Accessible Canada Act

The Accessible Canada Act (ACA), officially An Act to ensure a barrier-free Canada, came into force on July 11, 2019. It is the first federal legislation in Canada with the explicit goal of identifying, removing, and preventing barriers for persons with disabilities across all areas under federal jurisdiction.

Who must comply?

The ACA applies to federally regulated entities, which include:

SectorExamples
Federal governmentAll departments, agencies, Crown corporations
Banking and financial servicesBanks chartered under the Bank Act (not credit unions)
TelecommunicationsRogers, Bell, Telus, and other licensed carriers
BroadcastingCBC/Radio-Canada, private broadcasters
Interprovincial transportationAirlines, railways, interprovincial bus and ferry operators
Postal and courierCanada Post
First Nations governanceBand councils operating programs under federal jurisdiction

What does it require?

The ACA is organized around seven priority areas where barriers can exist:

  1. Employment — hiring, onboarding, workplace accommodation
  2. The built environment — physical spaces and facilities
  3. Information and communication technologies (ICT) — websites, apps, digital documents, software
  4. Communication, other than ICT — signage, publications, phone services
  5. Procurement of goods, services, and facilities
  6. Design and delivery of programs and services
  7. Transportation

For digital teams, ICT is the primary area of concern. Covered organizations must:

  • Publish an accessibility plan that identifies barriers in ICT and describes how they will be removed (updated every 3 years)
  • Publish an annual progress report on implementing the plan
  • Establish a feedback process that allows anyone to report accessibility barriers
  • Retain feedback records for 7 years
  • Make plans, reports, and feedback processes available on request and, where possible, in multiple accessible formats

Digital accessibility standards

Developer Designer

Accessibility Standards Canada (ASC) — a government agency created by the ACA — develops the technical standards that organizations must meet. For ICT, the primary standard is based on EN 301 549, the European harmonized standard for ICT accessibility, which itself incorporates WCAG 2.1 Level AA.

In practice, meeting WCAG 2.1 Level AA for all public-facing web content is the minimum digital accessibility standard under the ACA. The federal government’s own standard, the Government of Canada Digital Accessibility Playbook, goes further and recommends WCAG 2.1 Level AA as the floor, with AAA criteria applied where feasible.

Enforcement

The ACA created two new bodies:

Accessibility Commissioner

The Accessibility Commissioner operates within the Canadian Human Rights Commission (CHRC) and handles complaints about federally regulated organizations. Anyone can file a complaint if they believe an organization has failed to meet its obligations under the ACA.

Complaint process:

  1. Attempt to use the organization’s own feedback process first
  2. File a complaint with the Accessibility Commissioner
  3. Investigation by the CHRC
  4. Mediation or conciliation attempt
  5. If unresolved, referral to the Canadian Human Rights Tribunal

Canadian Transportation Agency (CTA)

For transportation-specific complaints (airlines, rail, ferry), the CTA has separate jurisdiction and can order carriers to remove transportation barriers.

Penalties

Organizations can face administrative monetary penalties of up to $250,000 per violation. The ACA also allows the Governor in Council to increase penalties by regulation.

Timelines

ObligationDeadline
First accessibility planJune 1, 2023 (federal departments/agencies); phased for other covered entities
Progress reportsAnnually, on the anniversary of the accessibility plan
Feedback processMust be in place before publishing an accessibility plan
ICT barrier remediationOngoing; organizations set their own milestones in their plans

Frequently asked questions

Does the ACA set specific WCAG conformance requirements?

The ACA itself does not specify WCAG levels directly — it delegates standard-setting to Accessibility Standards Canada. However, ASC’s ICT standard references EN 301 549, which incorporates WCAG 2.1 Level AA. The Government of Canada’s own Standard on Web Accessibility requires WCAG 2.0 Level AA (being updated to align with WCAG 2.1).

Do Crown corporations need to comply?

Yes. Crown corporations listed in Schedule II of the Financial Administration Act are subject to the ACA. This includes CBC/Radio-Canada, Canada Post, Export Development Canada, and others.

What if my organization is both federally and provincially regulated?

Some activities of your organization may fall under federal jurisdiction (e.g., interprovincial operations) while others fall under provincial jurisdiction (e.g., retail locations in Ontario). The ACA applies to your federally regulated activities; provincial laws such as AODA apply to provincial activities. Many organizations choose to apply the stricter standard across all operations for consistency.

Is there a size exemption for small federally regulated businesses?

The ACA currently exempts some smaller entities from specific reporting obligations. However, the duty to remove barriers applies regardless of size. Check the most recent Accessible Canada Act regulations for current thresholds.