Three accessibility frameworks apply to Canadian organizations: AODA (Ontario), SWA (federal Treasury Board), and the Accessible Canada Act (federal). Vendors need to know which applies to them and what to design to.
**AODA (Ontario)** — provincial law, applies to Ontario-incorporated orgs above size thresholds, references WCAG 2.0 AA, enforced by Accessibility Directorate of Ontario.
**SWA (federal TBS)** — federal policy, applies to GoC websites, references WCAG 2.0 AA with TBS guidance moving to 2.1 AA, enforced by TBS internal accountability.
**Accessible Canada Act (federal law, 2019)** — applies to federally-regulated entities (banks, telcos, federal-regulated transport, federal contractors meeting the test), references WCAG 2.1 AA in CRTC and Accessibility Commissioner guidance.
The practical answer for any Canadian vendor: design to **WCAG 2.1 AA**. That clears all three with margin.
All three frameworks reference WCAG: AODA cites WCAG 2.0 AA, SWA cites WCAG 2.0 AA (with TBS guidance moving to 2.1 AA), and ACA-aligned guidance cites WCAG 2.1 AA. The substantive accessibility requirements are nearly identical. The differences are in scope (which orgs are bound), enforcement (who can act), and reporting (what you have to file).
**Reporting:** AODA requires periodic accessibility-compliance reports filed with Ontario's Accessibility Directorate. ACA requires regulated entities to publish accessibility plans and progress reports. SWA has internal TBS reporting only.
**Enforcement:** AODA has provincial enforcement powers including administrative penalties. ACA has Accessibility Commissioner authority. SWA enforcement is internal to the federal government.
**Scope of 'web':** ACA explicitly covers ICT broadly (not just web). SWA is web-specific. AODA covers web plus a broader Information & Communication Standard.
All three potentially apply. Design to WCAG 2.1 AA and you're covered.
On the substantive accessibility requirement: yes. You may still have separate reporting/filing obligations under AODA or ACA depending on your status.
Federal contractors meeting the federal works/undertakings test do. Most private-sector federal vendors do — check with counsel for your specific situation.
AODA's jurisdiction is Ontario-incorporated organizations meeting size thresholds. A federally-incorporated vendor with operations only outside Ontario is generally outside AODA's reach (but may still face federal ACA obligations).