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Guidance for Providing Training on Digital Accessibility Fundamentals

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 understanding of regulatory requirements 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

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List of Acronyms
ACARs
Accessible Canada Regulations
ACR
Accessibility Conformance Report (a completed VPAT®)
BTO
Broadcasting or Telecommunications Organizations (entity)
CHRC
Canadian Human Rights Commission
ESDC
Employment and Social Development Canada
ICT
Information and Communication Technologies
TSP
Transportation Service Providers
VPAT®
Voluntary Product Accessibility Template
WCAG
Web Content Accessibility Guidelines

Guidance on regulatory requirements

For federally regulated public and private sector organizations to which the new Phase 1 Regulations apply, digital accessibility training is mandatory for all employees involved in the development, maintenance, or purchasing of digital technologies. See section 19.8(1) of the Regulations Amending the Accessible Canada Regulations.

This guidance is meant to help organizations understand the regulatory requirements set by the Accessible Canada Regulations (ACARs) pertaining to employee training on digital technology accessibility fundamentals.

Important reminder

The requirements for employee training on digital accessibility fundamentals represent the minimum requirements. Regulated organizations are encouraged to build and continuously update a robust training program that goes beyond the minimum requirements, where appropriate.

Why training on digital accessibility fundamentals matters

The training requirements aim to gradually build employee knowledge by building practical knowledge, awareness and skills to:

  • understand regulatory requirements and prepare for future requirements on more complex digital technologies
  • build capacity on digital accessibility within organizations and equip employees with knowledge and skills to work with external contractors
  • apply the ICT Standard and other tools with confidence, helping make digital technology usable for everyone

Over time, successfully incorporating accessible digital technology education into practice will help foster a shift towards greater accessibility of digital technologies from the start. Continuous training will further keep pace with emerging digital technologies.

Did you know?

Digital accessibility training lays the foundation for accessible and inclusive organizations by equipping employees with essential knowledge to identify, prevent, and remove digital technology barriers before they are created. When digital technologies are designed to be accessible, they not only empower persons with disabilities, but also enhance usability for everyone.

Which organizations does the training requirement apply to

The regulatory requirement for digital accessibility training applies to all federally regulated public and private sector organizations covered by the new Phase 1 Regulations:

  1. Public sector organizations regardless of size, including:
    1. public sector transportation service providers (TSPs)
    2. public sector broadcasting or telecommunications organizations (BTOs)
    3. all other federal public sector organizations including federal government departments, agencies, Crown Corporations, Royal Canadian Mounted Police, Armed Forces, and Parliamentary Entities (other than TSPs and BTOs)
  2. Private sector organizations, which had an average of 100 or more employees during the preceding three-year period, including:
    1. private sector transportation service providers (TSPs)
    2. private sector broadcasting or telecommunications organizations (BTOs)
    3. all other federally regulated private sector organizations (other than TSPs and BTOs)

The requirement and date for compliance are the same for all these organizations.

No training is required for private sector organizations which had an average of 99 or less employees during the preceding three-year period, as they are fully exempt from the Phase 1 Regulations. Refer to the Phase 1 Regulations Guidance Overview for more information.

When is the deadline to provide training

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

Which employees must receive training

Federally regulated organizations must provide training on digital accessibility fundamental to employees involved in the development, maintenance, or purchasing of digital technologies, regardless of the extent of their involvement. This includes all operational and full-time or part-time employees, dependent contractors, and students. There are no exemptions for training based upon employment status (such as, full-time, part-time), level, or seniority.

The Phase 1 Regulations do not specify the type, level or classification of employee that requires training because not every regulated organization is structured the same. Each regulated organization must identify the employees who are responsible for, or contribute to, the development, maintenance, or purchase of digital technologies and make sure they receive training on digital accessibility fundamentals.

Important reminder

Under the Phase 1 Regulations, an employee means any person employed by a regulated entity described in paragraph 7(1)(e) or (f) of the Accessible Canada Act.

This also includes a dependent contractor as defined in subsection 3(1) of the Canada Labour Code; a person who works for and depends financially on one organization, even if they are not formally employed by that organization.

What should the training cover

The Phase 1 Regulations set minimum requirements for training on digital accessibility fundamentals but do not specify training content, formats or other requirements. This is intentional because every federally regulated organization is unique, including how they use digital technologies as well as the roles and responsibilities of their employees.

Annex C offers hypothetical training programs for employees that could be responsible for the development, maintenance and purchase of digital technologies. It is up to every organization to identify the:

  • employees that are responsible for the development, maintenance or purchase of digital technologies
  • digital accessibility fundamentals that would be appropriate for their organization and employees

While the regulations only require training to include digital accessibility fundamentals, regulated organizations may wish to tailor their training to make it more relevant and effective to exceed regulatory requirements.

Important reminder

The requirements for employee training on digital accessibility fundamentals represent the minimum requirements. Regulated organizations are encouraged to build and continuously update a robust training program that goes beyond the minimum requirements, where appropriate.

Planning and developing your employee training

Effective digital accessibility training begins with a clear plan. Organizations without an existing training program must make sure all required employees receive training on digital accessibility fundamentals by the applicable regulatory deadline. Refer to Annex B for a list of suggested steps to support organizations in the planning and implementation of employee training.

Organizations that already have meaningful training in place may continue to provide such training so long as it supports employees that are responsible for the development, maintenance, or purchasing of digital technologies.

Did you know?

Providing digital accessibility training to employees is more than just meeting a regulatory requirement - it can be a strategic advantage. It ensures digital products and services are inclusive, user-friendly, and aligned with the growing accessibility standards worldwide, reducing barriers that limit access and engagement for all people, including persons with disabilities.

Developing your training: objectives and expected outcomes

To help organizations develop their training that would meet the regulatory requirements, it is a best practice to consider employee and organizations outcomes.

By the end of employee training, employee objectives would include:

  • understanding the legal and regulatory requirements for the Phase 1 Regulations, including the relevant clauses of the ICT Standard that removes digital accessibility barriers before they start

Other optional and theoretical employee objectives could include:

  • identifying and applying accessibility and inclusive design theory practices and principles to remove and prevent digital accessibility barriers

By the end of employee training, organizational objectives would include:

  • meeting or exceeding regulatory requirements by the appropriate regulatory date for compliance
  • increasing employee confidence, competence, and capacity to identify, address, and prevent digital accessibility barriers

Other optional and theoretical organizational objectives could include:

  • applying accessibility and inclusive design theory principles and practices from the start
  • ensuring digital technologies are more usable, inclusive, and trusted by the public

Training format and delivery methods

The Phase 1 Regulations do not specify a particular format of how organizations are to deliver employee training. Training could include any effective format or blended approach that would best fit the needs and resources of the organization and the employee. Examples of potential formats and delivery methods could include:

  • interactive webinars
  • self-paced learning
  • expert-led sessions with Question and Answers (Q&A)
  • practical exercises with sample templates
  • leadership coaching sessions with real-world examples
  • workshops with scenario-based learning (for example, procurement policy, program design)
  • any other format that is effective for your organization and employees

Retention of training records

All federally regulated organizations subject to the Phase 1 Regulations must maintain digital records of completed employee digital accessibility training for at least 4 years from the date the training was completed.

While the Phase 1 Regulations do not specify what the digital records must include, it is expected that each regulated organization retain relevant information to prove that the training was complete. These records could include the:

  • name of the employee that received the training and their role in relation to the development, maintenance, or purchasing of digital technologies
  • type of training provided, content, format, and duration
  • date the training was completed

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.

Contact us

If you have questions or comments about this guidance document, please contact EDSC.LCA.REGLEMENTS-REGULATIONS.ACA.ESDC@servicecanada.gc.ca.

Annex A: Common questions and answers

1. Who is responsible for providing digital accessibility training?

Each federally regulated organization covered by the Phase 1 Regulations is responsible for the planning and delivery of employee training.

2. Is there a specific training format required?

Each regulated organization can decide the training format most suitable for their needs. While external resources (for example, modules, courses, educators, etc.) may be used, organizations must ensure the training is appropriate, effective, and completed by the regulatory deadline. Every organization is also not bound to the training format they select for the first year. As technology and regulatory requirements change, organizations are encouraged to improve the content and the delivery of training over time.

3. Is training limited to web pages, mobile applications and digital documents under the Phase 1 Regulatory requirements?

Employee training is expected to cover digital accessibility fundamentals related to the development, maintenance, or purchase of any digital technologies, not just web pages, mobile applications and digital documents.

4. Is it mandatory for the training to focus on the Accessible Canada Act?

No, the training must pertain specifically to digital accessibility fundamentals and support the implementation of the applicable clauses of the ICT Standard in order to comply with the Phase 1 Regulations.

5. Will guidance provide an outline or curriculum for organizations to use as a template?

Due to differences in organizational needs and capacity, it would not be possible to provide a specific or meaningful training outline or curriculum for each regulated organization. Each organization will have to identify their own relevant and effective training for their employees.

6. Who will identify and provide training for federal public service organizations?

The Canada School of Public Service is developing employee training for the federal public service organizations.

7. Is it possible to purchase a training program or curriculum?

The Phase 1 Regulations do not require organizations to purchase accessibility training. Many organizations may find resources available online; however, the effectiveness of these resources can vary. Organizations should ensure that any training resources, whether free or purchased, is appropriate, meaningful, and supports compliance.

8. What are the steps to identify or provide effective training?

There is not one correct way to identify or provide effective training. Annex C includes a list of potential steps for how you and your organization can identify and provide training for your employees.

9. How would organizations know if the training is effective?

Digital accessibility training is more that just checking a box. If done correctly and effectively, it is a powerful tool to improve the quality and outcomes of your organization. Comprehension alone does not guarantee skill development.

While it is not a requirement to determine whether your organization's training is effective, it is a best practice to consider measuring improved skill, understanding and digital accessibility improvement over time. This could include:

  • pre/post training self-assessments
  • scenario-based policy exercise submissions
  • quarterly check-ins to explore new case studies or challenges
  • monitoring the organization's digital technologies for improvements in usability

Together, these approaches may help to ensure training is meaningful, effective, and aligned with the goal of enhancing digital technology accessibility and inclusion.

10. Is the refresher training required to be the same as the initial training?

The Phase 1 Regulations do not specify or require the refresher training to be the same or different from the initial training. Organizations are welcome to reuse or build upon the training they've provided, so long as it remains effective.

11. Do regulated organizations have to train employees that are not involved in the development, maintenance, or purchasing of digital technologies?

Digital accessibility training is currently only required for employees of regulated organizations that are involved in the development, maintenance, or purchasing of digital technologies.

12. Do managers and directors, or other decision-makers require training?

The regulations do not specify or limit the role where training must stop; rather, the expectation is that anyone whose role meaningfully affects digital accessibility through the development, maintenance or purchasing of digital technologies, would also receive training. This could include managers, directors or other decision-makers.

13. Does digital accessibility training have to be the same for each employee?

The Phase 1 Regulations do not specify any requirements related to the content or structure for specific employees. Regulated organizations are welcome to tailor employee training to match the roles and responsibilities of their employees, should they choose to do so.

14. Is digital accessibility training required for dependent contractors?

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

This means that any dependent contractor involved in the development, maintenance, or purchasing of digital technologies also requires training on digital accessibility fundamentals.

15. What is the difference between an independent and a dependent contractor?

Dependent contractors are legally considered employees, because they:

  • work for one organization and are economically dependent on that organization, even if not formally employed
  • perform work that is integrated into the organization's ongoing operations

Independent contractors are not legally considered employees, because they:

  • are not economically dependent on one organization
  • do not perform work that is integrated into the organization's ongoing operations

16. Why do independent contractors not require training?

Independent contractors are not considered employees. Regulated organizations are not obligated to provide them with employee training on digital accessibility fundamentals.

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

All employees involved in the development, maintenance, or purchasing of digital technologies, regardless of their date of employment, are required to receive and complete training on digital accessibility fundamentals. 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.

Annex B: Best practices for identifying and providing digital accessibility training

Use this Annex to help your organization understand the general steps to identify and provide digital accessibility training for your employees.

Important Notice and Disclaimer

The following steps are meant to assist organizations with best practices for identifying and providing digital accessibility training for employees. They are a non-exhaustive list that could help organizations in the planning or delivery of such training. These steps are meant to inspire and help organizations to identify useful resources.

1. Assess training needs and objectives
2. Design the employee training program
3. Develop or source relevant content, tools, and other materials
4. Implement employee training
5. Evaluate and improve training
6. Follow-up and support

Annex C: Case studies for the practical application of relevant training requirements

While the Phase 1 Regulations do not specify content requirements, there is an expectation that the digital accessibility training will be relevant and effective. It is a general best practice to structure training into manageable topics.

Use this Annex to understand how a training program or curriculum could be structured to be more relevant for employees. Each regulated organization would provide their employees with a training structure based upon their size, needs, and available resources.

Important Notice and Disclaimer

These following case studies provide theoretical training curriculums for employees who would be responsible for the development, maintenance, or purchasing of digital technologies. Some modules may include a non-exhaustive list of resources that could help organizations in the planning or delivery of such training. These resources are meant to inspire and help organizations to identify useful resources - not necessarily require organizations to apply them.

It is up to each regulated organization to provide their employees with an effective training program that supports the employee's role and work objectives. This includes identifying the employees required to receive training, choosing the relevant training curriculum and supportive learning resources, and determining the most effective delivery method to provide such training that complies with the Accessible Canada Regulations.

Private Sector Digital Accessibility Training

Consider the following theoretical learning curriculum for private sector employees involved in the development, maintenance, or purchasing of digital technologies.

Learning Objectives

By the end of the training, participants should:

  1. understand the legal and regulatory requirements for the Phase 1 Regulations, including the relevant clauses of the ICT Standard that removes digital accessibility barriers before they start
  2. identify and apply accessibility and inclusive design theory practices and principles to remove and prevent digital accessibility barriers

Organizational Outcomes

By the end of the training, the organization should:

  1. meet or exceed regulatory requirements by the appropriate dates for compliance
  2. increase employee confidence, competence, and capacity to identify, address, and prevent digital accessibility barriers
  3. apply accessibility and inclusive design theory principles and practices from the start
  4. ensure digital technologies are more usable, inclusive, and trusted by the public

Structure

For this example, training is structured into manageable topics designed to build knowledge, awareness, and practical skills to identify, prevent, and address digital technology accessibility barriers.

Module 1: Introduction to digital accessibility

Content could include:

  • overview of the range of disabilities and the barriers associated with digital technologies
  • assistive technology (screen readers, voice recognition, etc.), keyboard navigation, and focus management
  • digital accessibility and inclusive design theory
  • why it matters: legal, ethical, and business case

Examples of potential useful resources:

Module 2: Regulatory requirements, compliance, and risk management

Content could include:

  • overview of relevant accessibility laws, regulations, and standards
  • regulatory requirements and penalties for non-compliance
  • understanding accessibility statements, conformance assessments, document retention, and alternative measures
  • risk mitigation strategies

Resources could include:

Module 3: The business case for digital accessibility

Content could include:

  • identifying barriers embedding accessibility and inclusive design in the Return on Investment (ROI) of digital accessibility
  • case studies of successful digital accessibility transformation

Module 4: Digital accessibility in practice

Content could include:

  • embedding accessibility and inclusive design for digital transformation
  • identifying practical actions employees can implement within their organization to address and prevent digital accessibility barriers

Resources could include:

Module 5: Procurement and vendor management

Content could include:

Resources could include:

Module 6: Leadership and culture for senior management and executives

Content could include:

  • providing appropriate training for employees
  • role of business owners in fostering inclusion and responsibility for ensuring conformance to the appropriate accessibility standard
  • communicating accessibility priorities internally
  • setting performance indicators and governance tools: policy tracking, stakeholder engagement, accountability

Module 7: Tools, resources, and support

Content could include:

  • basic accessibility testing tools (WAVE)
  • accessibility statements, conformance assessment reports, Voluntary Product Accessibility Templates (VPATs)
  • independent testing and user testing with persons with disabilities
  • continuous accessibility improvement strategies
  • quarterly or annual accessibility audits

Module 8: Monitoring and improvement

Content could include:

  • keeping up with emerging tools, standards, and best practices

Public Sector Accessible Digital Technology Training

Consider the following theoretical learning curriculum for public sector employees involved in the development, maintenance or purchasing of digital technologies.

Learning Objectives

By the end of this training, participants will be able to:

  1. understand the legal and regulatory requirements for the Phase 1 Regulations, including the relevant clauses of the ICT Standard that removes digital accessibility barriers before they start
  2. identify and apply accessibility and inclusive design theory practices and principles to remove and prevent digital accessibility barriers

Organizational Outcomes

By the end of the training, organization should:

  1. meet or exceed regulatory requirements by the appropriate dates for compliance
  2. increase employee confidence, competence, and capacity to identify, address, and prevent digital accessibility barriers
  3. apply accessibility and inclusive design theory principles and practices from the start
  4. ensure digital technologies are more usable, inclusive, and trusted by the public

Structure

For this example, training is structured into manageable topics designed to build knowledge, awareness, and practical skills to identify, prevent, and address digital technology accessibility barriers.

Module 1: Introduction to Digital Accessibility

Content could include:

  • overview of the range of disabilities and the barriers associated with digital technologies
  • assistive technology (screen readers, voice recognition, etc.), keyboard navigation, and focus management
  • digital accessibility and inclusive design theory
  • why it matters: legal, ethical and business case
  • federal disability inclusion policies and strategies

Resources could include:

Module 2: Regulatory requirements, compliance, and risk management

Content could include:

  • overview of relevant accessibility laws, regulations, and standards
  • regulatory requirements and penalties for non-compliance
  • understanding accessibility statements, conformance assessments, document retention, and alternative measures
  • risk mitigation strategies

Resources could include:

Module 3: Digital accessibility in practice

Content could include:

  • embedding accessibility and inclusive design for digital transformation
  • identifying practical actions employees can implement within their organization to address and prevent digital accessibility barriers
  • procurement strategies: referencing "Guide for Including Accessibility in ICT Related Procurement"
  • governance tools: policy tracking, stakeholder engagement, accountability

Resources could include:

Module 4: Procurement and vendor management

For effective training for most public service organizations, more than one training or module would be required.

Content could include:

  • accessibility requirements and clauses for solicitations and non-competitive contracts
  • evidence of conformance to the ICT Standard for third-party tools and services
  • contract management practices, including managing non-conformance
  • procurement strategies: referencing "Guide for Including Accessibility in ICT Related Procurement"

Resources could include:

Module 5: Web and digital application development

For effective training for most public service organizations, more than one training or module would be required.

Content could include:

  • core accessibility requirements for digital technologies
  • key standards (for example, WCAG) relevant to developers and designers
  • accessible front-end practices (for example, keyboard access, contrast, semantics)
  • accessibility testing during development (e.g., assistive technologies, automated tools)
  • coding and documentation practices to prevent introducing new accessibility barriers

Resources could include:

Module 6: Accessible policies, programs, and digital service delivery

For effective training for most public service organizations, more than one training or module would be required.

Content could include:

  • how policies and programs create or remove digital accessibility barriers
  • how to integrate digital accessibility into policies, digital governance, and services standards
  • accessibility requirements for digital public services (for example, online applications, forms, portals)
  • processes for feedback, monitoring, and addressing accessibility issues
  • procurement and vendor considerations in policy and program delivery

Resources could include:

Module 7: Leadership and culture for senior management and executives

For effective training for most public service organizations, more than one training or module would be required.

Content could include:

  • role of business owners in fostering inclusion and responsibility for ensuring conformance to the appropriate accessibility standard
  • communicating accessibility priorities internally
  • setting performance indicators for accessibility
  • developing appropriate training for employees
  • governance tools: policy tracking, stakeholder engagement, accountability

Module 8: Tools, resources, and support

Content could include:

  • basic accessibility testing tools (WAVE)
  • accessibility statements, conformance assessment reports, Voluntary Product Accessibility Templates (VPAT®)
  • independent testing and user testing with persons with disabilities
  • continuous accessibility improvement strategies
  • quarterly or annual accessibility audits

Resources could include:

Module 9: Monitoring and improvement

Content could include:

  • keeping up with emerging tools, standards, and best practices

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2026-06-30