According to Ontario.ca, "Beginning January 1, 2021, all public websites and web content posted after January 1, 2012 [nb: I suspect a typo here and it s/b 2021] must meet WCAB 2.0 Level AA." According to Adobe website, "PDF documents can be made to meet WCAG 2.0 to the Priority AA level."
It would appear then that LCBO simply doesn't care and took the easy way out eliminating the problem by making the PDF's disappear.
Exactly. When my company creates PDFs for our clients, we are required to make them WCAG 2.0 Level AA compliant. It’s a PITA and time-consuming (Adobe’s automated tools don’t really work so it takes quite a bit of manual labour), but it can be done.