Section 4. Preparing your accessibility plans
From: Employment and Social Development Canada
- Section 1. Introduction
- Section 2. Accessibility plans
- Section 3. Recommended first steps
- Section 4. Preparing your accessibility plans
- Section 5. Recommendations on evaluating and documenting your accessibility plans
- Section 6. Looking ahead: the reporting cycle and updating your accessibility plan
On this page
- Introduction
- Required heading: "General"
- Required headings: Areas described under Section 5 of the ACA
- Required heading: "Consultations"
- Other recommended content
- Length, detail, and design
- Alternate formats and simple, clear, and concise language
- Requirements for publishing your plans
- Keeping copies of plans
You can also read our optional accessibility plan template for additional help.
Introduction
These modules provide information about both required and recommended content for your accessibility plans. The Accessible Canada Regulations (regulations) require that accessibility plans include the following headings:
Other than requiring those headings, the regulations do not dictate the content of your accessibility plan. Your plan should be tailored to reflect your organization's resources, needs, and capabilities, as well as the services you provide and the clients you serve.
Reminder: The ACA and its regulations also require you to prepare and publish progress reports respecting the implementation of your accessibility plan. Those progress reports must include the same required headings ("General," headings respecting areas described under Section 5 of the ACA, and "Consultations"), as well as an additional heading on feedback you have received.
Additional guidance on preparing progress reports will be published in early 2022.
Required heading: "General"
What the regulations require that you include under the "General" heading
The regulations state that the information that is included under the "General" heading must include:
- the position title of the person designated to receive feedback on behalf of the regulated entity
- the manner and information by which the public can communicate with the regulated entity
This "manner and information" includes the regulated entity's mailing address of its publicly accessible businesses, a telephone number, and an email address.
This contact information will allow the public to:
- request the entity's accessibility plan in one of the alternate formats described in subsection 8(2) of the regulations
- request the description of the entity's feedback process in one of the alternate formats described in subsection 9(5) of the regulations
- provide feedback to the regulated entity
In other words, you must provide the information necessary for the public to be able to communicate with your organization about accessibility and barriers.
Additional information we recommend you include under the "General" heading
This could be a good place to include an executive summary of your plan, providing an overview of the major barriers identified and the most important steps taken in response. You could also include an accessibility statement describing how accessibility fits within your organization's overall goals and values.
This section could also include some basic information about your organization, such as what you do, who your clients are, how many people are on your staff, and what your organization's overall vision and values are.
If a team or committee is preparing your organization's accessibility plan, you might list members' names and contact information here as well, subject to any applicable privacy restrictions. You could also list and describe any designated accessibility-related roles (such as an accessibility evaluator, a training coordinator, or an ombudsperson) within your organization.
Required headings: Areas described under Section 5 of the ACA
What the regulations require that you include under these area headings
Your accessibility plan must include content respecting your organization's policies, programs, practices and services in relation to the identification and removal of barriers, and the prevention of new barriers, in the areas described in Section 5 of the ACA:
- employment
- the built environment
- information and communication technologies (ICT)
- communication, other than ICT
- the procurement of goods, services and facilities
- the design and delivery of programs and services
- transportation
Your accessibility plan must include a heading for each of the areas identified under Section 5 of the ACA, even if you cannot immediately identify barriers or develop activities in those areas. Additional areas may be designated under future regulations.
Some federally regulated entities engage in operations that may fall under additional regulations under the ACA, developed by either the Canadian Radio-television and Telecommunications Commission (CRTC) or the Canadian Transportation Agency (CTA). This means that they may be required to report to both the Accessibility Commissioner (a member of the Canadian Human Rights Commission (CHRC)) and either CRTC or the CTA. The ACA requires that such entities' accessibility plans address their policies, programs, practices and services in a way that conforms to other regulations or laws that may apply to those entities.
Read sections 42 through 50 of the ACA to learn more about entities who carry on broadcasting undertakings, and their requirements under the Broadcasting Act.
Read sections 51 through 59 of the ACA to learn more about entities who are Canadian carriers or telecommunications service providers, and their requirements under the Telecommunications Act.
Read sections 60 through 68 of the ACA to learn more about entities who are a part of the federal transportation network, and their requirements under the Canada Transportation Act.
Remember: The ACA requires that you consult persons with disabilities in the preparation of your accessibility plan. Take advantage of these consultations to ask for advice on identifying, removing, and preventing barriers to ensure accessibility in all areas.
Additional information we recommend you include under these area headings
Each organization will have different barriers to identify, remove, and prevent. We recommend that the sections of your accessibility plan related to each of the areas described in Section 5 of the ACA be tailored accordingly.
Under each area heading, we recommend that you include some or all of the following:
- concrete and achievable actions your organization is taking (or has already taken) to identify, remove, and prevent barriers in that area
- short descriptions of your current level of accessibility, your accessibility goals, and the positive changes expected to result from greater accessibility in that area
- Note: in stating your organization's accessibility goals, it can be helpful to choose them using the S.M.A.R.T. system; goals should be:
- specific
- measurable
- attainable
- realistic
- time-based
- Read the guidance module on evaluating your accessibility plan for recommendations on setting goals with these qualities
- Note: in stating your organization's accessibility goals, it can be helpful to choose them using the S.M.A.R.T. system; goals should be:
- policies, programs, practices and services you intend to change related to that particular ACA area, how you plan to change them, and the results you expect from those changes
- other accessibility achievements or milestones you expect to reach while this accessibility plan is in place
- training related to this particular area that you have provided, or plan to provide, to employees
- long-term plans for activities or changes that go beyond the duration of this accessibility plan
- the names and contact information of any accessibility plan team members, accessibility officers, or other staff within your organization who have responsibilities related to the plan
You should choose the format and content for these sections that best describe and support your efforts to identify, remove, and prevent barriers to accessibility.
Required heading: "Consultations"
What the regulations require that you include under the "Consultations" heading
The regulations state, with reference to the ACA, that your accessibility plan must set out the manner in which you consulted persons with disabilities in the preparation of your plan (in other words, explain how you consulted persons with the disabilities).
Keep in mind that your organization must also consult persons with disabilities in the preparation of your progress reports. ESDC will publish additional guidance on consulting persons with disabilities in early 2022.
Additional information we recommend you include under the "Consultations" heading
Since organizations all have different resources, needs, and capabilities, and serve different clients and provide different services, the ACA and its regulations do not mandate a specific way to conduct consultations. We recommend that your organization consult persons with disabilities in a way that best supports your efforts to identify, remove, and prevent barriers.
In this section of your accessibility plan, we recommend that you include information about some or all of the following:
- whom you consulted:
- the names of disability organizations or experts who participated
- the number of participants
- the range of disabilities represented
- note: except in the case of expert participants appearing in a professional capacity, the names of individual participants should be removed to respect individuals' right to privacy
- what you consulted on:
- the questions asked and the answers received
- an explanation of how those responses informed your accessibility plan
- when you consulted:
- the dates or period of time during which the consultation(s) took place
- a description of how far along you were in developing your accessibility plan at the time the consultations occurred
- how you consulted:
- a description of the consultation process and activities (for example, whether you used in-person events, virtual meetings, group discussions, digital surveys, or a combination of these or other means)
- an explanation of why you chose that process and those activities
- an account of what your organization did to ensure the consultations were accessible
- where you consulted:
- the communities, cities, or other locations where you held consultations (if relevant)
- results:
- what data and information you received from your consultations and how you intend to act on them
Consultations offer important opportunities to listen, learn, and discuss. As you consult, you may learn about other topics you may wish to include in your accessibility plan.
Other recommended content
The headings required by the regulations cover important aspects of accessibility, but they may not cover every subject your organization would like to include in your accessibility plan. You may have additional priorities, or you may identify and remove additional barriers based on your organization's activities, location, or other factors. Your accessibility plan is an opportunity to publicly present your organization's values, achievements, and commitments regarding accessibility.
Here is some additional content that we recommend you include under separate headings.
Glossary
You could include a glossary where you define some of the words in your plan, such as types of disabilities, how the ACA defines "barriers", or any technical or professional terms relevant to your organization. A glossary can make it easier to read your plan. It can also prevent you from having to define terms every time they appear in your plan.
Budget and resources
You could also include a description of the money and resources your organization plans to allocate for accessibility improvements. This would promote accountability and demonstrate your organization's commitment to accessibility to employees, clients, and members of the disability community. You could create a heading for this section or include this information under the "General" heading of your plan.
Training
You could provide details about training you will offer to your staff, such as training about accessibility and about communicating with people with different types of disabilities. Persons with disabilities are best placed to partner with you in the development and delivery of training programs given their lived and living experiences. Such partnerships also reaffirm organizations' commitment to the principle of "Nothing without us."
Training can improve how your employees serve clients with disabilities. It can show how accessibility benefits everyone, including employees. Well-trained staff are critical to any organization's success. You could include a separate heading in your plan for this, or include this information under the appropriate headings for the areas described in Section 5 of the ACA.
Length, detail, and design
The regulations do not specify a minimum or maximum length for accessibility plans. They must include all required contents, and should be comprehensive and useful without being too long or complicated. They must also be written in simple, clear, and concise language. Guidance on simple, clear and concise language will be published in the spring of 2022.
The published plan should also be optimized for accessibility. Consult the Digital Accessibility Toolkit and the Canada.ca Content Style Guide for recommendations on creating accessible documents.
Alternate formats and simple, clear, and concise language
Alternate formats
The regulations require that you provide your accessibility plans in the following formats upon request:
- large print (increased font size and clarity)
- braille (a system of raised dots that people who are blind or who have low vision can read with their fingers)
- audio (a recording of someone reading the text out loud)
- electronic (an electronic format that is compatible with adaptive technology that is intended to assist persons with disabilities)
Additional guidance offering recommendations, tips and best practices for providing your accessibility plans, progress reports, and descriptions of feedback processes in alternate formats will be published in the spring of 2022.
The regulations set different deadlines for different entities to provide copies of their accessibility plans depending upon the requested format.
- All federal government entities, including departments, agencies, Crown corporations, or government-related entities such as the Canadian Forces or Parliamentary entities, must provide print, large print, and electronic formats of their plans within 15 days of a request
- Federally regulated private-sector organizations with an average of 100 or more employees must provide print, large print, and electronic formats of their plans within 15 days of a request
- Federally regulated private-sector organizations with an average of between 10 and 99 employees must provide print, large print, and electronic formats of their plans within 20 days of a request
- All organizations must provide braille or audio versions of their plans within 45 days of a request
Read subsections 1(2) and 1(3) of the regulations to learn how to calculate your average number of employees, or what to do if that average changes.
Simple, clear, and concise language
The regulations require that you write your accessibility plans, progress reports, and descriptions of your feedback process in language that is simple, clear, and concise. This will ensure that your plan is easy to read and understand. Your sentences should be short, and you should avoid technical words. Someone who knows nothing about your organization or its work should be able to understand the plan's contents.
Additional guidance offering recommendations and best practices for the use of simple, clear and concise language will be published in spring of 2022.
Requirements for publishing your plans
The regulations set different deadlines for the publication of different entities' first accessibility plans:
- government entities, including departments, agencies, Crown corporations, or government-related entities such as the Canadian Forces or Parliamentary entities: December 31, 2022
- large federally regulated private sector entities with an average of 100 or more employees: June 1, 2023
- small federally regulated private sector entities with an average of between 10 and 99 employees: June 1, 2024
Entities with an average of fewer than 10 employees are exempt from these planning and reporting requirements. Read subsections 1(2) and 1(3) of the regulations to learn how to calculate your average number of employees, or what to do if that average changes. Read subsections 2(a) and 2(b) of the regulations to learn about additional exemptions, for a period of five years from the day the regulations come into force, for First Nations band councils and certain related entities.
You must notify the Accessibility Commissioner within 48 hours of publishing your accessibility plan. This notification must be sent by email or other electronic means. It must include either the URL address of the plan, a hyperlink to that URL address, or the mailing addresses of the places of business at which that version of the plan is displayed.
Your organization may engage in operations that fall under additional regulations under the ACA, developed by either the Canadian Radio-television and Telecommunications Commission (CRTC) or the Canadian Transportation Agency (CTA). If so, you may be required to notify both the Accessibility Commissioner (a member of the Canadian Human Rights Commission (CHRC)) and either the CRTC or the CTA.
Read sections 42 through 50 of the ACA to learn more about entities who carry on broadcasting undertakings, and their requirements under the Broadcasting Act.
Read sections 51 through 59 of the ACA to learn more about entities who are Canadian carriers or telecommunications service providers, and their requirements under the Telecommunications Act.
Read sections 60 through 68 of the ACA to learn more about entities who are a part of the federal transportation network, and their requirements under the Canada Transportation Act.
Your organization must publish your accessibility plan on the main digital platform that you use to communicate with the public, such as a website or social media account. The published version of the plan must meet a certain level of the Web Content Accessibility Guidelines (WCAG). These are guidelines for designing accessible websites. Accessibility plans must at least meet AA-level success criteria of the most recent version of WCAG that is available in both English and French, which is currently WCAG 2.0. The specified version will be updated whenever official translations of later WCAG versions become available.
If your organization does not have a digital presence, you must display paper copies of the plan in the reception area or entrance of each of your places of business. These copies must be clearly visible and accessible to the public.
Keeping copies of plans
Your organization must keep copies of your accessibility plans for a period of seven years from the date on which that version of the plan was required to be published. If your organization has a public digital platform, a digital copy of your plan must be hosted there. If your organization does not have a public digital platform, you must retain a physical or electronic copy of the plan in such a manner that it is accessible to the public.
Note: Your organization must also keep print or electronic copies of any feedback you receive through your feedback process for a period of seven years beginning on the day on which it was received. Additional guidance offering recommendations and best practices for describing and maintaining your feedback process will be published in early 2022.
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