Publishing and handling your progress reports

From: Employment and Social Development Canada

On this page

• Introduction
• Publishing progress reports: timelines and notifications
• Publishing progress reports: locations
• Publishing progress reports: format and contents
• Publishing progress reports: handling and retention

Introduction

The Accessible Canada Regulations (regulations) say when, where, and how you must publish your organization’s progress reports. They also set rules for how you must handle and retain copies of those reports.

Exemptions

Remember: Not all organizations to which the ACA and its regulations apply need to publish progress reports. The regulations set out the details of these exemptions.

• Exemptions for organizations described in paragraph 7(1)(e) or (f) of the ACA that have an average of fewer than 10 employees
  • Read subsections 1(2) and 1(3) of the regulations to learn how to calculate your average number of employees
  • You can also consult the accessibility web pages of the CHRC’s website for examples of these calculations
• Exemptions for First Nations Band Councils, applying for a period of 5 years from the day (December 13, 2021) that the regulations came into force

Publishing progress reports: timelines and notifications

The regulations set the following planning and reporting cycle for federally regulated organizations:

• year 1: publish an accessibility plan and a feedback process description
• year 2: publish a progress report on the implementation of the accessibility plan
• year 3: publish a second progress report
• year 4: publish an updated accessibility plan
• year 5: publish a progress report on the implementation of the updated accessibility plan; continue the cycle as before

The deadline for publishing a first accessibility plan is not the same for all organizations. The deadline for publishing progress reports is based on the deadline for the accessibility plan.

Note: these deadlines may differ for organizations to which the Canadian Radio-television and Telecommunications Commission Accessibility Reporting Regulations and the Accessible Transportation Planning and Reporting Regulations apply. Check these regulations for progress report deadlines for different classes of organizations.

Organizations must publish progress reports by the anniversary of the deadline for publishing their most recent accessibility plan. Different types and sizes of organizations have different deadlines:

• federal government organizations (including departments, agencies, Crown corporations and government-related organizations such as the Canadian Forces or Parliamentary organizations)
  • publish first accessibility plan by December 31, 2022
  • publish first progress report by December 31, 2023
• private sector organizations with an average of 100 or more employees
  • publish first accessibility plan by June 1, 2023
  • publish first progress report by June 1, 2024
• private sector organizations with an average of between 10 and 99 employees
  • publish first accessibility plan by June 1, 2024
  • publish first progress report by June 1, 2025

Read the section on publishing accessibility plans to learn more about these deadlines.

Remember: as with accessibility plans and feedback process descriptions, you must notify the Accessibility Commissioner within 48 hours after publishing a progress report. You must send this notification by email or other electronic means. The notice must include either:

• the URL address of the progress report
• a hyperlink to the progress report, or
• the mailing addresses of the places of business at which you are displaying a print copy of the progress report

Your organization may also have to notify the Canadian Radio-television and Telecommunications Commission (CRTC) or the Canadian Transportation Agency (CTA). Read the section on different regulatory and enforcement authorities for details about these responsibilities.

Publishing progress reports: locations

You must publish your progress report on the main digital platform that you own, operate, or control. This platform must be one that you use to communicate with the public, such as your organization’s website or digital portal. The progress report must be accessible either directly on the home screen or homepage, or by a hyperlink from that home screen or homepage.

If you do not have such a digital platform, you must still publish progress reports. You must display printed copies of the reports in the reception area or entrances of each of your places of business. These locations must be clearly visible and accessible to the public.

Publishing progress reports: format and contents

The regulations do not say how long your progress reports must be. The reports are to show your progress in implementing your accessibility plan. This is especially true for the concrete actions you set out in that plan. Read the section on what you must include under each of the progress report’s required headings.

If you publish your progress reports online, they must meet the requirements for Level AA conformance in the most recent WCAG officially available in French and English (currently WCAG 2.1).

Here are some additional suggestions for making your progress reports accessible:

• use properly formatted and nested headings from your word processing program’s style sheet (Heading 1, Heading 2, and so on)
• use size 12 or 14 sans serif fonts
  • serifs are decorative features, like hooks or tails, that some fonts include in letters
  • popular sans serif fonts include Arial, Calibri, and Helvetica
• use strong colour contrast; black text on a white background is best
• use images, tables, and other visual elements only when necessary
  • ensure all images and tables have captions or alternative text (“alt text”) describing their purpose and contents

Read more on creating accessible documents for more recommendations and tips. You can also consult the Government of Canada’s Digital Accessibility Toolkit and the Canada.ca Content Style Guide for more tips.

Simple, clear, and concise language

The regulations require that you write your progress reports in language that is simple, clear, and concise.

Using such language will ensure that your report 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.

Read the guidance on simple, clear, and concise language for more recommendations and tips.

Publishing progress reports: handling and retention

You must make copies of your progress reports available in the following formats upon request:

• print
• large print
• braille
• audio format
• an electronic format compatible with adaptive technology intended to assist persons with disabilities

Read the guidance on alternate formats for more recommendations and tips about making alternate formats available.

Organizations must make progress reports available in these formats according to the deadlines in the regulations. While all regulated organizations must make these formats available as soon as feasible, but within the applicable deadlines set in the regulations, the deadlines depend on the type of format and organization.

• For print, large print, and electronic formats:
  • federal government organizations, including departments, agencies, Crown corporations, or government-related organizations such as the Canadian Forces or Parliamentary organizations: within 15 days of a request
  • private sector organizations with an average of 100 or more employees: within 15 days of a request
  • private sector organizations with an average of 99 or fewer employees: within 20 days of a request
• For braille or audio formats:
  • all organizations: 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. You can also consult the accessibility web pages of the CHRC’s website for examples of these calculations.

Retaining copies of progress reports

Once you publish a progress report, you must retain a copy of it that is accessible to the public. How and where you retain this copy will depend on how and where you published the progress report.

• If it was published on your main digital platform, retain a digital copy on that platform
• If it was displayed in the reception or entrance area of your place(s) of business, retain a print or electronic copy at each place

You must retain a copy of each progress report for at least 7 years from the day by which you had to publish it. This applies equally to digital, print, and electronic copies.