Why Ontario Restaurants Need to Think About Digital Accessibility
If you run a restaurant in Ontario, you're probably focused on menus, staff scheduling, and keeping customers happy at the table. But there's another area that inspectors and auditors are increasingly paying attention to: your digital presence. Specifically, whether your website, online ordering system, and downloadable menus are accessible to customers with disabilities.
This isn't a niche concern. Over 2.6 million Ontarians live with some form of disability, and many of them order food online, browse menus before visiting, or rely on assistive technology to interact with your website. Under the Accessibility for Ontarians with Disabilities Act (AODA) and Ontario Regulation 191/11 (the Integrated Accessibility Standards Regulation), businesses have clear legal obligations — and restaurant owners are not exempt.
What the Law Actually Requires
Ontario Regulation 191/11 sets out the Information and Communications Standards that apply to organizations with one or more employees in Ontario. For most restaurants, the key requirements include:
- Making new and significantly updated web content conform to WCAG 2.0 Level AA (Web Content Accessibility Guidelines)
- Ensuring that any documents you publish publicly — including menus — are accessible or available in an accessible format upon request
- Providing accessible online forms and ordering processes
Private sector businesses with 1 to 49 employees had an initial deadline of January 1, 2021, to meet these standards. Larger organizations were required to comply even earlier. If you haven't addressed this yet, you are technically out of compliance.
The Problem with Menu PDFs
This is where many restaurants unknowingly fall short. A scanned PDF of your printed menu — essentially a photo of a document — is almost completely inaccessible to someone using a screen reader. Screen readers are software tools used by people who are blind or have low vision. They read text aloud, but they cannot interpret an image.
What makes a menu PDF inaccessible?
- It was created by scanning a printed page
- It has no tagged structure (headings, lists, reading order)
- Images have no alternative text
- Font contrast is too low for people with low vision
- It cannot be navigated by keyboard alone
The fix doesn't have to be complicated. You can create a properly tagged PDF using tools like Adobe Acrobat, or better yet, publish your menu directly as HTML text on your website, which is naturally more accessible and easier to update.
Online Ordering: Where Accessibility Problems Multiply
If you use a third-party ordering platform like SkipTheDishes, DoorDash, or Uber Eats, those companies are responsible for the accessibility of their own platforms. However, if you have your own website with integrated ordering, you are responsible for its accessibility.
Common issues include:
- Buttons that aren't labeled — a screen reader user hears "button" with no description of what it does
- Forms without proper field labels — someone using assistive technology can't tell what to type where
- Error messages that only use colour — a person who is colour blind may not notice that a field is marked red as an error
- Pop-ups and modals that trap keyboard users — someone navigating without a mouse can get stuck
Each of these is a barrier that could prevent a customer from completing an order — and each one is a potential compliance issue under WCAG 2.0 Level AA.
What Inspectors and Auditors Look For
The Accessibility Directorate of Ontario conducts compliance audits and can request documentation showing your accessibility efforts. While enforcement has historically focused on larger organizations, small businesses are increasingly being reviewed, particularly following customer complaints.
Auditors typically look for:
- A published Accessibility Policy on your website
- A multi-year accessibility plan (required for businesses with 20+ employees)
- Evidence that web content meets WCAG 2.0 Level AA
- Accessible document formats available upon request
- Staff training on accessibility
Even if a formal audit never reaches your door, a customer complaint to the Directorate can trigger a review. Beyond legal risk, inaccessible digital experiences mean lost business from a significant portion of the population.
Practical Steps to Get Started
You don't need to rebuild your website overnight. Start with these manageable actions:
- Audit your current website using a free tool like WAVE or Axe
- Replace scanned menu PDFs with tagged PDFs or HTML menus
- Add alt text to all images on your site
- Check colour contrast using the WebAIM Contrast Checker
- Review your online ordering flow by trying to complete it using only a keyboard
If your website was built by an agency or freelancer, ask them directly about WCAG 2.0 Level AA compliance. It's a reasonable question and one they should be able to answer.
Take the First Step Today
Accessibility improvements don't have to be overwhelming or expensive, especially when you know where to focus. Run a free automated AODA accessibility scan on your restaurant's website today to identify your biggest gaps. It takes minutes, costs nothing, and gives you a clear starting point for bringing your digital presence into compliance — protecting your business and welcoming every customer who wants to order from you.