Accessible Canada Act: What it Means for Your Business’s Digital Presence

If you’re in a federally regulated organization, or you build digital properties for one, The Accessible Canada Act (ACA) matters. It’s not just about fixing accessibility issues, it’s about planning, reporting, and proving ongoing progress toward a barrier-free Canada.

If you’ve got multiple websites, portals, apps, PDFs, and teams shipping every week, the ACA is really asking one question: can you consistently identify, remove barriers, and prevent barriers from reappearing?

TL;DR

• The Accessible Canada Act aims for a barrier-free Canada by 2040, covering seven priority areas (including ICT).
• It applies mainly to federally regulated organizations – banks, telecom/broadcasting, federal transportation – plus federal bodies, departments, and the RCMP.
• Orgs covered by the ACA must publish a three-year accessibility plan, consult people with disabilities, run feedback processes, and publish annual progress reports.
• Digital rules reference CAN/ASC-EN 301 549 and phase in with key dates Dec 5, 2027 and Dec 5, 2028. Enforcement via the Accessibility Commissioner, CTA, and CRTC includes penalties up to $250,000 per violation.

What is the Accessible Canada Act?

At its core, the Accessible Canada Act is Canada’s federal framework for achieving a barrier-free Canada by January 1, 2040. It takes a proactive approach: instead of waiting for discrimination complaints, it pushes organizations to identify and remove accessibility barriers, and, just as importantly, prevent barriers from being introduced in the first place.

The Act defines a “barrier” broadly, not just in terms of stairs, ramps, and elevators: it includes anything physical, architectural, technological, attitudinal, information/communications-based, or policy/practice-based that hinders the full and equal participation of people with disabilities.

The ACA focuses on seven priority areas:

• Employment
• The built environment (buildings and public spaces)
• Information and communication technologies
• Communication (other than ICT)
• Procurement of goods, services, and facilities
• Design and delivery of programs and services
• Transportation

One detail that often gets overlooked is that the Act recognizes sign languages, including Indigenous sign languages, as primary languages of Deaf people in Canada, and includes them explicitly under “communication” as a priority area.

So, which federally regulated organizations are actually subject to these compliance requirements?

Who needs to comply with the Accessible Canada Act?

The ACA applies to organizations under federal responsibility, which is a specific slice of Canada’s economy and public sector – not every business in Canada.

Federally regulated entities and federal organizations include:

• The federal government, including government departments, agencies, and Crown corporations
• The Canadian Forces and the Royal Canadian Mounted Police
• Parliamentary entities, such as the House of Commons, Senate, Library of Parliament, and Parliamentary Protective Service
• Parts of the private sector regulated by the Government of Canada, including:
  • Banks
  • The federal transportation network – airlines and rail/road/marine transportation providers that cross provincial or international borders
  • The broadcasting and telecommunications sectors

In practice, that means many organizations beyond those in the public sector and the ecosystems that support them.

What about everyone else, such as retailers, healthcare providers, provincially regulated services, manufacturers, and more? They’re usually governed by provincial accessibility laws rather than the Canada Act, unless they operate inside a federally regulated industry.

Once you know you’re an organization subject to the ACA, or you deliver services into that world, the next step is the operational heart of compliance.

Accessible Canada Act accessibility plan requirements

If you strip away the legal language, the ACA’s planning and reporting model is basically: commit, consult, publish, prove progress, repeat.

Under the Act and the Accessible Canada Regulations, most covered organizations must:

1. Prepare and publish accessibility plans describing how they will identify, remove, and prevent barriers
2. Update plans every three years
3. Consult people with disabilities when creating or updating plans
4. Maintain feedback processes so people can report barriers
5. Publish progress reports that explain what’s been done, and how feedback was considered

What must be in the plan?

Plans should map actions across the priority areas that are relevant to your organization. For example, for digital teams, the “information and communication technologies” area is usually front and center.

The Regulations also push for clear structure, like identifying a contact person or job title for receiving feedback and making the plan easy to find and request in alternate formats.

Publication and accessibility of your published documents

Your plan, feedback-process description, and progress reports typically need to be published online if you have an online presence. They also need to meet WCAG Level AA expectations, which includes document accessibility, not just web pages.

Progress reports are annual

Progress reports need to be completed on a yearly basis. The Regulations summary explains that organizations must publish progress reports by the first and second anniversary of the deadline, so they’re effectively reporting annually during the three-year cycle.

Key planning and reporting deadlines

The Regulations summary laid out initial deadlines like this:

• Federal government, Crown corporations, Parliamentary entities, RCMP, and Canadian Forces: first plans by Dec 31, 2022
• large businesses (100+ employees): first plans by June 1, 2023
• small businesses (10–99 employees): first plans by June 1, 2024

So far, this is the governance layer. The next section is where it gets very real for product, engineering, and content teams, as we look at the ACA’s digital accessibility requirements and the phased deadlines attached to them.

Key compliance deadlines for digital accessibility

Canada introduced Phase 1 Digital Technologies Accessibility Regulations by adding “Information and Communication Technologies” requirements into the Accessible Canada Regulations. These rules apply to web pages, digital documents, and mobile applications, and they’re tied to the CAN/ASC-EN 301 549 (ICT) Standard.

Here are the headline milestones (phased by organization type):

The government guidance frames Phase 1 as building capacity, so digital technologies are designed to be accessible from the start, not retrofitted after launch.

Also note that the amendments include obligations around training, conformity assessments, record keeping, and accessibility statements.

Digital accessibility standards under the ACA

For years, many teams treated WCAG as the web accessibility benchmark. Under the ACA, WCAG is still important, but it’s no longer the whole story.

WCAG still matters, especially for published plans and reports

The Accessible Canada Regulations require certain published documents, like accessibility plans and progress reports, to be posted in formats that meet WCAG Level AA expectations.

The digital technology benchmark is CAN/ASC-EN 301 549

Phase 1 digital requirements reference the ICT Standard, defined as Accessibility Standards Canada’s CAN/ASC-EN 301 549 – as amended over time.

This matters because EN 301 549 covers a broader remit than just your web pages. It’s designed for procurement and evaluation across:

• Web-based technologies
• Non-web software
• Mobile apps
• Documents and other ICT services

Accessibility Standards Canada has published CAN/ASC-EN 301 549:2024 as a national adoption of the European EN 301 549 standard.

ACA compliance does not equal WCAG checkboxing

Even if your team hits WCAG success criteria, ACA compliance still expects operational proof:

• Governance through accessibility plans and progress reports
• Consultative processes – make sure you consult people with disabilities
• Feedback processes and responsiveness
• Procurement checks, training, and documentation under the digital rules

And when you miss? That’s where enforcement comes in, so let’s talk about how the ACA is enforced, who enforces it, and what the legal risk actually looks like.

Enforcement mechanisms and penalties

The ACA isn’t voluntary guidance. It has real enforcement, and it’s split across regulators depending on the sector.

Who enforces what?

From the Government of Canada’s summary:

• The Accessibility Commissioner enforces the Act for most organizations and priority areas, including the Government of Canada, parliamentary entities, and banks.
• The Canadian Radio-television and Telecommunications Commission (CRTC) enforces within the broadcasting and telecommunications sectors for priority areas in its jurisdiction.
• The Canadian Transportation Agency enforces within the federal transportation network for priority areas in its jurisdiction.

What can happen if you don’t comply?

Enforcement tools include inspections, production orders, compliance orders, notices of violation, and compliance agreements.

Penalties can be significant. The summary notes notices of violation can require payment of up to $250,000 per violation, and the Regulations summary breaks penalties into minor, serious, and very serious ranges that can reach that maximum.

Complaints, and why saying you’re compliant isn’t a shield

If a regulation under the Act isn’t met, individuals can file accessibility complaints. Depending on context:

• Many complaints go to the Accessibility Commissioner
• Transportation-related complaints go to the Canadian Transportation Agency
• Broadcasting/telecom complaints go to the CRTC
• Complaints related to accessibility for most federal public servants and parliamentary employees can go through the grievance process handled by the Federal Public Sector Labour Relations and Employment Board

Also, accessibility complaints under the ACA are different from discrimination complaints under the Canadian Human Rights Act, and meeting ACA requirements doesn’t prevent Canadian Human Rights Commission processes under that separate framework.

So, what about organizations that have the more complex reality of operating across provinces, where provincial accessibility legislation can apply alongside federal rules?

How the ACA relates to provincial accessibility laws

The ACA covers federal jurisdiction. Provincial laws cover everything else – and many large organizations straddle both.

If you’re a national brand with the following:

1. Federally regulated business lines in banking, telecom, and/or transportation
2. Provincially regulated locations/services,

Then you may need to comply with both federal requirements and the accessibility legislation of each Canadian province you operate in.

A few examples of provincial accessibility legislation:

• Ontario’s Accessibility for Ontarians with Disabilities Act (AODA)
• Manitoba’s Accessibility for Manitobans Act
• British Columbia’s Accessible British Columbia Act
• Nova Scotia’s Accessibility Act
• Newfoundland and Labrador’s Accessibility Act
• New Brunswick’s Accessibility Act (newer framework)

The practical takeaway for digital teams: treat accessibility as a shared baseline across all digital properties, then layer jurisdiction-specific requirements (like statements, reporting cycles, or procurement rules) on top.

So how do you turn all of this – plans, standards, deadlines, and enforcement – into a workflow your teams can actually sustain? Let’s finish with an implementation playbook.

Building accessible digital products for ACA compliance

You don’t achieve accessibility once and then never have to worry about it again. You build a system that keeps accessibility from regressing every sprint, every content upload, and every redesign.

Below is a practical workflow that maps cleanly to the ACA’s expectations: prevent barriers, remove barriers, and report openly.

1. Tie product work to your accessibility plan

Your accessibility plans should be actionable for digital teams.

• Translate plan commitments into a roadmap, with quarterly themes and concrete deliverables
• Define what “done” means with acceptance criteria tied to WCAG and the ICT Standard where relevant
• Assign an internal owner, often a product ops lead, accessibility lead, or platform owner

These steps make progress reports easier because you’re tracking work continuously, not reconstructing it at year-end.

2. Build guardrails into design and engineering

If you want fewer accessibility issues, stop relying on heroics at the end.

Here are some practical guardrails to set up:

• Design systems – Accessible components, tokens, and patterns, like focus states, contrast, error messaging, and motion
• Semantic HTML and ARIA restraint – use native elements first and document ARIA usage patterns
• Keyboard-first checks – Every UI shipped should be usable without a mouse
• Screen reader smoke tests – Quick checks catch real-world friction that automated tools miss

These steps directly support the ACA principles around dignity, equal participation, and meaningful options.

3. Treat document accessibility as a product surface

Under the ACA, digital isn’t only your marketing concern. PDFs, forms, statements, and policy documents are often where barriers hide.

Make the following routine:

• Publish tagged PDFs, with reading order, headings, link text, and table structure
• Ensure download experiences are accessible with clear file naming and format options
• Include document checks in content publishing workflows

This aligns with the broader ICT scope and reduces last-minute remediation work.

4. Test like you ship

A balanced testing stack looks like this:

• Automated checks in CI – Great for regressions and obvious failures
• Manual audits per release – Keyboard, focus order, form flows, and screen reader passes
• User feedback channels that actually get actioned – The ACA expects feedback processes, not just an inbox

5. Make accessibility bugs easy to report, and impossible to ignore

Many enterprise teams fall down when accessibility issues are found, but the reports are vague, missing context, and hard to reproduce.

A strong reporting workflow captures:

• Exact URL and environment
• Steps to reproduce
• Expected vs. actual behavior
• Screenshots/annotations
• Technical metadata, such as browser, OS, and viewport)
• Severity and affected users

Tools like Marker.io help here because you can collect visual feedback directly from your site, annotate problems, like focus traps or missing labels, and send structured reports to your preferred PM tool. Accessibility issues get triaged like any other defect, not buried in a spreadsheet, which also makes your progress reporting and record keeping dramatically easier.

6. Prepare now for the digital deadlines (don’t wait for December)

If your organization is in scope for the Phase 1 rules, build a runway:

• Inventory your digital properties, e.g., web apps, mobile apps, documents, and third-party embeds
• Prioritize high-traffic and high-risk flows, e.g., auth, payments, account management, and support
• Schedule audits and remediation cycles ahead of the Dec 5, 2027, and Dec 5, 2028 milestones

Conclusion

The Accessible Canada Act is pushing federally regulated organizations toward systemic change –  not just fixing individual barriers, but building a repeatable way to prevent barriers, consult people with disabilities, and report progress openly, year after year.

If you’re on the hook for an accessibility plan, or you support an organization that is, the fastest wins come from operationalizing accessibility, such as clearer bug reports, tighter triage, better documentation, and fewer regressions across your digital properties.

If you want to make accessibility issues easier to capture, reproduce, and fix – without endless back-and-forth – try Marker.io to turn in-context website feedback into structured tickets your team can actually ship.