alt text and make sure the contrast holds up - but treat alt text as a floor, not the cure. It lets a screen reader announce the message, yet it still will not zoom cleanly, restyle for the reader, or translate. An accessibility overlay cannot turn a JPG's pixels back into text either; this lives in your markup and your stylesheet, which is why source-level work is what holds up.
When you make the change, keep a dated note of what you swapped from image to text. That record, folded into an Accessibility Conformance Report, is worth far more than a badge if a complaint ever lands.
Want to know which of your banners a screen reader goes silent on before a customer does? Free Vayle Report, about 30 seconds: vayle.art. It detects overlay widgets, surfaces real WCAG failures, and tells you exactly what legally applies to your organization in Ontario. No obligation.
Vayle is a remote-first accessibility-engineering studio serving Ontario. General information, not legal advice.