Section 4. Preparing your accessibility plans

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.

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.

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
• 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.

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.

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.

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.

Alternate formats

The regulations require that you provide your accessibility plans in the following formats upon request:

• print
• 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.