Webinar recap: Aligning your Accommodations Policy with Canadian Accessibility Standards

In this webinar, Untapped Accessibility addressed how HR and accessibility professionals can modernize their accommodations policy to align with accessibility standards.

Since Accessibility Standards Canada released voluntary federal Accessible Employment Standards in 2025, many organizations are unsure where to start.

In this session, we walked through what the standards say about accommodations and how to assess your existing process. Untapped unpacked the principles articulated in the standards and how to apply them to a review of your organization’s policy or process.

Key takeaways from the webinar included:

How the standards address accommodations

Accommodations are only part of an organization’s larger employment accessibility strategy

An accommodations policy shouldn’t be your only policy that addresses accessibility and inclusion for disabled workers—it’s one tool in the accessibility toolbox. Accommodation is one of 13 policy domains listed as essential to an employment accessibility strategy (clause 10.5.2.). Your organization also needs an accessibility-specific policy that focuses on proactive and intentional barrier identification, removal, and prevention (clause 10.5.3).

All policies—including the accommodations policy—must support accessibility and inclusion of disabled workers by focusing on the identification, removal, and prevention of barriers.

Accommodation and accessibility are not the same

Accessibility is the proactive work of identifying, removing, and preventing barriers before they interfere with access. An accessibility policy is focused on an organization-wide commitment to improve access for workers with disabilities by proactively identifying, removing, and preventing barriers.

Accommodation is changing an existing condition to remove or minimize a barrier for someone—and it’s usually made at the request of the person who’s already experienced the barrier. An accommodation policy is focused on responding to individual instances where barriers interfere with a worker’s access.

Both accommodations and accessibility are important

An accessibility policy allows you to be proactive about inclusion and catch barriers before they cause problems.

An accommodation policy provides a pathway for people with disabilities to come forward with additional needs.

How they are related

Your accommodation policy should accomplish two things:

1.Outline how you will respond to the barriers that are reported via accommodation requests in a timely manner.

2.Outline how you will apply what you learn from each accommodation request to improve broader accessibility.

Principles for designing accommodations policies

Within the standards, there are key principles that should inform your revised policy. In clause 14.2 of the standards, the following principles are noted:

• Accessibility first: Make sure you balance proactive barrier identification and removal with a responsive accommodation process
• Worker-centered approach: Respect the integrity of the worker when they describe their needs and make a request
• Social model focus: Focus the process on evaluating workplace conditions instead of obtaining medical proof of need
• Driven by lived experience: Prioritize the worker’s preferences as much as possible
• Optimal approach: Focus accommodations on creating conditions that allow the worker to fully engage in all aspects of work—instead of providing the minimum change needed
• Truly collaborative: Ensure the worker is a central participant to all collaborative accommodation discussions, not just the subject of these discussions

What else does the standard say?

Accommodations policy should ensure that:

The standards flag that accommodations should be portable (workers continue getting what they need if they change roles within the organization). They also note that it’s important that requests are managed in a timely manner.

The standards also recognize that not every accommodation will be fulfilled as requested. In these cases, clear and honest explanations should be provided when requests cannot be fully implemented—and the rationale is documented.

While many accommodations policies may have been designed to protect the organization, or limit the number of accommodations, the standards call employers to aim to a yes by default approach, which means approaching each request with a can-do attitude and seeking ways to support the employee.

An accommodations policy should ensure that:

• Support is available without medical documentation where possible
• Examples are included to support understanding of the process
• Roles and responsibilities within the process are clearly defined—and proper training is provided to anyone involved
• The process is clearly communicated to all workers.

How to evaluate your current policy

Untapped recommends 5 key areas to examine in your current policy. These are areas where your changes can align the new policy with the standards:

1.Review descriptions of legal duties to ensure they’re accurately reflected

2.Scan for any mention of proving need with medical evidence and re-focus the section on barrier removal

3.Take note of how requests are managed to ensure that any evaluation is against the limits of undue hardship

4.Examine entry points into the process and ensure there are multiple pathways to initiate accommodation

5.Add a section on how accommodations inform larger accessibility improvements

How Untapped can help

If the process feels daunting, or you just don’t have the capacity, Untapped can help. We have experience working with organzizations to review their processes and policies in many areas. We can customize an approach that works for your budget.

Reach out to us and let’s chat!