Manitoba Website Accessibility Requirements for Small Business

The rule in one paragraph

The Accessibility for Manitobans Act lets the province set accessibility standards that organizations must follow. One of them, the Accessible Information and Communication Standard Regulation, covers how you share information: in person, in print and online. For websites, it points to WCAG 2.1 Level AA. WCAG (Web Content Accessibility Guidelines) is the international rulebook for making websites usable by people with disabilities, including people who are blind, have low vision, are Deaf or hard of hearing, or can't use a mouse. Level AA is the middle of its three levels, and the one most laws use.

Does it apply to your business?

Almost certainly, yes. The regulation came into force on May 1, 2022 and was phased in by sector. Businesses and non-profits came last, three years later:

• May 1, 2023: the Manitoba government.
• May 1, 2024: public sector organizations, large municipalities, libraries and schools, colleges and universities.
• May 1, 2025: businesses and non-profits with one or more employees in Manitoba, and small municipalities.

There is no small-business exemption. The province names shops, restaurants and professional services as examples. Size only changes the paperwork: if you have 50 or more employees, you also have to write down your accessibility and training policies and let the public know they're available.

What your website has to meet

The website rules have a few parts. Your web content must meet WCAG 2.1 Level AA when either of these is true:

• It was published on or after May 1, 2025.
• It's needed for people to get your goods or services, such as a booking page, a quote form, an online store or your contact details.

In practice, that means anything new you've added since May 2025, plus the pages that matter most to customers, however old they are.

Web applications follow a separate rule. A web application is software people use in a browser, such as a customer portal or online ordering system. One that's launched or gets a significant update on or after May 1, 2025 must also meet WCAG 2.1 AA. The regulation defines a significant update as one that changes what the app does, who uses it or what it's for.

Two limits worth knowing. For businesses, the website rule covers your public website, not your staff intranet. And according to the province, mobile apps from an app store aren't covered, only apps that run in a web browser. Accessibility is still good practice for both.

The exceptions, and how narrow they are

Web content and web apps don't have to meet WCAG 2.1 AA if:

• It isn't technically feasible.
• The technology needed isn't readily available.
• It would cause undue hardship to your organization.
• You don't have direct control over the content, for example a widget run by another company.
• The content is a product label or other product information.

Don't lean on these lightly. The province's own guidance says inconvenience, preferences or some costs don't usually count as undue hardship. It also says that if you don't have the skills in-house, you still have to comply, using an outside web developer or designer if needed.

It's not just the website

The standard has a few other requirements every covered business has to meet. Several of them show up on your website:

• Tell people they can ask for information in an accessible format, such as large print, a screen-reader-friendly document or plain language, or through a communication support, such as captioning or sign language.
• When someone asks, talk with them about what would work, then provide it in a timely way. You can't charge them more than anyone else.
• Have a feedback process for comments and complaints about the accessibility of your information. It has to suit people with disabilities. Document what you did in response, and share that record if someone asks.
• Train the people who deal with the public, look after your website, buy your technology or set your accessibility policies. Training has to cover how to spot and remove barriers, how to provide accessible formats, and a review of The Human Rights Code, the Act and the regulation.

A simple way to cover the first and third points online is an accessibility page linked from your footer. Say that information is available in other formats on request, and give more than one way to reach you, such as email, phone and a form. Then keep a simple log of each request or piece of feedback and what you did about it.

Who enforces it, and what happens if you don't comply

The province's Accessibility Compliance Secretariat monitors and enforces the standard. Its stated approach is to start with constructive feedback and a plan to fix problems, and to escalate only if that doesn't work.

Escalation is set out in the Act. An inspector can order a business to fix a contravention by a deadline. If the order isn't followed, the director can issue an administrative penalty, with the amount set by regulation. Separately, failing to comply with an accessibility standard is an offence under the Act, with a maximum fine of $250,000 on conviction.

Meeting the standard also doesn't shield you from a human rights complaint. The province notes that The Human Rights Code still applies on top of it.

A 10-point self-check for your website

You can do most of these yourself in an afternoon. They're based on WCAG 2.1 and the W3C's "Easy Checks". Passing them isn't a full audit, but failing any of them means there's work to do.

• Images: every image that carries meaning has a short text description (alt text) that a screen reader can read aloud. Decorative images are skipped.
• Page titles: each page has its own title in the browser tab that says what the page is.
• Headings: each page has one main heading, and the subheadings follow in order, so the outline makes sense on its own.
• Contrast: normal text has a contrast ratio of at least 4.5 to 1 against its background, and large text at least 3 to 1. Free online contrast checkers will tell you.
• Zoom: text can be enlarged to 200% without anything overlapping or being cut off.
• Phones and narrow screens: at 320 pixels wide, content fits without scrolling sideways.
• Keyboard: put the mouse away. You can reach and use every link, button, menu and form field with the Tab and Enter keys alone.
• Focus: as you tab through, you can always see where you are, usually as an outline around the active item.
• Forms: every field has a visible label, and error messages say what went wrong and how to fix it, not just a red border.
• Video and audio: pre-recorded videos have captions, and there's a clear note on your site that information is available in other formats on request, with a way to send accessibility feedback.

Also check your PDFs. Menus, price lists and forms posted as scanned images can't be read by screen readers, and they count as web content too.

Why an accessibility widget won't make you compliant

You may have seen "overlay" tools: a script you add to your site that puts an accessibility button in the corner, often sold as instant compliance. The regulation asks for your web content to meet WCAG 2.1 AA. A toolbar sitting on top of the page doesn't fix missing labels, broken headings or a menu that can't be used with a keyboard underneath.

In April 2025, the US Federal Trade Commission finalized an order requiring accessiBe, a well-known overlay maker, to pay $1 million. The FTC had alleged that its accessWidget tool did not make all of its users' websites WCAG compliant, despite advertising that it could. The order bars the company from claiming its automated products can make any website WCAG compliant unless it has evidence to back that up.

Automated scanners are useful for finding some problems, but the W3C itself warns that a page can seem to pass basic checks and still have significant barriers. Real fixes happen in the site's design and code.

Where to start

Begin with the pages people need to do business with you: home, services, contact, booking or checkout. Run the self-check on those, fix what fails, then add your accessibility notice and feedback contact. After that, make WCAG 2.1 AA part of every new page you publish.

If you're planning a redesign anyway, that's the cheapest time to get it right. Contrast, headings, forms and keyboard support are far easier to build in from the start than to fix later. If you'd like help working through your site, that's the kind of work we do.