Digital accessibility rules for federally regulated entities

Summary#

These are final changes to the Accessible Canada Regulations that add a new set of rules about digital accessibility (web pages, mobile apps and downloadable documents). They require many federally regulated organizations to make new and updated digital content meet the national ICT accessibility standard CAN/ASC‑EN 301 549, with staged deadlines and some sector and size-based exemptions.

What it does#

• Adds a new Part called “Information and Communication Technologies” to the Accessible Canada Regulations that uses the ICT standard CAN/ASC‑EN 301 549 as the technical reference for accessibility.
• Requires covered organizations to make new or updated digital content conform, “to the extent feasible,” to the ICT Standard:
  • Web pages (including web applications).
  • Mobile applications (selected types).
  • Non‑web downloadable documents (for public-facing downloads).
• Sets different deadlines depending on the organization:
  • Federal public sector web pages and some other public‑sector obligations start after 24 months (i.e. on or about December 5, 2027).
  • Most private sector requirements and other items start after 36 months (i.e. on or about December 5, 2028).
• Requires training and reporting pieces:
  • Training on digital accessibility fundamentals for employees who develop, maintain or buy ICT, with refresher training at least every 3 years.
  • An accessibility statement published at least once every 12 months, describing accessibility features, gaps, contact information and plans to fix gaps.
  • Retention of certain records (accessibility statements, training records, conformity assessments) for 4 years.
• Procurement rule: when buying products or services for regulated web pages or mobile apps, many covered organizations must obtain or commission a conformity assessment (gap analysis) against the ICT Standard.
• Allows temporary “alternative measures” if conformance is not currently feasible, but those alternatives must remove the barriers to users while the organization works toward conformance.
• Clarifies a number of exceptions and limits:
  • Heritage content, user‑generated content, and content inside employee collaborative environments are generally exempt from the ICT requirements.
  • Entities are not required to provide alternative access for maps, mapping services, technical drawings or images.
  • The definition of “employee” is expanded to explicitly include dependent contractors.
• Limits and exemptions:
  • Small federally regulated private businesses with an average of 99 or fewer employees are exempted.
  • First Nations band councils and certain activities on reserve are exempted from these digital rules (and other planning/reporting requirements) until December 31, 2033.
  • Broadcasting/telecommunications entities and many transportation service providers have a narrower scope because they fall under other regulators (CRTC, CTA); some obligations still apply to their employee‑facing web pages.
• Enforcement: non‑conformance is treated as a “minor” violation under the administrative monetary penalty framework; penalty ranges include $1,000 to $10,000 for a first minor violation and $50,000 to $75,000 for repeated violations (as set out in the Accessible Canada Regulations’ penalty scheme).

Who's affected#

• Federal public sector bodies: departments, agencies, Crown corporations and similar federal entities.
• Federally regulated private sector organizations:
  • “Large” businesses (those with an average of 500 or more employees) face the broadest set of requirements.
  • “Medium” businesses (average 100–499 employees) have a narrower set of obligations (for example, web page accessibility and training).
  • Small businesses (average 99 or fewer employees) are not covered by these Phase 1 requirements.
• Organizations that operate under federal transportation or broadcasting/telecom rules will see a limited application, because other regulators already set related digital rules for them.
• People who use these services: persons with disabilities are the main intended beneficiaries, and all users may see improvements in usability.
• Employees who work on digital products, procurement or communications will have new training and procurement responsibilities.
• Digital vendors and suppliers may be asked to provide conformity assessments and to meet accessibility expectations when selling to federally regulated entities.
• The enforcement authority is the Accessibility Commissioner within the Canadian Human Rights Commission (for compliance and penalties).

Why it matters#

• It aims to reduce the daily barriers millions of Canadians with disabilities face when trying to use government and federally regulated online services. That includes applying for jobs, accessing benefits, banking, and doing everyday tasks online.
• The government’s cost‑benefit analysis projects the rules will cost regulated entities a present value of $309.95 million over 10 years and produce benefits with a present value of $1,209.78 million, for a net present value of $899.83 million. These figures come from the Regulatory Impact Analysis Statement attached to the amendments.
• The rules focus on preventing new accessibility problems in three priority digital areas (web pages, mobile apps, downloadable documents) while leaving more complex issues (legacy content, enterprise software, AI) for future regulatory phases.
• Organizations get time to comply (mostly 24–36 months) and can use temporary alternative measures when full conformance is not feasible. First Nations band councils have extra time (exemption to December 31, 2033) to allow for co‑development of an approach tailored to reserve contexts.
• In practice, this means better online access for people with disabilities, new procurement and training expectations for covered organizations, and a clearer path for vendors to supply accessible digital products.