Why PDFs Matter for AODA Compliance
If your business shares documents online — price lists, application forms, reports, menus, or policy documents — there is a good chance those files are PDFs. And if those PDFs are not accessible to people with disabilities, your business may already be offside with Ontario law.
Under the Accessibility for Ontarians with Disabilities Act (AODA) and specifically Ontario Regulation 191/11 (the Integrated Accessibility Standards Regulation), organizations in Ontario are required to make their web content and digital documents accessible when those documents are published on a public-facing website. For most private-sector businesses with one or more employees, these requirements have already come into effect. Ignoring them is not a neutral choice — it carries real risk.
The good news is that checking your PDFs for accessibility problems is easier than you think, and you can start today without creating an account, downloading software, or hiring a consultant.
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What "Accessible PDF" Actually Means
An accessible PDF is one that can be read and understood by people using assistive technologies such as screen readers — software used by people who are blind or have low vision to have text read aloud to them.
A PDF that looks fine on screen can be completely unreadable to a screen reader if it was created by simply scanning a printed page, or exported without proper formatting. Common problems include:
- No document tags — the underlying structure that tells a screen reader what is a heading, a paragraph, or a list
- Images with no alt text — visual content that has no written description
- Unreadable reading order — content that appears in the wrong sequence when read aloud
- Non-searchable text — scanned documents where the content is treated as a flat image
- Missing document title — a basic metadata field that helps users identify the file
Each of these issues creates a real barrier for a real person trying to access your content.
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What Ontario Law Actually Requires
Ontario Regulation 191/11, Section 14 requires that organizations make new or significantly revised internet and intranet websites conform to WCAG 2.0 Level AA, which includes documents posted to those sites. Section 15 extends that requirement to web content.
For documents, the practical interpretation is this: if you are posting a new PDF to your website after your compliance deadline has passed, that document should meet accessibility standards. Older documents are generally grandfathered unless they are actively used to provide a core service — such as an application form or a service request document.
The Canadian Human Rights Act and the Ontario Human Rights Code run parallel to AODA. Even where AODA provides exceptions, those codes require that you not discriminate on the basis of disability. Posting a service form that a person cannot use independently is a form of barrier that can trigger a complaint.
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How to Check Your PDF Right Now — No Account Needed
The most practical free tool available is the Adobe Acrobat Accessibility Checker, which is built into the free Adobe Acrobat Reader. However, if you want a fast browser-based check without installing anything, the tool you want is PAC 2024 (PDF Accessibility Checker), developed by the Swiss organization Access for All. It is free to download and requires no registration.
Steps to Run a Basic Check
- Download PAC 2024 from the official site (pdfua.foundation) — it is a small, free Windows application
- Open your PDF by dragging it into the PAC window
- Click "Check" and wait a few seconds
- Review the results — PAC categorizes issues by severity and shows you exactly which elements failed
- Use the preview panel to see how a screen reader would interpret your document
You do not need to understand every technical detail. Even a basic scan will show you whether your document has tags, a title, and alt text on images — the three most critical elements for basic accessibility.
What to Do With the Results
- Zero errors — your document is likely in good shape; review visually for reading order
- Minor issues — add missing alt text or a document title; this can often be done in Microsoft Word before exporting to PDF
- Major issues — consider recreating the document from scratch with accessibility in mind, or using a Word template known to produce accessible exports
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The Real Cost of Doing Nothing
The AODA Compliance Reporting process requires businesses with 20 or more employees to file accessibility compliance reports. Inspectors appointed under the AODA have authority to conduct audits and issue compliance orders. Fines for corporations can reach $100,000 per day for ongoing violations.
Beyond enforcement, consider this: approximately one in five Canadians lives with a disability. An inaccessible PDF is a closed door to a customer who may simply take their business elsewhere — or file a complaint.
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Take the First Step Today
You do not need a big budget or a technical background to start improving your PDF accessibility. Run a free check on your most-visited documents this week using PAC 2024 or Adobe's built-in checker. If you want a broader picture of how your entire website and digital content stack up against AODA requirements, run a free AODA accessibility scan on your website today — no signup, no obligation, and results in minutes. Small fixes made now protect your business, serve your customers better, and keep you on the right side of Ontario law.