Level Access

Author: Level Access

More than six million Canadians over the age of 15 have one or more disabilities, whether related to hearing, vision, mobility, memory, or something else. That’s one in five, or 22%, of the country’s population, according to Statistics Canada. For these individuals, being able to participate in society on par with their fellow citizens—shop in the same places, learn at the same schools, and access the same online services—is a fundamental right.

In the U.S., the Americans with Disabilities Act (ADA) is a civil rights law that protects individuals with disabilities by prohibiting discrimination in employment, public services, public accommodations, and telecommunications. Adopted in 2019, the Accessible Canada Act (ACA) shares similar goals that help ensure equal access for people with disabilities. Alongside the ACA, the government also created Accessibility Standards Canada (ASC), which is responsible for developing and maintaining the standards organizations must follow.

Wondering if the ACA applies to your organization—and what your obligations are under this and other Canadian accessibility laws? This blog takes a deep dive into the ACA and accessibility standards in Canada, including what recent proposed updates to the ACA mean for organizations. We’ll also cover Canadian provincial laws that may include accessibility requirements beyond the scope of the ACA.

How does the Accessible Canada Act establish Canadian accessibility standards?

The ACA, adopted with the goal of creating a barrier-free Canada by 2040, is designed to identify, remove, and prevent barriers across key areas including employment, physical environments, technology, communications, programs and services, procurement, and transportation. ASC plays a central role in this effort, ensuring Canada’s standards evolve to reflect both national priorities and international best practices.

The Accessible Canada Act applies to federally regulated organizations. This includes Parliament, Crown corporations, the federal government, and private-sector businesses under federal jurisdiction, such as banking, telecommunications, and transportation.

Organizations within this policy’s scope are required to develop accessibility plans, receive feedback, and publish updated reports every three years. In tandem with the law’s enactment, the Canadian government created an Accessibility Commissioner who is responsible for enforcing compliance with the ACA.

2025 proposed amendments to the ACA

In 2025, the Canadian government proposed significant updates to the Accessible Canada Regulations (the rules for compliance with the ACA), expanding digital accessibility requirements for federally regulated organizations. These amendments would set clearer expectations for how organizations must support inclusive digital experiences.

The standard for compliance with these regulations is CAN/ASC – EN 301 549, a national accessibility standard for information and communications technology (ICT) developed by ASC. This standard incorporates the European standard for digital accessibility, EN 301 549. Notably, this standard aligns with international best practices for digital accessibility and adopts WCAG 2.1.

What would the proposed ACA amendments require?

The new proposed amendments introduce requirements for web, mobile, and document accessibility, along with documentation, training and procurement. The following table outlines the different types of requirements, along with corresponding deadlines for federally regulated public and private organizations:

Requirement Public sector Private sector
Accessible web pages June 1, 2027 June 1, 2028
Accessible mobile apps & documents June 1, 2028 June 1, 2028
Accessibility statements June 1, 2027 June 1, 2028
Digital accessibility training (every 3 years) June 1, 2027 June 1, 2027
Accessibility assessments for digital purchases June 1, 2028 June 1, 2028

 

Let’s unpack the specifics of each potential obligation.

Web, mobile, and document accessibility

If these proposed amendments become law, federal public-sector and large private-sector organizations must ensure that new public-facing web pages, new public-facing mobile apps, and new digital documents published on public websites are accessible to people with disabilities. (The requirements are not applicable to internal files or internal communications.)

Federal public-sector organizations would have until June 1, 2027, to meet web accessibility requirements, while large private businesses would need to comply with these requirements by June 1, 2028. The proposed deadline for compliance with mobile and document accessibility requirements is June 28, 2025, for both public- and private-sector organizations.

Accessibility statements

The proposed amendments would mandate that federal public-sector organizations and large businesses publish accessibility statements written in clear, simple language. These statements would need to include:

  • Instructions for using accessibility features.
  • Descriptions of alternative access methods.
  • Timelines for resolving known accessibility barriers.

Federal public-sector organizations would be required to publish accessibility statements by June 1, 2027. Large private businesses would have until June 1, 2028.

Training and documentation

Under the proposed amendments, federal public-sector organizations as well as medium-sized and large private businesses (100+ employees) under federal responsibility would have to provide digital accessibility training to relevant staff—including those involved in developing, supporting, or procuring digital technologies—by June 1, 2027.

They would also be required to offer refresher training every three years and retain records of training—along with accessibility statements and assessments—for at least four years.

Procurement obligations

Starting in 2028, organizations would be required to obtain accessibility assessments when procuring digital products and services.

Alternative access provisions

If full compliance with digital standards isn’t technically feasible, the proposed amendments stipulate that organizations offer alternative methods of access and clearly explain these alternatives in their accessibility statements.

Exemptions

The proposed amendments provide exemptions for certain types of organizations. Specifically:

  • Private businesses under federal jurisdiction with fewer than 100 employees would not need to meet new requirements.
  • First Nations Band Councils would be exempt until December 31, 2033, allowing time for tailored approaches that reflect community needs and priorities.

Additionally, the proposed amendments allow exemptions for some types of digital content, including:

  •  Internal documents and internal communications.
  • Web pages, mobile, apps, and public documents published before the applicable compliance deadline (June 1, 2027 or June 1, 2028, depending on the type of organization and content).

Penalties

Organizations that fail to comply with the new proposed requirements could face administrative monetary penalties ranging from $250 to $75,000, depending on the severity of the violation.

Beyond the ACA: What provinces in Canada have accessibility laws?

Many individual provinces in Canada have established accessibility legislation that complements the Accessible Canada Act. For some provinces, these laws expand the reach of the ACA, as well as the standards for compliance. Notable provincial laws in Canada include:

The Accessibility for Ontarians with Disabilities Act (AODA)

The AODA became law in 2005 in Ontario. As such, it has been on the books longer than any other accessibility legislation in Canada. The AODA requires both public- and private-sector organizations to follow established sets of accessibility standards when dealing with the public. The standards fall into five categories: information and communications, customer service, transportation, employment, and design of public spaces.

The Accessibility for Ontarians with Disabilities Act establishes specific standards for Canadian website accessibility laws by adopting WCAG 2.0 AA, offering organizations a technical framework for providing barrier-free online experiences. The AODA also goes further than the ACA in that it not only requires public spaces to be more accessible but also requires that businesses train their staff in accessibility, referred to as AODA training.

The Accessibility for Manitobans Act

In 2023, Manitoba enacted the Accessibility for Manitobans Act. With this law, Manitoba expanded the ACA by requiring all public- and private-sector organizations to comply with the law.

The Act’s structure is similar to that of Ontario’s law: It currently focuses on five mandatory accessibility standards that apply to both the public and private sectors. And, like the AODA, it includes an Accessible Information and Communications Standard that covers online information and uses WCAG 2.0 AA as the compliance benchmark.

The Nova Scotia Accessibility Act

In 2017, the province of Nova Scotia passed its own legislation aimed at developing accessibility standards in six areas, including information and communication. In defining “barrier,” the act specifically mentions potential barriers in technology. Nova Scotia’s law is similar in scope to Ontario’s and Manitoba’s in that it applies to all organizations within the province. The government is working to establish accessibility standards for each area addressed.

The Accessible British Columbia Act

In 2021, British Columbia adopted the Accessible British Columbia Act, which aligns closely with the ACA. The most limited in scope of the provincial accessibility laws, this act initially applies only to British Columbia’s government, requiring that government entities create accessibility plans that are reviewed and revised every three years.

The Newfoundland and Labrador Accessibility Act

In December of 2021, Newfoundland and Labrador became the most recent Canadian province to adopt its own accessibility law. In alignment with the ACA, the act’s initial focus is developing accessibility standards for the province. The first standards Newfoundland and Labrador aims to establish are for customer service and ICT.

Website Accessibility Standard (SGQRI 008 3.0)

Enacted on 29 April 2024, this standard establishes rules to ensure websites are designed so that all Internet users can access information and use online functions. Its purpose is to guarantee that any site and its content are usable by everyone, including people with disabilities.

Adopting a single standard across the Québec government helps harmonize practices in web accessibility and ensures inclusive digital services for all citizens.

The Ministry of Cybersecurity and Digital Affairs is responsible for issuing version 3.0 of the Standard.

The future of accessibility standards in Canada

At both the federal and provincial level, most of the next steps outlined by accessibility-focused laws are to establish standards for accessibility compliance. In addition to CAN/ASC – EN 301 549, the ASC currently has 16 standards under development and has published a technical guide for Accessible and Equitable Artificial Intelligence Systems.

An innovative solution

With new regulations on the horizon, now is the time to assess your digital assets and build a proactive accessibility strategy. Level Access has helped numerous organizations achieve, and maintain, compliance with Canadian and international accessibility laws.

Our end-to-end solution spans the three pillars of a sustainable accessibility program: Audit & Test, Build & Fix, and Governance & Reporting. Request a demo today to learn how we can support long-term compliance for your organization.