Digital Accessibility Law in Canada: the ACA, the 2025 Rules and the AODA

The Accessible Canada Act: Who It Covers

The Accessible Canada Act (S.C. 2019, c. 10) received Royal Assent on 21 June 2019 and, apart from section 205, came into force on 11 July 2019. Section 5 sets its purpose: a Canada without barriers on or before 1 January 2040, reached by identifying, removing and preventing barriers in employment, the built environment, information and communication technologies, other communication, procurement, the design and delivery of programs and services, and transportation.

It is a federal law, so it reaches only what Parliament regulates. Section 7(1) applies it to:

• Federal departments and agencies in Schedules I to V of the Financial Administration Act, Crown corporations, designated parts of the federal public administration and the Canadian Forces
• Any person or organisation operating a work, undertaking or business within the legislative authority of Parliament: in practice banks, telecommunications and broadcasting, airlines, rail, interprovincial and international transport, ports, pipelines, and postal and courier services
• Certain others, including First Nations band councils, and, with modifications under Part 9, Parliament itself

The regulatory impact statement's examples of federally regulated private organisations are “banking, parcel services, pipeline companies, trucking companies, feed, flour, seed and grain companies, uranium mining”. Most retail, e-commerce and software businesses are provincially regulated and outside the Act. If that describes you, skip ahead to the provinces.

Enforcement, penalties and complaints

Enforcement is split by sector. The Canadian Radio-television and Telecommunications Commission (CRTC) handles broadcasters and telecom carriers, the Canadian Transportation Agency (CTA) handles the transportation network, and the Accessibility Commissioner, a member of the Canadian Human Rights Commission, handles everyone else. The Commissioner can inspect (section 73), order production of documents (section 74), make compliance orders (section 75), issue notices of violation with a warning or a penalty (Part 5), enter compliance agreements (section 82), and publish the name of a violator, the nature of the violation and the penalty (section 93).

The penalty figures need reading carefully. Section 91(2) caps any single violation at $250,000, but the regulations sort violations into minor, serious and very serious, and every digital duty in the 2025 amendments is classed minor. For a regulated entity other than a small business, the minor ranges are:

Two things raise the stakes. Under section 88, a violation that continues on more than one day is a separate violation for each day. And the regulations' lower “small business” ranges are for organisations with fewer than 100 employees, who are exempt from the digital duties anyway, so every business covered by them faces the full ranges above. The $250,000 ceiling is reached only by the top range for very serious violations. There is a two-year limitation period (section 90).

Individuals can complain too. Under section 94(1), anyone harmed or otherwise adversely affected by a breach of regulations made under section 117(1) may complain to the Accessibility Commissioner; federal public servants with grievance rights use that route instead. Remedies under section 102 include corrective measures, lost wages and expenses, extra costs of alternatives, and compensation for pain and suffering up to an amount that was $20,000 in the year the section came into force and is indexed annually, with the same amount again for a wilful or reckless practice. Because the digital duties sit in section 117 regulations, inaccessible new web content becomes complainable once they are in force. The Commissioner's 2025 to 2026 report puts it plainly: “As new regulations come into force, the scope of complaints possible under the Accessible Canada Act will expand.”

The Accessible Canada Regulations: Plans, Feedback and Progress Reports

The Accessible Canada Regulations (SOR/2021-241) were registered on 13 December 2021 and came into force that day. They already impose three duties on federally regulated organisations, and these are what the Commissioner has been inspecting:

• An accessibility plan. First plans were due 31 December 2021 for the federal public sector, 1 June 2022 for private organisations with 100 or more employees and 1 June 2023 for those with 10 to 99. Plans are updated every 36 months, written in plain language, with a heading for each priority area and one for consultations.
• A feedback process. A person designated by title receives feedback by mail, phone, email and any other means used with the public, anonymous feedback is allowed, and receipt is acknowledged.
• Progress reports. Published in the two years between plans, with a feedback section added.

Plans and progress reports must be published on the organisation's main digital platform, linked from the homepage, “in a format that meets the requirements for Level AA conformance” of WCAG, and the Commissioner must be notified within 48 hours. Alternate formats (print, large print, Braille, audio, electronic) must be supplied on request: Braille and audio within 45 days, others within 15 days for the public sector and organisations with 100 or more employees, or 20 days for smaller ones. Records are kept for seven years. Private organisations with fewer than 10 employees are exempt from all three duties.

One detail is easy to miss. The regulations define WCAG as “the most recent version that is available in both English and French”. W3C published the authorised French translation of WCAG 2.2 on 17 March 2025, so in our analysis plans and progress reports should now be published to WCAG 2.2 AA. That is our reading of two verified facts, not a statement from the regulator.

The 2025 Digital Amendments (SOR/2025-255): Who Must Do What, and When

The Regulations Amending the Accessible Canada Regulations, SOR/2025-255 (P.C. 2025-886), were made on 5 December 2025 and published in the Canada Gazette Part II on 17 December 2025, after a draft in Part I on 21 December 2024 and a consultation that drew about 800 participants to seven technical briefings and 170 written comments. They add a new Part 1.1, “Information and Communication Technologies” (sections 19.1 to 19.9), and they are final. As of 11 November 2026, the Justice Laws consolidation still lists them as amendments not in force, because section 18 sets two later dates: the second anniversary of registration, 5 December 2027, and the third, 5 December 2028.

Size is measured by the average number of employees over the preceding three-year period, counting dependent contractors and excluding students in student employment programmes. The government's guidance uses three tiers: small (99 or fewer, exempt from all of Part 1.1), medium (100 to 499) and large (500 or more).

Conformity assessment reports and training records are kept for four years. The accessibility statement (section 19.6) must be in plain language and include its publication date, contact details with at least two of email, phone and mailing address, an acknowledgement of the organisation's obligations, its accessibility features, an overview of non-conformities, the alternative measures offered where conformity is not feasible, and “plans and timelines for addressing gaps”. It must be reachable from a prominent location on each web page, or from an app's home screen. Our accessibility statement guide and statement generator cover most of these elements.

What is and is not covered

• No retroactivity. The duties cover pages created or updated on or after the start date, apps launched after it and documents made available for download after it. The impact statement says organisations will not have to make pre-existing content conform, and treats any change to a page's content as an update. Existing apps need only the assessment and gap analysis.
• “To the extent feasible”. Section 19.3 weighs the availability of technology, significant obstacles and efforts to overcome them, and the organisation's degree of control over the content, including under agreements with third parties. Where conformity is not feasible and barriers result, the organisation must offer alternative means of accessing the key information or completing the task, except for maps, mapping services, technical drawings and images.
• Exceptions. Heritage content (reproductions kept mainly for historical, artistic or aesthetic interest) and user-generated content are excluded, as is content in an employee-facing collaborative digital environment. Web pages include web applications and pages behind a login.
• Broadcasters, telecoms and transport. Broadcasting and telecommunications entities (regulated by the CRTC) and transportation service providers (regulated by the CTA) are excluded from the public-facing web, app and document duties, and broadcasting and telecom entities from the procurement duty. They still have the employee-facing web and training duties and, if large, the statement duty. Transportation providers are covered only if they are subject to Part 1 of the transportation regulations and have 100 or more employees; their public websites are already governed by those regulations, below.
• Contractors. Section 19.31 gives anyone acting in the name of, or for the benefit of, an obligated organisation the same obligations.
• First Nations band councils. Their exemption from the planning duties was due to lapse at the end of 2026. SOR/2025-255 extends it, and an exemption from Part 1.1, to 31 December 2033.
• Content meant for Canada. The impact statement, though not the regulation text, says the rules apply only to digital content meant primarily for people in Canada or whose place of work is in Canada.

The standard: CAN/ASC-EN 301 549, as amended from time to time

The “ICT Standard” is CAN/ASC-EN 301 549, Accessibility requirements for ICT products and services, published by Accessibility Standards Canada “as amended from time to time”. ASC adopted the European standard on 31 May 2024 as CAN/ASC-EN 301 549:2024 (EN 301 549:2021, IDT), meaning ETSI EN 301 549 v3.2.1 “in its entirety and without modification”, and makes it available free in English and French. The regulations call on clauses 4 (functional performance), 5 (generic requirements), 6 (two-way voice), 7 (video), 9 (web), 10 (non-web documents) and 11 (software, including mobile apps). Clause 9 is the WCAG 2.1 Level A and AA success criteria, so for web content the target today is WCAG 2.1 AA. Our EN 301 549 checklist tracks every v3.2.1 requirement.

Section 19.9 adds flexibility. Instead of the current Canadian edition, an organisation may conform to “any version” of ETSI EN 301 549 published more recently, or to the immediately preceding CAN/ASC edition while the current one is less than three years old. ETSI published EN 301 549 v4.1.1 on 2 September 2026, aligned to WCAG 2.2. Our interpretation, not official guidance: because v4.1.1 is newer than the 2021 edition the Canadian standard is based on, conforming to it, and so to WCAG 2.2 AA on the web, satisfies the rule. We found no notice that ASC plans to adopt v4.1.1 as a new Canadian edition.

The government estimates about 183 federal public sector entities, 199 large businesses and 719 medium businesses are affected from the first period, plus 112 First Nations band councils from the tenth, with present-value costs of about $310 million against benefits of about $1.21 billion over ten periods. A second phase is planned: ESDC lists it as “Planned” and names artificial intelligence systems including automated decision-making, software, hardware and emerging technologies as its topics.

Federal Government Websites: the 2011 Standard Is Gone

For fifteen years, federal departments followed the Treasury Board's Standard on Web Accessibility (2011), which required WCAG 2.0 AA. A direction from the Chief Information Officer of Canada to deputy heads and departmental CIOs, on a page dated 12 March 2026, rescinded it “effective immediately” in preparation for the new regulations.

In the meantime, departments must keep public-facing websites and device-based mobile apps at a minimum of WCAG 2.0, and the direction points them to CAN/ASC-EN 301 549 and the technical summary of EN 301 549 v3.2.1. From 5 December 2027 their new and updated pages fall under SOR/2025-255 like any other federal public sector entity. Many widely read guides still present the 2011 Standard as the binding rule; it no longer is.

Transportation Providers: WCAG AA Is Already Required

One federal sector already has a binding web rule. Section 9 of the Accessible Transportation for Persons with Disabilities Regulations (SOR/2019-244, as amended by SOR/2021-9) says a transportation service provider “must ensure that every website, mobile website and application that it owns, operates or controls and that is made available to the public” meets WCAG Level AA. WCAG is defined as WCAG 2.0 “as amended from time to time”. The Canadian Transportation Agency enforces it, which is why SOR/2025-255 leaves transportation providers' public content alone.

Provincial Laws: Ontario, Manitoba, Quebec and Nova Scotia

Provincially regulated businesses, which is most of them, answer to provincial accessibility law where it exists, and everywhere to provincial human rights codes (the Quebec Charter in Quebec), under which web barriers can found a discrimination claim. Federally regulated organisations are bound by the Canadian Human Rights Act in the same way.

Ontario: AODA and the Integrated Accessibility Standards Regulation

The Accessibility for Ontarians with Disabilities Act, 2005 aimed for an accessible Ontario by 1 January 2025, a date that has now passed. Its web rule is section 14 of the Integrated Accessibility Standards Regulation, O. Reg. 191/11:

• Who. Designated public sector organisations and large organisations, defined as those with 50 or more employees in Ontario. Small organisations (1 to 49 employees) have no website duty, though they still have accessible formats duties. The Government of Ontario and the Legislative Assembly have a wider duty covering intranets, at full WCAG 2.0 AA since 1 January 2020.
• What. Internet websites and web content, including web-based applications, must conform with WCAG 2.0. New sites had to meet Level A by 1 January 2014, and all internet websites and web content Level AA by 1 January 2021, other than success criteria 1.2.4 Captions (Live) and 1.2.5 Audio Descriptions (Pre-recorded).
• Limits. The duty applies to sites the organisation controls directly or through a contract that allows modification, to content published after 1 January 2012, and “except where meeting the requirement is not practicable”.
• Reporting. Businesses and non-profits with 20 or more employees file an accessibility compliance report every three years, and the current deadline is 31 December 2026. Designated public sector organisations report every two years; their last deadline was 31 December 2025. Organisations with fewer than 20 employees do not report but must still comply.

The penalties are often misquoted. Ordinary administrative penalties for a corporation under section 83 and Schedule 3 of the regulation run from $500 (minor impact, minor history) to $15,000 (major and major). Only where both the impact and the history are major may a director treat the penalty as daily, up to $100,000 a day for a corporation and $50,000 for an individual or unincorporated organisation. Separately, section 37 of the Act makes it an offence to give false or misleading information in a report, fail to comply with a director's or Tribunal order, or take reprisals, with fines on conviction of up to $100,000 a day for a corporation and $50,000 a day for anyone else. Neither $100,000 figure is a standard fine for an inaccessible website.

The web standard itself has not moved since 2011. The AODA Alliance, an advocacy group, reported in December 2025 that the government had made no revisions to the regulation despite a standards development committee's final report in 2020.

Manitoba: WCAG 2.1 AA for the private sector since May 2025

The Accessible Information and Communication Standard Regulation, Man. Reg. 47/2022, made under the Accessibility for Manitobans Act, came into force on 1 May 2022 and phased in over three years: government departments from 1 May 2023; government agencies, health authorities, Winnipeg and other cities, educational institutions and libraries from 1 May 2024; and all other organisations from 1 May 2025.

Section 7(1) requires web content to “meet or exceed” WCAG 2.1 Level AA if it was published on or after the day the regulation applies to the organisation, or if it is needed to access the organisation's goods and services. Section 8 applies the same standard to web applications published or significantly updated after that date. Exceptions cover content where conformity is not technically feasible, technology is not readily available, it would cause undue hardship, the organisation lacks direct control, and product labels or product information. The regulation also requires a feedback process, training and accessible formats on request. Some secondary sources cite the regulation as 171/2022; the official register shows 47/2022.

Quebec: SGQRI 008 3.0 for public bodies

Quebec's Standard sur l'accessibilité des sites Web, SGQRI 008 3.0, came into force on 29 April 2024. It applies to the public bodies covered by section 2 of the Loi sur la gouvernance et la gestion des ressources informationnelles (chapter G-1.03), not to private businesses. It requires the most recent WCAG version available in French, which the standard identifies as WCAG 2.1, plus some WCAG 2.2 criteria, with Level AA as the general target. It applies to new content from the design stage and to significant changes, not retroactively. Some vendor guides still cite the older SGQRI 008 2.0.

Nova Scotia: a standard expected in 2028 to 2029

Nova Scotia's Accessibility Act (S.N.S. 2017, c. 2) works towards what the province calls an accessible Nova Scotia by 2030. Its information and communication accessibility standard is “expected in 2028-29”, so there is no binding web or WCAG rule yet. The built environment standard is already law.

Other provinces

British Columbia, Saskatchewan, New Brunswick and Newfoundland and Labrador have accessibility statutes, and government sources indicate their regulations focus on public sector planning and standards still in development, with no web or WCAG standard in force. Not confirmed: we could not verify this against the regulation texts when this page was reviewed, so check the provincial source before relying on it.

Case Law: Jodhan v. Canada

The leading Canadian web accessibility judgment is Canada (Attorney General) v. Jodhan, 2012 FCA 161. In 2010 FC 1197, the Federal Court found that the government's failure to monitor and ensure compliance with its own 2001 web accessibility standards (the Common Look and Feel standards) infringed the equality guarantee in section 15 of the Charter for a blind applicant. It gave the government 15 months to comply and kept supervisory jurisdiction.

On 30 May 2012 the Federal Court of Appeal (Nadon J.A., Sharlow and Dawson JJ.A. concurring) allowed the appeal in part. It upheld the declaration that she had been denied equal access to, and benefit from, government information and services provided online, a breach of section 15(1), and kept the declaration that the government should comply within a reasonable time such as 15 months. It removed the supervisory order, finding “no factual or legal basis to justify” it. Archived information was excluded where it is provided accessibly on request.

Enforcement under the Accessible Canada Act is still young. The Commissioner's 2025 to 2026 report records over 250 inspections initiated, with over 95 of the more than 160 resolved inspections finding non-compliance, and one complaint received. Complaints so far have been limited to plans, feedback and progress reports. We found no published notice of violation with a monetary penalty.

Canadian Companies Selling Into the EU and US

Where you are incorporated does not decide your exposure abroad. The European Accessibility Act has applied since 28 June 2025 to covered products and services offered on the EU market, wherever the company is based, and its harmonised standard is EN 301 549. In the United States, ADA Title III exposure follows your customers, not your head office.

The federal rules were drafted with this in mind: the impact statement says using the most recent ICT Standard minimises regulatory differences with Canada's major trading partners. In our analysis, because SOR/2025-255 uses EN 301 549 and section 19.9 accepts any newer ETSI edition, one EN 301 549 conformance programme can serve both Canada and the EU.

What To Do Now

1. Work out which regime you are under. Federally regulated (banking, telecom, broadcasting, transport, federal government) means the Accessible Canada Act. Otherwise check the provinces you operate in: Ontario with 50 or more employees there, any organisation in Manitoba, and Quebec public bodies have web standards today.
2. Count your employees the federal way. Average over the preceding three years, including dependent contractors. Under 100: no digital duties. 100 to 499: web pages and training. 500 or more: everything in the table above.
3. Train before December 2027. Training for staff who develop, maintain or procure ICT is the first business duty, due 5 December 2027 for every covered organisation with 100 or more employees, a year before the web duty. Keep the records for four years.
4. Build new work to EN 301 549 now. Everything you create or update after the start date must conform, so templates and components built today will be in scope. Target WCAG 2.1 AA as the floor, or WCAG 2.2 AA with the WCAG 2.2 checklist to cover Canada, the EU and the newer EN edition together.
5. Assess your apps and documents. Large businesses and the public sector need a conformity assessment and gap analysis of every existing app still on offer by 5 December 2028, and accessible downloadable documents from that date.
6. Change procurement. Ask vendors of web and app products and services for a conformity assessment and gap analysis against CAN/ASC-EN 301 549, and write it into contracts that run past 2028.
7. Draft the accessibility statement. List your non-conformities, alternative measures and a timeline for fixing gaps, with two contact routes. The accessibility statement generator gives you a starting draft to adapt.
8. In Ontario, file by 31 December 2026. Businesses and non-profits with 20 or more employees owe their three-yearly compliance report this year. See the accessibility deadlines calendar for other dates.

Sources

Every figure on this page was read from the documents below on 11 November 2026, unless the text says otherwise. Secondary sources are named where used.

1. Regulations Amending the Accessible Canada Regulations, SOR/2025-255, P.C. 2025-886, registered 5 December 2025, with Regulatory Impact Analysis Statement, Canada Gazette Part II, Vol. 159, No. 26, 17 December 2025
2. Accessible Canada Regulations, SOR/2021-241, consolidated text including the SOR/2025-255 amendments not yet in force, Justice Laws Website (current to 19 October 2026)
3. Accessible Canada Act, S.C. 2019, c. 10, Justice Laws Website (current to 19 October 2026)
4. Proposed Regulations Amending the Accessible Canada Regulations, prepublication, Canada Gazette Part I, Vol. 158, No. 51, 21 December 2024
5. Overview of regulatory amendments: digital technologies (Phase 1), Employment and Social Development Canada guidance, 17 December 2025
6. Consultation on accessibility regulations for information and communication technologies, Phase 2, Employment and Social Development Canada (status: planned)
7. Accessibility Standards Canada adopts globally recognized accessibility standard for ICT products, news release, 31 May 2024
8. Summary of CAN/ASC - EN 301 549:2024 Accessibility requirements for ICT products and services (EN 301 549:2021, IDT), Accessibility Standards Canada
9. Direction on Information Communication Technologies Accessibility; towards regulatory implementation, Chief Information Officer of Canada, Treasury Board of Canada Secretariat, page dated 12 March 2026
10. Accessible Transportation for Persons with Disabilities Regulations, SOR/2019-244, section 9, Justice Laws Website
11. Accessibility Commissioner, Accessible Canada Act annual report 2025 to 2026, Canadian Human Rights Commission
12. Canada (Attorney General) v. Jodhan, 2012 FCA 161, Federal Court of Appeal, 30 May 2012
13. Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11, Ontario e-Laws
14. Integrated Accessibility Standards, O. Reg. 191/11, sections 14 and 83 and Schedule 3, Ontario e-Laws
15. Completing your accessibility compliance report, Government of Ontario (updated 19 February 2026)
16. Accessible Information and Communication Standard Regulation, Man. Reg. 47/2022, Manitoba (PDF)
17. Standard sur l'accessibilité des sites Web (SGQRI 008 3.0), Ministère de la Cybersécurité et du Numérique, Québec
18. Information and communication accessibility standard, Accessibility Directorate, Government of Nova Scotia
19. W3C publishes authorized French translation of WCAG 2.2, W3C Web Accessibility Initiative, 17 March 2025