Backgrounder 1 - Digital Technologies Accessibility Regulations: Accessibility barriers, benefits and priorities for action

Note: This document was originally developed as a public consultation module. It has been updated and reformatted as a backgrounder following the finalization of Digital Technologies Accessibility Regulatory amendments in December 2025 (SOR/2025-255). For information on the earlier consultation and what we heard from participants, see the Phase 1 consultation.

List of abbreviations

ATM: Automated teller machine
EPT: Electronic payment terminal
ICT: Information and communication technologies
iOS: iPhone operating system
MS: Microsoft
NASCIO: National Association of State Chief Information Officers
PDF: Portable document format
TTS: Text to speech
URL: Uniform resource locator

Background

The term Information and communication technologies (ICT), (digital technologies hereafter) includes everything we use to communicate and do business online. Some examples:

Websites
Web applications such as web-based email, web-based online banking
Non-web (digital) documents like PDF and MS Word files, presentations such as PowerPoint
Software such as Windows, iOS, Skype and QuickBooks
Mobile hardware such as smartphones and tablets
Stationary hardware such as ATMs and self-service kiosks for parking payment
Other hardware, including computers, mice, keyboards, scanners and printers
Assistive technology like screen readers and Braille displays
Virtual meeting platforms like Webex, Microsoft Teams and Zoom

Digital technologies play an increasingly important role in our work and personal lives. The COVID-19 pandemic has made it even more critical to our livelihood and wellbeing. For many people, access to everything from health care to education depends on their access to digital technologies. Services have increasingly moved online, a trend that is expected to continue.

Improving accessibility of digital technologies will allow persons with disabilities and other Canadians to participate fully in their communities. It will also reduce barriers to accessing and keeping employment.

Since the time this material was developed, the Government of Canada has finalized the Phase 1 Digital Technologies Accessibility Regulations under the Accessible Canada Act. They were published in the Canada Gazette, Part II on December 17, 2025 (SOR/2025-255). Requirements for federally regulated entities will apply in stages beginning in 2027 and 2028.

What are digital technologies barriers

The Accessible Canada Act (ACA) defines a barrier as "anything […] that hinders the full and equal participation in society of persons with an impairment […] or a functional limitation^{Footnote 1}."

Digital technologies barriers are created when digital technologies are not designed to be inclusive, with a broad range of users in mind. This can make it difficult or impossible for some persons with disabilities to send an email or use everyday technology like a phone. Digital technologies barriers can also prevent individuals from accessing and benefitting from services and programs. In Canada, close to 45% of Canadians with disabilities say they have encountered a digital technologies-related barrier with a federal organization or business^{Footnote 2}.

Overview of barriers

The sections that follow provide an overview of some of the main digital technologies barriers.

Overview of barriers: web content

Web content refers to text, audio or visual content published online. Examples include websites, blogs, podcasts, shopping websites and online banking.

The World Wide Web Consortium^{Footnote 3}. Web Accessibility Initiative (W3CWAI) defines web accessibility as follows:

Web accessibility means that websites, tools and technologies are designed and developed so that persons with disabilities can use them

When web content is accessible, people can:

perceive, understand, navigate and interact with the web
contribute to the web

Barriers to web accessibility impact persons with different disabilities, including:

auditory
cognitive
neurological
physical
speech
visual

Web accessibility also benefits people without disabilities, for example:

people using mobile phones, smart watches, smart TVs and other devices with small screens, different input modes, etc.
people with situational limitations such as in bright sunlight or in an environment where they cannot listen to audio
people using a slow internet connection, or who have limited or expensive bandwidth

Poor website navigation design

Poor website navigation design is a common reason for inaccessible web content. The design often does not consider assistive technology that persons with disabilities may use to navigate the web.

Examples:

Website menus designed to work only when the user positions their mouse over them
These menus are not accessible, especially for persons with disabilities who use assistive technology with a keyboard interface
Poorly organized level and order of headings on a web page
A person using a screen reader may have to listen to the whole page to find the content they want
Well-designed headings allow them to skip down the page to find the content they are looking for

Inaccessible tables and lack of alternative text

Tables on websites can present challenges for people who use screen readers.

Examples:

Poorly identified table row or column headers:
- To work well, screen readers require well-identified row or column headers
Their performance can also be affected by tables that contain split, merged, blank cells or nested tables
Nested tables (table within a table):
- A screen reader may have problems navigating and might get stuck inside a cell

Tables should only be used for data organized into simple rows and columns and, must have alternative text to explain their content.

Lack of alternative text for images, captions on videos, text transcripts or audio description* tracks*

Screen readers do not recognize images and infographics. Therefore, images and infographics on a website must be accompanied by alternative text that describes what they are saying. Alternative text needs to be clear and concise, allowing users to navigate content quickly and efficiently.

Videos can be excellent tools for sharing ideas and educating people. However, without captions, text transcripts or audio descriptions, persons with disabilities may not be able to access their content. Captions and text descriptions also benefit anyone viewing in noisy environments, such as on public transit.

Colour, contrast and font size issues in web content

Examples of barriers for people with low vision or colour blindness:

Using colour alone to convey meaning; for example, using a red circle to indicate "incorrect"
Inadequate colour contrast between background and text on a webpage
A lack of text resizing features and inadequate colour contrast in closed captioning

Flashing effects and very bright colours are also an accessibility barrier for people who are sensitive to light. They can trigger seizures in individuals with epilepsy, and be distracting to individuals with autism or other cognitive disabilities.

Web chat features that don't work with assistive technology

Some websites have live chat features, like a chat box to speak to a customer service agent. Sometimes these features don't work with assistive technology, such as speech recognition software.

Inaccessible web forms

Web forms are online documents that allow users to enter information for various purposes. For simple web forms, the user may only need to enter a name and email address to subscribe to a newsletter. Complex web forms, like a job application, require the user to enter a lot of information.

Some examples of accessibility problems with web forms:

Web forms and links that are not correctly coded
- Individuals using screen readers won't know what information they need to provide in the form
- Individuals using speech recognition software may not be able to access or navigate the form
Links and buttons on web forms that show up as symbols or images but are not labelled appropriately
- For example, buttons with a "+" sign are commonly used to represent adding something to a list
- If not labelled appropriately, a screen reader would simply read "+" as "plus"
- The user would not know that the symbol indicates an area where information can be added
For security reasons, many forms time out quickly, creating barriers for anyone needing more time to fill them out

Hyperlink issues

Websites use hyperlinks so users can navigate to other pages on the same site or to other websites. If not properly coded, hyperlinks can create barriers to accessibility. Links should describe where they are taking the user. Vague link text like "click here" or "read more" doesn't tell the reader where a link goes. This creates barriers for people who use screen readers.

Web content inaccessibility on mobile devices

Many persons with disabilities use mobile devices for their built-in accessibility features. However, websites and web applications are not always designed with mobile accessibility in mind. As a result, web content that is accessible on desktop could be inaccessible on smart phones and tablets.

Overview of barriers: non-web (digital) documents

Digital documents include PDF and MS Word files, as well as presentations in PowerPoint or other formats. The barriers explained above for web content also apply to digital documents. These include:

documents not written in plain language
lack of alternative text for images, graphs and tables
excessive use of images and similar elements
lack of colour contrast and appropriate font size and text resizing feature
lack of headings and reading order issues
multiple slides in presentations having the same title
inaccessible form fields and links

Many users print digital documents and forms to use offline. For this reason, documents that contain live or embedded links to other sites must also include the full address for the webpage (URL) for the links.

Overview of barriers: software

Software includes all desktop and mobile applications, as well as the systems that run them. Examples of software are Windows, iOS, Microsoft Teams, Skype and Zoom. The software's design determines how people can interact with the software.

When software is designed without consideration for a range of abilities, it creates barriers for users, including persons with disabilities.

Incompatibility with assistive technology

Software that is not compatible with assistive technology can create barriers. It is impossible for users to enter the required inputs or receive the desired outputs from the assistive technology.

One example of an assistive technology is switch devices. Switch devices enable users to select and input whole words or phrases instead of typing them out in full using a keyboard. For this type of assistive technology to work, the computer or tablet must have software that allows the switch device to send it input. A lack of such software makes the device inaccessible to the user.

Lack of integration with computer operating systems

Some software applications do not use the standard interactive elements that come with the operating system of a device. Instead, these applications may interact directly with the screen or keyboard bypassing the operating system altogether. This can create significant barriers for users, including persons with disabilities.

For example, some users may have adjusted the default settings of their operating system to improve accessibility of their devices. Examples of this are increasing the default font size or changing the colour scheme. Software applications that bypass the operating system may ignore these changes and make the application inaccessible to these users.

Enterprise software that is difficult to use

Enterprise software is designed to meet the needs of an organization rather than individual users. Organizations use such software for a range of internal tasks, including managing human resources and processing payments. Governments, businesses and schools typically use enterprise software.

Enterprise software can be very complex, requiring specialized skills and knowledge to use. Unfortunately, accessibility is often not considered in its design. This can create significant barriers to employment or career advancement for persons with disabilities.

Inaccessible virtual meeting platforms

Virtual meetings can deliver a lot of information visually and via audio. A lack of accessibility features can make it very difficult for persons with disabilities to participate meaningfully in a virtual meeting. To be inclusive and accessible, virtual meeting software should include features such as closed captioning, automatic transcripts, screen reader support and magnifiers^{Footnote 4}.

Software that enables screen reading, for example, would help attendees with visual impairments participate fully. The screen reader could convey useful information, such as who joins the meeting.

Virtual meeting software should also be compatible with text to speech (TTS) synthesis^{Footnote 5}, to ensure access for those who cannot speak or have learning disabilities such as dyslexia.

It is important to note that accessible and inclusive software is only one aspect of accessible and inclusive virtual meetings. It is also important to provide accessible and inclusive materials and to schedule meeting times to accommodate a range of abilities.

Overview of barriers: mobile devices

Many smartphones that are available today include accessibility features, making them an important tool for persons with disabilities and other users. These include:

the ability to turn on audio descriptions (for videos that have audio description tracks)
screen readers
screen magnifiers, and
compatibility with hearing devices

However, users can sometimes face barriers when using mobile devices like smartphones and tablets.

Small screen issues

The small screens on some mobile devices can present a barrier for people with low vision or with dexterity-related or cognitive disabilities. Examples:

The "zooming in" function can help to address some of the concerns of small screens

However, it also pushes content off the screen, making it difficult to navigate the page
Zooming in also pixelates and distorts texts and images

Menus can take up a large space on the screen, leaving less room for other content
To operate a mobile device, users often need to use small motions

This can be difficult for individuals with movement and dexterity challenges
For example, a small screen usually means less space between interactive elements
This increases the chances of selecting the wrong option by accident

No alternatives to touchscreen functionality

With some mobile devices, the only way to enter information is through the touchscreen, using gestures such as swiping, sliding and two-finger pinch zoom. However, a touchscreen can create barriers for people who rely on different methods to provide input. Allowing for alternate ways to provide input, like through keyboards or speech, makes the mobile device accessible to more people.

Challenging environmental conditions and locations

Environmental conditions and location can have a significant impact on the accessibility of mobile devices. People can face barriers in some workplaces and public spaces where they can't control their environment. Issues such as low or poor lighting, excessive bright light, glare or a lot of noise can cause significant barriers.

Overview of barriers: stationary hardware

Stationary hardware includes devices that stand on the floor (such as an information kiosk) or are mounted on a wall or other immovable structure, such as an automated teller machine (ATM).

Inaccessible physical location

Physical inaccessibility of information kiosks and automated teller ATMs can create significant challenges for persons with disabilities. For example:

Some individuals may not be able to operate an ATM or kiosk if the controls are set too far back
Some machines don't provide enough room for wheelchair users' legs, feet and toes
Wheelchair users may not be able to read displays if the screen is set too high or at a bad angle

Physical effort required

Kiosks that require physical effort to operate can cause barriers for users with mobility-related disabilities. For example, some individuals may have trouble pressing buttons or keys, turning knobs or inserting and removing cards or tickets.

Complexity concerns

Many people, including those with cognitive disabilities and low digital literacy, face additional barriers while using stationary hardware. For example, kiosks might have complex information and features and/or may time-out after a set period.

Overview of barriers: other hardware

"Other hardware" includes things like:

the physical parts of computers, mice and keyboards
office equipment like printers and scanners
electronic payment terminals (EPTs), handheld or fixed, that customers use to pay for goods or services using debit or credit cards

Absence of hardware, input and/or output connection points that are compatible with assistive technology

The inaccessibility of mice or keyboards is an example of a hardware-related barrier. For individuals with limited upper-extremity function or dexterity challenges, it can be difficult or impossible to use a standard mouse or keyboard. For example, keys or other mechanical parts may require too much force to operate.

A variety of hardware can address these barriers, including modified keyboards, trackballs, head-pointing devices and joysticks. These devices allow a person to use their chin, hands or other body parts to direct a cursor and operate the hardware. It's important to note that these products may require adjustments to meet an individual user's needs.

Closed systems that do not allow users to attach, install or use assistive technology^{Footnote 6}

Some types of hardware, such as kiosks that only have screens, allow only 1 method of entering information. They may not allow people to use alternative input devices. This prevents persons with disabilities, including those with dexterity challenges, from accessing the hardware.

Physical issues such as small screens and heavy hardware

In Canada, most stores and restaurants now have EPTs. For most people, they are a fast and convenient way to pay.

For persons with disabilities, EPTs can create major barriers. For example, EPTs usually have small screens and no alternative output methods, such as audio. People with vision impairment and older adults may have trouble reading information on the small screens. Some EPTs may be too heavy to hold for individuals with certain mobility-related disabilities. Some EPTs are also more complicated to operate than others, making them difficult for people with cognitive disabilities to use.

In these situations, a customer with disabilities may have to ask for help completing their purchase. They may also have to share their personal identification number with a stranger.

Overview of barriers: assistive technology

Technology that can make digital technologies more accessible is increasingly available. Screen readers, speech recognition software and other assistive technology are now common. But persons with disabilities who use these technologies continue to face barriers to accessing digital technologies^{Footnote 7}.

These barriers include:

accessibility features that are not always enabled on hardware and software
lack of supports, such as awareness and training for persons with disabilities, and
lack of knowledge and guidance when purchasing, installing or learning to use assistive technology

Other intersecting factors

Intersecting sociodemographic factors can make access to digital technologies products and services even more difficult for some people, including those with disabilities. For example, living in rural or remote areas where access to high-speed internet is not available can create barriers. Other factors that affect digital technologies accessibility could be a lack of digital literacy. Digital products and services designed with the digital literacy of technically savvy young people in mind can exclude many users.

COVID-19 pandemic

The global COVID-19 pandemic has underlined the importance of digital connectivity. Digital connectivity has allowed businesses to continue operating, children to continue their education and people to obtain goods and services online.

The pandemic has also exposed significant areas of inequity and exclusion as a result of the digitization of services and products. This is especially true for certain populations, for example, those lacking digital literacy or living in areas with no access to high-speed internet, as well as some individuals with disabilities.

It's estimated that 1 billion people around the world live with some form of disability^{Footnote 8}. In 2020, the International Telecommunications Union (the United Nations' specialized agency for digital technologies) organized a public webinar on digital accessibility during COVID-19. Participants pointed to the importance of implementing digital technologies accessibility on a global level. This would assure everyone's right to communicate and be part of the digital world, during and after the pandemic.

Participants emphasized that the design of digital information must consider the needs and abilities of all users. The kind of digital technologies they use to access information should not matter.

The 2020 UN disability-inclusive response to COVID-19 policy brief identified that when providing public health information, digital technologies accessibility is an important factor to ensure that pandemic responses and recovery include persons with disabilities.

Benefits of accessible digital technologies

Accessible digital technologies are designed inclusively, considering a wide range of abilities and disabilities. It enables users to interact with technology or digital content in ways that work best for them.

The US National Association of State Chief Information Officers says: "ICT accessibility ensures that people with and without disabilities can access the same information, perform the same tasks, and receive the same services using information technology. It is the digital equivalent to accessibility in the physical environment, the ramps, railings, etc., of the digital age^{Footnote 9}."

Accessible digital technologies offer many benefits to persons with disabilities, including:

equal access to education and skills training
potential access to more specialized employment opportunities
easier access to health services and information
more opportunities to participate in the cultural, social and political lives of their communities, and
greater independence, for example, using everyday digital technologies like ATMs and EPTs without having to ask others for help

Without accessible digital technologies, many persons with disabilities will be denied access to the ever-growing number of digital products and services.

At the same time, accessible digital technologies benefits everyone. For example:

building accessible digital products gives businesses access to larger markets
all employees are more productive when the technology they work with is easy to use
captioning can help anyone who is viewing a video in a noisy environment or who isn't proficient in the language of the video
large fonts and better colour contrast make it easier for people of all abilities to read signs in the workplace
accessible websites help customers find the information they need without having to contact customer service
organizations can access larger candidate pools and do better at retaining employees

Accessible digital technologies design focuses on ease of use, resulting in a better experience for all users. Siri, the voice assistant on Apple devices, is a good example. Siri was developed with funding from the U.S. Defense Advanced Research Projects Agency. Originally, the voice assistant was intended to improve digital technologies accessibility for persons with disabilities. Today, Siri and similar technologies make life easier for all users.

Accessible digital technologies creates employment, health and social opportunities, enhancing the personal and professional lives of people with and without disabilities. While some benefits of accessible and inclusive digital technologies can be monetized, not all the benefits can be measured in dollars and cents alone.
The COVID pandemic has shown the value of digital technologies’ intangible benefits. Virtual meeting platforms, smartphones and other digital technologies helped families stay connected during lockdowns. Digital technologies helped millions of Canadians avoid social isolation, a significant risk to social cohesion, health and wellbeing.

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2026-10-19