Language selection

Government of Canada / Gouvernement du Canada

Search

Guidance overview of regulatory amendments: Digital Technologies Phase 1

Important notice and disclaimer

This guidance document pertaining to the Regulations Amending the Accessible Canada Regulations includes links to external non-government resources for informational purposes only. By providing links, Employment and Social Development Canada (ESDC) is pointing to potentially helpful information but not endorsing or promoting these resources or any products, services, opinions, or content found on these resources. ESDC bears no responsibility for the accuracy, legality, or content of any external site or links. Consult the Canada.ca terms and conditions for more information about links to non-Government of Canada resources.

This guidance document is intended to facilitate regulatory compliance by offering context and clarity to help federally regulated entities ("organizations" hereafter for ease of reference) meet and exceed regulatory requirements under the amended Accessible Canada Regulations. It is, however, not a definitive guide to the requirements under the Accessible Canada Act or Accessible Canada Regulations.

Always check the Accessible Canada Act and the Accessible Canada Regulations for your organization's specific requirements. If there is any conflict between this guidance and the Accessible Canada Act or Accessible Canada Regulations, the Accessible Canada Act or Accessible Canada Regulations takes precedence.

This guidance document is also distinct from the compliance tools and materials developed by the Canadian Human Rights Commission (CHRC). The guidance document is intended to complement, not replace CHRC's resources.

On this page

Alternate formats

Guidance Overview of Regulatory Amendments: Digital Technologies Phase 1 [PDF - 496 KB]

Large print, braille, MP3 (audio), e-text and DAISY formats are available on demand by ordering online or calling 1 800 O-Canada (1-800-622-6232). If you use a teletypewriter (TTY), call 1-800-926-9105.

List of acronyms
ACAR
Accessible Canada Regulations
ATPDR
Accessible Transportation for Persons with Disabilities Regulations
BTO
Broadcasting or telecommunications organizations (entity)
CHRC
Canadian Human Rights Commission
CRTC
Canadian Radio-Television and Telecommunications Commission
CTA
Canadian Transportation Agency
ESDC
Employment and Social Development Canada
ICT
Information and Communication Technologies
PDF
Portable document format
TSP
Transportation service providers
VPAT®
Voluntary Product Accessibility Template
WCAG
Web Content Accessibility Guidelines

What are digital technologies

Digital technologies encompass a wide range of tools and services used to create, manage, transmit, and share information. This includes everything from hardware and software to networks and telecommunications systems. Examples of digital technologies include:

How digital technologies are regulated by the Accessible Canada Act

The Accessible Canada Act, which came into force in 2019, aims to create a barrier-free Canada by January 2040. To do so, the Act focuses on removing and preventing accessibility barriers in several areas. One of these areas is Information and Communications Technologies (ICT), hereafter referred to as digital technologies for ease of reference.

To support this goal, in 2024, Accessibility Standards Canada adopted the European Standard EN 301 549 as a National Standard of Canada, under the designation of CAN/ASC - EN 301 549:2024, hereafter referred to as the ICT Standard.

Did you know?

The Accessible Canada Act established Accessibility Standards Canada with the mandate to create national accessibility standards. Unlike regulations, standards are voluntary. However, if the Government of Canada incorporates a standard into a regulation, the standard becomes mandatory for all federally regulated organizations.

The ICT Standard was selected because it is the most comprehensive and internationally recognized digital accessibility standard. It also goes beyond web accessibility to cover accessibility requirements for a wide range of digital technologies.

Meeting the requirements of the ICT Standard is intended to help:

Phase 1 regulatory amendments at a glance

The amendments to the Accessible Canada Regulations (ACARs) introduce a new part titled “Information and Communication Technologies”. The amendments (referred to as Phase 1 Regulations hereafter) set out the first phase of new requirements for both public and private sector federally regulated organizations regarding digital accessibility.

The Phase 1 Regulations aim to help organizations make their digital technologies accessible from the start by requiring them to comply with certain mandatory requirements.

The new requirements include the following changes:

  1. new and updated web pages (employee-facing, as well as all other web pages that are non-employee facing), including web applications, to conform to the ICT Standard
  2. new and updated digital documents, such as PDFs, on non-employee facing web pages and non-employee facing mobile applications to conform to the ICT Standard
  3. new non-employee facing mobile applications to conform to the ICT Standard
  4. accessibility statements to report non-conforming regulated digital content, and plans to address those gaps
  5. digital accessibility training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies
  6. conducting or obtaining a conformity assessment of existing non-employee facing mobile applications
  7. conducting or obtaining a conformity assessment when purchasing anything related to regulated web pages and mobile applications to determine whether the digital technology conforms to the ICT Standard

Why do the Phase 1 Regulations include only three digital technologies

During early consultations with stakeholders, persons with disabilities identified accessibility of (1) web pages, (2) digital documents, and (3) mobile applications as a priority because they are necessary for accessing jobs, programs, and services. These include programs and services like:

As accessing these programs and services increasingly rely on web pages, digital documents, and mobile applications, the accessibility of these three technologies is an urgent priority for persons with disabilities.

In the next Phase, the ACARs could include additional accessibility requirements for other more complex digital technologies, such as artificial intelligence.

What are my organization's requirements and dates for compliance

The Phase 1 Regulations generally apply to all federal public service organizations, as well as federally regulated large and medium-sized private sector organizations. The requirements depend on whether an organization is public or private - and for private organizations, the requirements also depend on their size.

Regulatory requirements also depend on whether a regulated public or private sector organization is classified as a Transportation Service Provider (TSP) or a Broadcasting or Telecommunications Organization (BTO).

The Phase 1 Regulations generally apply to the following federally regulated organizations.

  1. Public sector organizations (excluding TSPs and BTOs)
    This includes:
    • Government departments and agencies
    • Crown Corporations
    • The Canadian Armed Forces
    • The Royal Canadian Mounted Police (RCMP)
    • Parliamentary entities (for example, House of Commons, Senate)
  2. Regulated private sector organizations (excluding TSPs and BTOs)
    This includes regulated private organizations with an average of:
    • 100-499 employees during the preceding three (3) calendar years (referred to as a medium-sized organization); or
    • 500 or more employees during the preceding three (3) calendar years (referred to as a large-sized organization).
  3. Transportation Service Providers (TSPs)
    This includes public sector and private sector organizations regulated and overseen by the Canadian Transportation Agency (CTA), subject to Part 1 of the Accessible Transportation for Persons with Disabilities Regulations (ATPDR). In the case of private sector organizations, they must have an average of:
    • 100-499 employees during the past three (3) calendar years (referred to as a medium-sized organization); or
    • 500 or more employees during the past three (3) calendar years (referred to as a large-sized organization).
  4. Broadcasting or Telecommunications Organizations (BTOs)
    This includes public sector and private sector organizations that are regulated by the Canadian Radio-Television and Telecommunications Commission (CRTC). In the case of private sector organizations, they must have an average of:
    • 100-499 employees during the past three (3) calendar years (referred to as a medium-sized organization); or
    • 500 or more employees during the past three (3) calendar years (referred to as a large-sized organization).

Exemptions from the Phase 1 Regulations

  1. Small-sized federally regulated private sector organizations (with an average of 99 or less employees) are fully exempt from all digital accessibility regulatory requirements.
  2. First Nations Band Councils are temporarily exempt from all requirements until December 31, 2033. See Section 2 of the Regulations Amending the Accessible Canada Regulations.
Did you know?

First Nations Band Councils are temporarily exempted from the Accessible Canada Regulations until December 2033 to give the Government of Canada more time to engage First Nation communities on reserve and other Indigenous communities on distinction-based legislative approaches to advancing accessibility.

Digital content fully exempt from the Phase 1 Regulations

The following digital content is fully exempt from all Phase 1 Regulatory requirements (see sections 19.4(4), 19.5(4), 19.51(4) and 19.52(4) of the Regulations Amending the Accessible Canada Regulations):

  1. reproduction or representation of heritage content on web pages, mobile applications, or digital documents, that is maintained by a regulated organization primarily for historical, artistic or aesthetic reasons, such as personal letters or diaries, photograph, film, art, architecture, printed material, audio recordings or other artifacts.
  2. user-generated content that may be uploaded to web pages, mobile applications, or digital documents, but not owned or contracted by the organization (for example, user input into public consultation forums, or survey submissions).
  3. content developed on employee-facing collaborative digital workplaces and environments (for example, SharePoint).

In the future, these exemptions may be removed as technology evolves.

What are the dates and requirements at a glance

This section provides a high-level overview of:

Use the following drop-down menu to select your organization classification and size to find the requirements specific to your organization.

Before using the drop-down menu, make sure you confirm:

  1. whether your organization is public or private
  2. whether your organization is classified as a BTO or a TSP
  3. the size of your organization if you are a private sector organization

This will help ensure you identify the correct requirements and dates for compliance related to your organization.

If your organization is classified as a BTO or a TSP, refer exclusively to the requirements listed for that category. For example, if your organization is the Canadian Broadcasting Corporation (CBC), you would select from the drop-down menu, "Public Sector Broadcasting or Telecommunications Organizations," not "Public Sector Organizations (excluding TSPs and BTOs)".

Important Notice and Disclaimer

For specific and the most up to date requirements, please always ensure to consult the Accessible Canada Act and the Accessible Canada Regulations. This guidance document is only meant to give a broad overview of requirements under the new regulations.

Always check the Accessible Canada Act and the Accessible Canada Regulations for your organization's specific requirements. If there is any conflict between this guidance and the Accessible Canada Act or Accessible Canada Regulations, the Accessible Canada Act or Accessible Canada Regulations takes precedence.

Requirements and Dates for Public Sector Organizations

Public Sector Organizations, including federal government departments, agencies, Crown Corporations, Royal Canadian Mounted Police, Armed Forces, and Parliamentary Entities (excluding TSPs and BTOs)

The following regulatory requirements and timelines generally apply to all organizations within the public sector.

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated Web pages

Section 19.4(1) and 19.5(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All non-employee and employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2027

3. New and updated Digital documents

Section 19.52(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All digital documents that are newly published or updated on non-employee facing web pages and mobile applications on or after the date below must meet clauses 4-7 and 10 of the ICT Standard.

Date: December 5, 2028

4. Mobile applications

Section 19.51(1) and 19.51(5) of the Regulations Amending the Accessible Canada Regulations

Two distinct requirements:

  1. All non-employee facing mobile applications that are newly published on or after the date below must meet clauses 4-7 and 11 of the ICT Standard.
    Date: December 5, 2028
  2. Conduct or obtain a conformity assessment with gap analysis against the ICT Standard for existing non-employee facing mobile applications.
    Date: This requirement must be met by December 5, 2028.
5. Accessibility statements for regulated content

Section 19.6(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Publish Accessibility statement(s) that:

  • provide an overview and describe the accessibility features of the regulated digital technologies
  • provide an overview of non-conforming digital technologies and plans to address those gaps
  • explain how users can access barrier-free alternatives

Of note, once published, Accessibility statements must be updated every 12 months thereafter.

Date: This requirement must be met by:

  • December 5, 2027 for web pages
  • December 5, 2028 for mobile applications and digital documents
6. Conformity assessment (procurement requirement)

Section 19.61 of the Regulations Amending the Accessible Canada Regulations

Requirement: Obtain a conformity assessment with gap analysis against the ICT Standard for products or services purchased on or after the date below, in connection with the development or provision of:

  • new and updated non-employee and employee-facing web pages, and
  • new non-employee facing mobile applications

Date: December 5, 2028

Public Sector Transportation Service Providers (TSPs)

The following regulatory requirements generally apply to service providers regulated and overseen by the Canadian Transportation Agency (CTA), subject to Part 1 of the ATPDR.

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated employee-facing Web pages

Section 19.4(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2027

3. Accessibility Statements for regulated content

Section 19.6(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Publish Accessibility statement(s) that:

  • provide an overview and describe the accessibility features of the regulated digital technologies
  • provide an overview of non-conforming digital technologies and plans to address those gaps
  • explain how users can access barrier-free alternatives

Of note, once published, Accessibility statements must be updated every 12 months thereafter.

Date: This requirement must be met by December 5, 2027.

4. Conformity assessment (procurement requirement)

Section 19.61 of the Regulations Amending the Accessible Canada Regulations

Requirement: Obtain a conformity assessment with gap analysis against the ICT Standard for products or services purchased on or after the date below, in connection with the development or provision of employee-facing web pages.

Date: December 5, 2028

Public Sector Broadcasting or Telecommunications Organizations (BTOs)

The following regulatory requirements generally apply to service providers regulated by the Canadian Radio-television and Telecommunications Commission (CRTC).

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated employee-facing Web pages

Section 19.4(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2027

3. Accessibility Statements for regulated content

Section 19.6(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Publish Accessibility statement(s) that:

  • provide an overview and describe the accessibility features of the regulated digital technologies
  • provide an overview of non-conforming digital technologies and plans to address those gaps
  • explain how users can access barrier-free alternatives

Of note, once published, Accessibility statements must be updated every 12 months thereafter.

Date: This requirement must be met by December 5, 2027.

Requirements and Dates for Private Sector Organizations (excluding TSPs and BTOs)

Private Sector – Large-sized Organizations

The following regulatory requirements generally apply to federally regulated large-sized private sector organizations (average of 500 or more employees during the preceding three calendar years).

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated Web pages

Section 19.4(1) and 19.5(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All non-employee and employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2028

3. New and updated Digital documents

Section 19.52(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All digital documents that are newly published or updated on non-employee facing web pages and mobile applications on or after the date below must meet clauses 4-7 and 10 of the ICT Standard.

Date: December 5, 2028

4. Mobile applications

Section 19.51(1) and 19.51(5) of the Regulations Amending the Accessible Canada Regulations

Two distinct requirements:

  1. All non-employee facing mobile applications that are newly published on or after the date below must meet clauses 4-7 and 11 of the ICT Standard.

Date: December 5, 2028.

  1. Conduct or obtain a conformity assessment with gap analysis against the ICT Standard for existing non-employee facing mobile applications.

Date: This requirement must be met by December 5, 2028.

  1. Accessibility statements for regulated content

Section 19.6(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Publish Accessibility statement(s) that:

  • provide an overview and describe the accessibility features of the regulated digital technologies
  • provide an overview of non-conforming digital technologies and plans to address those gaps
  • explain how users can access barrier-free alternatives

Of note, once published, Accessibility statements must be updated every 12 months thereafter.

Date: This requirement must be met by December 5, 2028.

6. Conformity assessment (procurement requirement)
Section 19.61 of the Regulations Amending the Accessible Canada Regulations

Requirement: Obtain a conformity assessment with gap analysis against the ICT Standard for products or services purchased on or after the date below, in connection with the development or provision of:

  • non-employee and employee-facing web pages, and
  • non-employee facing mobile application

Date: December 5, 2028

Private Sector - Medium-sized Organizations

The following regulatory requirements generally apply to federally regulated medium-sized private sector organizations (average of 100-499 employees during the preceding three calendar years).

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated Web pages

Section 19.4(1) and 19.5(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All non-employee and employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2028

Requirements and Dates for Private Sector Transportation Service Providers (TSPs)

Private Sector TSPs - Large-sized Organizations

The following regulatory requirements generally apply to service providers regulated and overseen by the Canadian Transportation Agency (CTA), subject to Part 1 of the ATPDR and who have an average of at least 500 employees during the preceding three calendar years.

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated employee-facing Web pages

Section 19.4(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2028

3. Accessibility Statements for regulated content

Section 19.6(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Publish Accessibility statement(s) that:

  • provide an overview and describe the accessibility features of the regulated digital technologies
  • provide an overview of non-conforming digital technologies and plans to address those gaps
  • explain how users can access barrier-free alternatives

Of note, once published, Accessibility statements must be updated every 12 months thereafter.

Date: This requirement must be met by December 5, 2028.

4. Conformity assessment (procurement requirement)

Section 19.61 of the Regulations Amending the Accessible Canada Regulations

Requirement: Obtain a conformity assessment with gap analysis against the ICT Standard for products or services purchased on or after the date below, in connection with the development or provision of employee-facing web pages.

Date: December 5, 2028

Private Sector TSPs - Medium-sized Organizations

The following regulatory requirements generally apply to service providers regulated and overseen by the Canadian Transportation Agency (CTA), subject to Part 1 of the ATPDR and who have an average of100-499 employees during the preceding three calendar years.

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated employee-facing Web pages

Section 19.4(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2028

Requirements and Dates for Private Sector Broadcasting or Telecommunications Organizations (BTOs)

Private Sector BTOs - Large-sized Organizations

The following regulatory requirements generally apply to service providers regulated by the Canadian Radio-television and Telecommunications Commission (CRTC) and, who have an average of 500 employees or more during the preceding three calendar years.

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated employee-facing Web pages

Section 19.4(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2028

3. Accessibility Statements for regulated content

Section 19.6(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Publish Accessibility statement(s) that:

  • provide an overview and describe the accessibility features of the regulated digital technologies
  • provide an overview of non-conforming digital technologies and plans to address those gaps
  • explain how users can access barrier-free alternatives

Of note, once published, Accessibility statements must be updated every 12 months thereafter.

Date: This requirement must be met by December 5, 2028.

Private Sector BTOs - Medium-sized Organizations

The following regulatory requirements generally apply to service providers regulated by the Canadian Radio-television and Telecommunications Commission (CRTC) and, who have an average of 100-499 employees during the preceding three calendar years.

1. Digital Accessibility Training for employees

Section 19.8(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: Provide training on the fundamentals of digital technology accessibility to employees involved in developing, maintaining, and/or purchasing of digital technologies.

Date: This requirement must be met by December 5, 2027, with refresher training at least once every three years thereafter.

2. New and updated employee-facing Web pages

Section 19.4(1) of the Regulations Amending the Accessible Canada Regulations

Requirement: All employee-facing web pages (including web applications) that are newly published or updated on or after the date below must meet clauses 4-7 and 9 of the ICT Standard.

Date: December 5, 2028

Additional requirements for all regulated organizations subject to the Phase 1 Regulations

All federal public sector organizations, medium and large private sector federally regulated organizations, TSPs, and BTOs must also keep digital copies of:

Determining feasibility of conformity

There may be reasons that some regulated digital technologies are unable to conform to the relevant clauses and requirements of the ICT Standard (see Section 19.3 of the Regulations Amending the Accessible Canada Regulations). These include, but are not limited to, the:

  1. unavailability of certain digital technologies that would permit conformity to the ICT Standard
  2. existence of significant obstacles to the implementation of the digital technology and efforts to overcome those obstacles
  3. degree of control over the digital technology, including under any agreement with a third party

Alternative measures

In instances where conformance with certain clauses and requirements of the ICT Standard is not feasible, and the non-conformance creates a barrier for a user or potential users, federally regulated organizations must offer temporary alternative measures that provide access to:

  1. key information provided on the regulated digital technology; and/or
  2. perform tasks associated with the digital technology

Alternative measures are not a permanent solution. As technologies evolve and improve over time, it is expected that regulated organizations continue working towards conformance to the ICT Standard to comply with the Phase 1 Regulations.

The dates for alternative measures are the same as the dates for each regulatory requirement outlined in the previous sections relevant to your organization. See Sections 19.4(2), 19.5(2), 19.51(2) and 19.52(2) of the Regulations Amending the Accessible Canada Regulations.

Digital content exempt from alternative measures

Maps, mapping services, technical drawings and images must conform to the relevant clauses and requirements of the ICT Standard as much as possible (for example, colour contrast). If not feasible, regulated organizations are not required to provide an alternative measure. See Sections 19.4(3), 19.5(3), 19.51(3) and 19.52(3) of the Regulations Amending the Accessible Canada Regulations.

Violations

Failure to meet the regulatory requirements under the Phase 1 Regulations are classified as minor violations. See Part 3 of Schedule 1 of the Regulations Amending the Accessible Canada Regulations.

Visit the Office of the Accessibility Commissioner website for more information on compliance and enforcement of the Accessible Canada Regulations.

Annex A: Common questions and answers

1. How do I calculate the average annual number of employees in my organization during the preceding three-year period?

To calculate the average number of employees:

  1. Count the average number of employees (including dependent contractors) for the previous calendar year. Start by adding together the highest number of employees for each month, divide the sum by twelve (12). Exclude any:
    • person employed as part of a student employment program; or
    • student employed solely during the student's vacation period.
  2. Round to nearest whole number. If the result is exactly between two whole numbers, round up.
  3. Repeat Step 1 and Step 2 for the second and third preceding calendar years.
  4. Add the average number of employees calculated for the past three (3) consecutive calendar years together and then divide by three (3) to determine the average of those three years.
  5. Round to nearest whole number. If the result is exactly between two whole numbers, round up.
  6. This total determines the average size of your organization. Below are two examples.

Example 1:

Consider the following scenario for a medium-sized regulated organization in 2026.

Table 1 shows the highest number of employees for every month for the preceding three consecutive years.

Example 1 - Table 1: the highest number of employees per month
Month 2023 2024 2025
January 72 112 520
February 55 97 480
March 63 108 495
April 48 103 505
May 59 101 510
June 66 106 490
July 57 109 515
August 62 95 485
September 53 110 500
October 61 102 525
November 64 104 475
December 60 115 510

Table 2 shows the total annual average of employees for the same preceding three years, by adding together the highest number of employees for each month, divide the sum by twelve (12), and then round that number to the nearest whole number.

Example 1 - Table 2: Annual average of employees
Year Annual Average
2023 60
2024 105
2025 501

The total average number of employees for the organization is calculated by adding the average from the three previous years and dividing by three.

(60 + 105 + 501) / 3 = 222

This total average number of employees for the past three consecutive years is 222. In 2026, this organization would be considered medium-sized.

Example 2:

Consider the following scenario for a large-sized regulated organization in 2026.

Table 1 shows the highest number of employees for every month of the past three consecutive years.

Example 2 - Table 1: the highest number of employees per month
Month 2023 2024 2025
January 466 746 369
February 436 686 364
March 455 657 300
April 489 711 358
May 412 715 329
June 530 665 350
July 467 724 311
August 441 742 361
September 501 743 369
October 535 668 305
November 515 649 367
December 453 694 477

Table 2 shows the total annual average of employees for the same preceding three years, by adding together the highest number of employees for each month, divide the sum by twelve (12), and then round that number to the nearest whole number.

Example 2 - Table 2: Annual average of employees
Year Annual Average
2023 475
2024 700
2025 355

The total average number of employees for the organization is calculated by adding the average from the three previous years and dividing by three

(475 + 700 + 355) / 3 = 510

This total average number of employees for the past three consecutive years is 510. In 2026, this organization would be considered large-sized.

Refer to the What are the dates and requirements at a glance section in the Guidance Overview to verify:

2. Do dependent contractors count as employees?

Yes. The definition of employee includes dependent contractors as defined in Section 1(1) of the Regulations Amending the Accessible Canada Regulations, and in subsection 3(1) of the Canada Labour Code.

3. What happens if my organization falls below the minimum employee requirements in a year? Would my organization still have to comply with the Phase 1 Regulations?

Regulated organizations that fall below the minimum employee threshold are still subject to the Phase 1 Regulations, unless they fall below the minimum employee threshold for the preceding three calendar years.

For example, if the average number of employees over the preceding three calendar years falls below 100, the regulated organization would be exempt from the Phase 1 Regulations.

4. What are web pages?

Under the Phase 1 Regulations, web pages are defined using the ICT Standard definition (see Section 19.1 of the Regulations Amending the Accessible Canada Regulations). For example, the term 'web page' covers all pages, including those associated with web applications and those that require permissions such as a login access.

A web application that opens in a browser on a mobile phone or a tablet and that does not require installation on the mobile device, is also included under the definition of web pages. For example: GC jobs or ArriveCan portals that can be accessed using a mobile phone.

5. What are 'employee-facing' web pages?

Under the Phase 1 Regulations, employee-facing web pages includes all web pages that are primarily intended to be used by the employees of a regulated organization (see Section 19.1 of the Regulations Amending the Accessible Canada Regulations), including web pages that can be accessed by contractors. For example, an internal network or portal that an organization uses for internal communications, tool and applications, or other administrative resources.

6. What are 'non-employee facing' web pages?

This includes all other web pages that are not primarily intended to be used by employees of an organization. For example, a public service information page, customer portals, corporate website homepage, among others.

7. What is an 'update' to a web page?

An 'update' to a web page means changes to any content on those pages. This applies to updates to both employee-facing and non-employee facing web pages.

8. If part of a digital technology is determined not feasible to conform to the ICT Standard, is it exempted?

No. If part of a digital technology or digital content is not feasible to conform to the ICT Standard, regulated organizations must still provide alternative measures until the non-conformance is corrected (see Sections 19.4(2), 19.5(2), 19.51(2) and 19.52(2) of the Regulations Amending the Accessible Canada Regulations).

The only digital content that is exempt from providing alternative measures include maps, mapping services, technical drawings and images (see Sections 19.4(3), 19.5(3), 19.51(3) and 19.52(3) of the Regulations Amending the Accessible Canada Regulations).

9. Why do regulated organizations have to reconsider feasibility of conformity with the requirements of the ICT Standard every time there is new digital content or an update to digital content?

Regulated organizations must reconsider feasibility of conformity with the requirements of the ICT Standard every time there is new or updated digital content because as technology evolves, the factors that determine the feasibility for conforming to the ICT Standard may also change. Newer technologies are now making it faster, easier, and cheaper to make digital technologies more accessible. Part of a digital technology that may not be feasible to conform with the requirements of the ICT Standard today may become feasible to conform with these requirements in the near future.

10. My organization now meets the requirements of a federally regulated organization, but after the date the Phase 1 Regulations came into effect. When am I required to comply?

You are subject to the Phase 1 Regulations the day in which your organization becomes a federally regulated organization.

11. What are alternatives to the ICT Standard?

There are two alternatives for regulated organizations to meet the requirements of the Phase 1 Regulations for their digital technologies (see Section 19.9 of the Regulations Amending the Accessible Canada Regulations):

  1. by conforming to any version of the European Telecommunications Standards Institute (ETSI) standard EN 301 549, Accessibility requirements for ICT products and services that is more recent than the ICT Standard; or
  2. by conforming to the version of the ICT Standard that immediately precedes the current version. However, only if the current version was published within the last three years.

12. Do the Phase 1 Regulations apply to organizations with operations outside of Canada?

The Phase 1 Regulations apply to all digital content primarily intended for Canadians or for employees whose place of work is in Canada. This applies to both federally regulated public and private sector organizations. For example, a bank operating a branch in Canada is required to comply with the Phase 1 Regulations for its Canadian operations.

13. What digital content is exempt from all Phase 1 Regulatory requirements?

Digital technologies that are exempt from all Phase 1 Regulatory requirements means that none of the Phase 1 Regulatory requirements apply to that content. This means that the specific digital content does not have to:

  1. conform to the ICT standard
  2. have an accessibility statement
  3. undergo a conformity assessment
  4. require document retention

14. What is the date for digital accessibility training for new employees hired after December 5, 2027?

All required employees, regardless of their date of employment, are required to receive and complete digital accessibility training. It is expected that any employee hired after December 5, 2027, would receive training as soon as possible, for example, as part of their onboarding.

15. What do you mean by 'existing' mobile applications?

This includes any mobile application that is still available for download from any app store or web page. Existing mobile applications do not include mobile applications that are removed and unavailable for download from any app store or web page.

16. Is employee digital accessibility training limited to the Phase 1 Regulatory requirements?

No. Digital accessibility training for employees is not limited to Phase 1 Regulatory requirements. Employee training is expected to cover the fundamentals of digital technology accessibility related to developing, maintaining, and/or purchasing of any digital technologies, not just the regulated web pages (including web applications), digital documents, and mobile applications.

17. What do you mean by a conformance assessment and gaps analysis? Would a Voluntary Product Accessibility Template (VPAT) cover this?

A conformity assessment and gap analysis describes which requirements from the ICT standard applies to the digital technology being purchased, and whether the digital technology conforms to those applicable requirements or not, and why.

A VPAT covers conformance assessment and gap analysis.

18. If we obtain a gaps analysis from a vendor, are we expected to ensure that it's accurate?

For all regulated organizations that are required to obtain a conformity assessment and gaps analysis, it is expected it will be produced or acquired in good faith.

19. How many accessibility statements must each regulated organization have? Is one sufficient?

Regulated organizations are required to publish at least one accessibility statement covering the areas for which they are required to comply with the Phase 1 Regulations.

Page details

2025-12-17