Rules

Do Ontario businesses need captions on their videos? The AODA rules in plain English

6 min readBy Arian Khavari, Founder

Most businesses find out about Ontario's accessibility rules when a customer complains or a procurement form asks. If you put video on your website, and most of our clients do, here is what the Accessibility for Ontarians with Disabilities Act asks of you, in plain English, straight from the government's own guidance and the standard it points to.

Viterno Group guide to AODA caption requirements for Ontario business videos
Viterno Group guide to AODA caption requirements for Ontario business videos

The short answer

If your organization has 50 or more employees, or is a designated public sector organization, the videos on your public website need captions. That has been the rule since January 1, 2021, under the AODA's website requirements.

If you have fewer than 50 employees, the website rule does not apply to you. We would still caption every video, because plenty of people scroll with the sound off, and a muted video with no words on screen says nothing.

One thing first: this is a plain-English summary of public guidance, not legal advice. If accessibility is part of a contract, a tender or a complaint, check with your lawyer.

Who has to comply

The Ontario government's page on how to make websites accessible (updated September 21, 2026) sets out who the website rules cover.

You areWebsite rule applies?
A business or non-profit with 50 or more employeesYes
A designated public sector organizationYes
A business with fewer than 50 employeesNo

The organization that controls the website has to meet the requirements, whether it controls the site directly or through a contract. If an agency built and runs your site, the responsibility is still yours.

The rules apply to websites and web content published after January 1, 2012. Content published before that date is not covered.

What the standard actually requires

The AODA does not write its own technical rules for websites. It points to an international standard, the Web Content Accessibility Guidelines, and requires WCAG 2.0 Level AA, with two exemptions:

  • 1.2.4, live captions. You do not have to caption live video in Ontario.
  • 1.2.5, pre-recorded audio description. The Level AA version of audio description is exempt.

Everything else at Levels A and AA applies, and for video that means two rules in particular.

Rule one: captions on pre-recorded video

WCAG success criterion 1.2.2 is short: captions are provided for all pre-recorded audio content in synchronized media. In practice that means any video with sound on your website.

Three details catch people out.

Captions are timed. A transcript under the video is not a caption. The words have to appear in sync with the speech.

Captions carry more than dialogue. The W3C's guidance says captions include who is speaking and the sounds that carry meaning: a door slamming in a skit, laughter, a song that sets up the joke. If someone watching without sound would miss it, it belongs in the caption.

Burned-in captions count. The W3C lists open captions, the kind that are always visible because they are part of the video, as a sufficient technique. That is how almost every Reel and TikTok is captioned anyway, so a social cut placed on your website can already meet this rule if the captions are complete and accurate.

There is one exception: a video that presents nothing more than text already on the page, and is clearly labelled as an alternative to that text, does not need captions. Very few marketing videos qualify.

Rule two: the audio description trap

This is the one most businesses miss. Ontario exempts the Level AA audio description rule, so people assume audio description is off the table entirely. It is not.

WCAG success criterion 1.2.3 is Level A, and it still applies. Pre-recorded video needs either an audio description of what is shown or a full text alternative that describes what happens on screen and in the audio.

The good news is a built-in exception: if everything important in the picture is already said out loud in the audio, nothing extra is needed. A founder talking to camera usually passes. A silent product montage with music and on-screen text does not, because someone who cannot see it gets the music and nothing else.

The practical fix is cheap: either have the voiceover say what the screen shows, or publish a short text description next to the video.

What about Instagram, TikTok and YouTube?

The Ontario guidance does not mention social media by name. It talks about your public websites and web content, and about the organization that controls them.

Here is how we would read that, as video people rather than lawyers:

  • A video embedded on your own website is your web content. Caption it, and meet the audio description rule, whatever platform it is hosted on.
  • Posts that live only on Instagram, TikTok or YouTube are on platforms you do not control. The guidance does not say whether they are covered, so we would not assume they are exempt.
  • The cheapest answer is the same everywhere: caption every video once, in the edit, and every copy of it is covered.

If you need certainty for a specific case, ask a lawyer rather than relying on an agency's reading.

A caption checklist for business video

This is what we check before a video goes out. You can use it without us.

  1. Every spoken word is on screen, in sync. Speed the video up and the captions must keep up.
  2. Names, numbers and addresses are correct. Automatic captions often trip on exactly these, and they are the words a viewer most needs. Read them yourself.
  3. Meaningful sounds are captioned. Laughter, a phone ringing, a song that matters to the joke.
  4. The speaker is clear when more than one person talks, by placement on screen or a name.
  5. Captions are readable on a phone: big enough, high contrast, and clear of the platform's buttons at the bottom and side of the screen.
  6. The picture is described in the voiceover or in text next to the video if it carries information the audio does not.
  7. The website copy has its own captions. If you upload a different cut to your site, check that one too.

How we caption at Viterno

Every video we deliver is captioned for viewers watching with the sound off. The captions are part of the edit, so they travel with the video wherever it is posted, including your website. If you are an Ontario organization with 50 or more employees, run the checklist above on anything you embed, our videos included, and do not skip step six.

If you want to see how captions fit the rest of a short-form video, our glossary defines the terms, and our post on how Reels reach people who do not follow you shows why the first two seconds, words included, decide whether anyone stays. For the full service, see video marketing in Toronto and our content creation agency page.

Frequently asked questions

Do Ontario businesses have to caption their videos?

Businesses and non-profits with 50 or more employees, and designated public sector organizations, must make public websites and web content meet WCAG 2.0 Level AA under the AODA. That includes captions on pre-recorded video on those websites. It has applied since January 1, 2021.

Are live videos covered by the AODA caption rule?

No. Ontario exempts WCAG success criterion 1.2.4, live captions, from its website requirements. Pre-recorded video still needs captions.

Do burned-in captions on Reels and TikToks count?

The W3C lists open captions, the always-visible kind built into the video, as a sufficient way to meet the captions rule. They need to be complete, in sync and accurate, including who is speaking and meaningful sounds.

Do I need audio description for my videos in Ontario?

Ontario exempts the Level AA audio description rule, but the Level A rule still applies: provide audio description or a text alternative for pre-recorded video, unless everything important in the picture is already said in the audio. A talking-head video usually passes; a silent montage usually does not.

Does the AODA apply to social media posts?

The Ontario government's guidance does not name social media. It covers public websites and web content an organization controls. A video embedded on your own website is your web content, so caption it there, and captioning every video in the edit covers every platform at once.

See the client case studies behind this, one page per video →

How we do this for clientsShort-form video services →Strategy, filming, editing and posting, done for you.

Want this done for you?

We run the whole content engine for Toronto brands: strategy, filming, editing and posting. 300M+ views, all organic.

Book a discovery call → Or get a free Breakdown of your Reels