Canada’s first accessibility regulation became law in December 2025  

Background

The Accessible Canada Act came into force in 2019. With a focus on removing and preventing barriers, it aims to create a barrier-free Canada by January 2040.

Barriers related to Information and Communications Technologies (ICT) prevent people with disabilities from having equal and full access to everyday necessities like banking, government services, social media, etc. To address these types of barriers, Accessibility Standards Canada adopted the European Standard EN 301 549 as the national ICT Standard.

What’s happened

All published federal accessibility standards are voluntary, unless they’re adopted as regulation. Until December 2025, all our standards have remained voluntary. But now, in 2026, this is no longer the case.

The ICT Standard has been adopted into regulation. This means that federally regulated sectors like banks, telecoms, and transportation providers have some must-do’s.

When implemented, these new requirements will:

• Improve digital access for all users, including persons with disabilities
• Ensure digital technologies are designed to be compatible with assistive technologies
• Create proactive digital accessibility and inclusion

Context: Standards versus regulations

To date, Accessibility Standards Canada has published 8 standards. They cover areas like employment, service delivery, and plain language. In total, there will be 30 areas with accessibility standards.

Standards are developed in consultation with experts and people with disabilities across all sectors. They include guidance around best practices for accessibility.

While they’re written with language that suggests they are required, including many “should’s” and “will’s”, all standards begin as voluntary. They remain voluntary unless Accessibility Standards Canada submits them to the Minister of Diversity, Inclusion and Persons with Disabilities to be adopted into regulations.

Once a standard is adopted into regulation, it becomes mandatory for federally regulated organizations and federal government departments and agencies. To date, only 1 standard has become regulation: Accessibility requirements for ICT products and services regulation, which is also called the ICT Standard.

Who must comply with the regulation

The Phase 1 Regulations apply to all federal public service organizations, as well as federally regulated large and medium-sized private sector companies. Small private sector businesses with fewer than 100 employees are exempt, and First Nations Councils are temporarily exempt until 2033.

Provincially regulated entities can futureproof their digital properties

If your organization isn’t federally regulated, it’s important to note that most provincial governments have agreements with Accessibility Standards Canada that ensure provincial standards align with federal standards. This means we can safely assume that provincial standards for ICT will mirror what’s in the federal regulation.

You can futureproof your organization by reviewing the ICT Standard and ensuring that digital technology projects scheduled for 2027 onward align. Take advantage of your extended lead time and get started on training your digital teams now!

What’s included in the ICT Standard?

The ICT Standard covers digital technologies. This term encompasses a wide range of tools and services used to create, manage, transmit, and share information.

Although a guidance document from Employment and Social Development Canada recognizes a broad range of digital technologies, the regulation focuses on 3 types:

• new and updated web pages (employee-facing, and non-employee facing),
• New and updated digital documents, such as PDFs and Microsoft Word files on public-facing web pages and mobile applications digital documents,
• New public-facing mobile applications. 

Compliance requirements and timeline

Phase 1 Regulations apply to federal public service organizations and federally regulated large and medium-sized private sector companies. There are some slight differences in conformance requirements for Private Sector Transportation Service Providers and Private Sector Broadcasting or Telecommunications Organizations. Generally, here’s what’s required:

Requirements by Dec 5, 2027

• Provide Digital Accessibility Training for employees involved in developing, maintaining, and/or purchasing digital technologies. Refreshers must be provided to existing staff every 3 years, and new hires are expected to receive training as part of their onboarding.
• Ensure new and updated web pages conform to the ICT Standard.
• Ensure new and updated digital documents conform to the ICT Standard.
• Publish an accessibility statement for webpages to report non-conforming regulated digital content, including plans to address the gaps. 

Requirements by December 5, 2028

• Ensure new non-employee mobile applications meet conformance.
• Conduct a conformity assessment and gap analysis for mobile apps.
• Publish an accessibility statement to report non-conforming regulated digital content, including plans to address the gaps.
• Conduct or obtain a conformity assessment when purchasing anything related to regulated web pages and mobile applications.

Guidance from Employment and Social Development Canada (ESDC)

To dig further into the details, review the excellent guidance published by ESDC. It includes a helpful section titled “Phase 1 regulatory amendments at a glance” and an FAQ.

Connecting regulatory requirements and your accessibility plan

If you’re a federally regulated entity, and you’re working on your next accessibility plan, you should look for ways to connect the conformance requirements and your committed actions for 2027 and 2028. The Accessibility Commissioner and your customers will want to see that you’re planning to conform by the compliance deadlines.

How Untapped Accessibility can help

If you’d like help developing an implementation plan, or training your digital team, reach out to Untapped for support.