What Manitoba's accessibility standard means for small businesses

Since May 1, 2025, Manitoba's accessibility standard for information and communication has applied to organizations with one or more employees in the province. For most small businesses, that means the website is now part of their legal obligations, alongside how they share information with customers. This article explains who is covered, what the standard asks for, how enforcement works and what a sensible first step looks like.

The law and the regulation

Two pieces of legislation work together here. The Accessibility for Manitobans Act, C.C.S.M. c. A1.7, is the framework law. It allows the province to set accessibility standards and sets out how they are enforced.

The standard that matters for websites is the Accessible Information and Communication Standard Regulation, Man. Reg. 47/2022. It came into force on May 1, 2022 (s. 15 (opens in a new tab)). For organizations with one or more employees in Manitoba, the date was three years later: May 1, 2025 (s. 2(c) (opens in a new tab)).

For a fuller walk-through of each section, see our page on the Manitoba standard.

Who is covered

The threshold is low. If your organization has one or more employees in Manitoba, the standard applies to you. That includes a two-person dental office, a family restaurant, a trades contractor, a retail shop and a small non-profit with a paid coordinator.

There is no exemption for being small.

What it requires

The regulation has several parts. The ones most small businesses need to know are these.

Web content must meet WCAG 2.1 Level AA

Under s. 7(1) (opens in a new tab), web content must meet the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA if it was published on or after the applicable date, or if it is needed to access the organization's goods or services. WCAG 2.1 Level AA is made up of 50 success criteria: 30 at Level A and 20 at Level AA. Our Insights library includes a plain-language guide to all 50.

The second condition matters. Older pages are not automatically excused. If a customer needs a page to book an appointment, see a menu, request a quote or buy a product, that page is in scope regardless of when it was first published.

Web applications

Web applications, such as online booking tools or customer portals, are addressed in s. 8(1) (opens in a new tab) for applications published or significantly updated after the applicable date.

Limited exceptions

Section 7(2) (opens in a new tab) lists exceptions: where meeting the requirement is not technically feasible, where the technology is not readily available, where it would cause undue hardship, where the organization has no direct control over the content, and for product labels and product information. These are narrow. They are not a general opt-out, and relying on one is a decision worth documenting carefully.

Accessible formats, feedback and training

• Notice of accessible formats and communication supports (s. 5 (opens in a new tab)). You let people know that information is available in accessible formats and with communication supports on request.
• Feedback process (s. 9 (opens in a new tab)). You have a way for people to tell you about accessibility barriers in your information and communication.
• Training (s. 4 (opens in a new tab)). People who communicate publicly on your behalf, maintain your web content, or buy information and communication technology need training, as soon as reasonably practicable.

Large employers have additional documentation duties: they must document their measures and policies (s. 3(2) (opens in a new tab)) and a training policy (s. 4(4) (opens in a new tab)).

How enforcement works

Enforcement under the Act is a sequence of steps rather than an automatic fine.

1. Inspections (ss. 23 (opens in a new tab)-26 (opens in a new tab)). The Act provides for inspections to check compliance.
2. Compliance orders (s. 27 (opens in a new tab)). Where an organization is not complying, a compliance order can be issued requiring it to take specific steps.
3. Administrative penalties (s. 29 (opens in a new tab)). A penalty may be imposed if a compliance order is not complied with.
4. Public reporting (s. 32 (opens in a new tab)). Orders and penalties can be reported publicly.
5. Offences (s. 34 (opens in a new tab)). On summary conviction, a fine can be up to $250,000 (s. 34(3) (opens in a new tab)). Directors and officers who authorized or permitted a corporate offence can also be found guilty (s. 34(2) (opens in a new tab)).

The practical point is that penalties follow an unmet compliance order. An organization that understands its obligations and is working through them in good faith is in a very different position from one that ignores an order.

Why it matters beyond compliance

About 27% of Canadians aged 15 and over reported one or more disabilities in 2022, according to Statistics Canada's Canadian Survey on Disability. Many of those people are customers who use a keyboard instead of a mouse, a screen reader, magnification or captions. A website that works for them is also, in most cases, clearer and easier to use for everyone else.

What to do first

You do not need to fix everything this week. You do need to know where you stand. A sensible order of work looks like this:

1. List the pages customers actually need. Home, contact, booking, menu, product pages, forms and any PDFs linked from them. These are in scope under s. 7(1) (opens in a new tab) regardless of age.
2. Get an audit against WCAG 2.1 AA. Automated scans catch some issues, but many criteria can only be checked by a person using a keyboard and a screen reader. Our testing method explains what that involves.
3. Fix the barriers that block tasks first. A form that cannot be submitted by keyboard matters more than a minor heading issue.
4. Add your accessible formats notice and feedback process. These are often quick to put in place.
5. Arrange training for whoever updates the website or speaks publicly for the business.
6. Keep records. Notes on what was tested, what was fixed and when are useful if questions are ever asked.

Be cautious about one-line fixes. Overlay widgets that promise instant compliance do not meet the standard on their own; we explain why in a separate article. You can see what a full audit produces in our sample report, and the FAQ answers common questions about scope and timing.

Talk to us

If you are not sure whether your website meets the standard, we can review it and tell you plainly. Book a consultation and we will explain what an audit would cover and provide a fixed written quote. You can also read more about our services.

Last reviewed October 2026. General information, not legal advice.