Accessibility laws · Canada (federal)

Accessible Canada Act (ACA)

Canada's federal accessibility law changed shape on December 5, 2025. Until that day the Accessible Canada Act mostly asked for plans, feedback processes, and progress reports. It did already say those documents had to meet WCAG Level AA when you published them electronically. What it never did was set a standard for the rest of your website. Then the Governor in Council registered SOR/2025-255, which names a technical standard and attaches hard dates to it. Federal public sector web pages have to conform by December 5, 2027. Private federally regulated businesses averaging 100 or more employees have until December 5, 2028.

Via CAN/ASC-EN 301 549: 2.1 AA
Max penalty (CAD): $250k
Federal web deadline: Dec 2027
Private employees covered: 100+

What the law is

The Accessible Canada Act received royal assent on June 21, 2019 and came into force on July 11, 2019, aiming at a Canada without barriers on or before January 1, 2040. It binds the federally regulated sector, which in Canada is a narrow and specific slice of the economy rather than every business in the country. Banking, telecommunications, broadcasting, airlines, transport that crosses a provincial or international border, Crown corporations, and the federal government itself all sit under federal authority. Everybody else answers to a province, which for Ontario means the AODA. If you look the Act up you will see two 2019 dates and wonder which one counts. Royal assent is when Parliament finished with it. July 11 is when it started binding anyone.

The technical standard is CAN/ASC-EN 301 549:2024, published by Accessibility Standards Canada as a National Standard of Canada on May 31, 2024 and identical to the European EN 301 549:2021. Its clause 9 carries WCAG 2.1 Level AA, and that clause is your web requirement. Three clause sets do three different jobs here, so read the one that matches what you are building. Web pages answer to clauses 4 to 7 and 9, non-web documents to clauses 4 to 7 and 10, and mobile applications to clauses 4 to 7 and 11. Ontario's AODA still points at WCAG 2.0 Level AA, which means an AODA-compliant site is a WCAG version behind what the federal rule asks for.

Canada incorporated that standard on an ambulatory basis, a small phrase with a large consequence. Your obligation moves whenever Accessibility Standards Canada publishes a new version of the standard. No new regulation is needed. So if ASC republishes against WCAG 2.2, the federal requirement becomes WCAG 2.2 on its own. Two release valves sit under that. Both are in the regulation itself. You may satisfy the Canadian standard by conforming to any ETSI edition of EN 301 549 published more recently than it. And for three years after a new Canadian edition lands, the one before it still counts. So a new edition is a moving bar with a run-up, rather than a cliff. The other half of the design is that these rules only look forward. Web pages are captured where they are created or updated on or after the applicable date, mobile apps where they are launched after it, and non-web documents where they are made available after it. A legacy page nobody ever touches is never swept in.

This applies to you if…

You run a federally regulated organization, meaning one of the businesses Canada's constitution places under federal rather than provincial authority. Banking, telecom, broadcasting, airlines, transport that crosses a provincial or international border, and Crown corporations are the usual ones. The statute itself does not print that list. It reaches them through a catch-all for any business within the legislative authority of Parliament.
You are part of the federal public sector, which takes in government departments and agencies, the Royal Canadian Mounted Police, and the Canadian Armed Forces. Size is not a factor on this side. Federal public sector entities are in from the first employee.
You are a private federally regulated business that averaged 100 or more employees over the preceding three-year period, which is where the dated web page rules first reach the private sector. Mobile apps and downloadable documents start higher, at an average of 500 employees. And read the word average carefully. The regulation means it. You add the average number of employees for each of the three years, divide by three, and round to the nearest whole number. So a company that crossed 100 for the first time last year may not be captured yet.
You averaged 99 or fewer employees, in which case the digital accessibility rules leave you alone entirely, though the planning, feedback, and reporting regime still reaches you. There is a floor under that one as well. A private federally regulated entity averaging fewer than 10 employees is exempt from the plan, feedback and progress report sections outright, and the exemption lapses in any year the average reaches 10. First Nations band councils sit outside both regimes, and the end date is the one thing here we cannot give you cleanly. The regulation in force exempts them until the day before the fifth anniversary of the day it came into force, which lands in December 2026. A 2025 amendment replaces that with December 31, 2033, and the federal consolidation still lists it under amendments not in force. So the extension is announced rather than operative, and a band council should ask counsel about the gap rather than reading 2033 off a website.
You are a broadcaster, a telecommunications entity, or a transportation service provider, and the carve-out here is bigger than most guides admit. You sit outside the public-facing web page, mobile app, and digital document requirements, because you answer to the CRTC or the Canadian Transportation Agency under their own accessibility regimes instead. Those regulators are a substitute for this set of duties, not an extra layer on top. Your employee-facing web pages are the part that stays, with one condition worth checking before you assume it. Transport providers keep it only where Part 1 of the Accessible Transportation for Persons with Disabilities Regulations reaches them. Outside that, it does not land on you either.

What it technically requires

Publish an accessibility plan, run a process for people to report the barriers they hit, and file progress reports. That regime is already live and has been for years, and the dates come in two steps that get collapsed into one constantly. The regulations set a fixed day for each group, and the Act then gives you a year after it to publish. The fixed days are December 31, 2021 for the federal public sector, June 1, 2022 for a private entity averaging 100 or more employees, and June 1, 2023 for one averaging 10 to 99. Add the year and your first plan was due December 31, 2022, June 1, 2023, or June 1, 2024. Plans get updated every 36 months, and a progress report lands on the anniversary in between. The same regulations put clocks on alternate format requests. Braille or audio has to arrive within 45 days, and other formats within 15 days for a large entity or 20 days for a small one.
Bring your web content up to CAN/ASC-EN 301 549:2024 by the date that matches you. Federal public sector web pages conform by December 5, 2027. Private-sector web pages have until December 5, 2028, and so do mobile apps and downloadable documents on both the public and the private side. Employee-facing pages count. Your intranet and your staff portal are in this alongside the storefront. The duty is written as conformity to the extent feasible, and where full conformance genuinely is not feasible the government expects an alternative way to reach the information, described as temporary rather than permanent.
Train every employee involved in developing, maintaining, or buying your digital systems on the fundamentals of digital accessibility. The deadline is 24 months from the regulation's December 5, 2025 registration, refresher training comes at least once every three years, and you keep the records until the fourth anniversary of the training. This one lands on the federal public sector at any size and on private entities with 100 or more employees. No other jurisdiction on this site mandates accessibility training by regulation.
Publish an accessibility statement if you are a federal public sector entity or a private entity averaging 500 or more employees. Put it somewhere prominent. That means your web pages, your mobile app home screens, and any page where documents can be downloaded. It has to be in simple, clear language, carry a publication date, and give at least two ways to reach you out of email, phone, and mailing address. It also has to say plainly where you are not meeting the standard, describe what you offer instead, and set out your plan and timeline for closing those gaps. Update it every 12 months and keep each version for four years.
Get a conformity assessment, including a gap analysis against the standard, as part of buying any new web page or mobile app. This falls on federal public sector entities and private entities averaging 500 or more employees, and the clock is 36 months from registration. Mobile apps you already run need the same gap analysis even though only newly launched apps have to conform. If you sell to Canadian federal buyers, this is the requirement that reaches you first. It arrives in a purchase order, not from a regulator.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

This law expects a published accessibility statement, and regulators check for it first. Generate yours free →

How it is enforced

Four bodies enforce this law, and which one you answer to depends on what you do. The Accessibility Commissioner, who sits inside the Canadian Human Rights Commission, is the default. The Canadian Radio-television and Telecommunications Commission takes broadcasting and telecom. The Canadian Transportation Agency takes transport. The Federal Public Sector Labour Relations and Employment Board takes federal public sector employment matters. The Commissioner's powers include entering and inspecting, ordering a fix, and issuing a notice of violation.

The CA$250,000 number needs a caveat, and you will not find it on most pages about this law. That figure is the Act's absolute statutory ceiling, and every digital accessibility provision in SOR/2025-255 is classified as a minor violation. For a large regulated entity, a minor violation runs CA$1,000 to CA$10,000 on a first offence. A second runs CA$10,000 to CA$25,000, a third CA$25,000 to CA$50,000, and a fourth or later one CA$50,000 to CA$75,000. What that means in practice is that an inaccessible bank website is a four-figure to five-figure problem, not a quarter-million-dollar one. The ceiling belongs to the very serious violations, which are obstruction, false or misleading statements, and reprisal, committed by a large entity for the fourth time.

The small numbers add up because of how the Act counts days. Section 88 says a violation committed or continued on more than one day is a separate violation for each of those days. The amount inside a band is not arbitrary either. It is calculated from a gravity value. That value weighs negligence, the harm done, any economic benefit you got, what you did to fix it, and how far you cooperated. Which is a fairly direct way of saying that showing your work lowers the bill. Pay within 15 days and the penalty settles at 90% of the assessed amount.

The paperwork carries its own exposure, well before the 2027 and 2028 technical dates arrive. The regulations list 47 separate minor violation items covering the planning, reporting, and feedback duties. Failing to publish a plan is a violation. So is failing to consult people with disabilities while you write one. Part 6 of the Act also gives people who run into a barrier a route to complain about it. Your website can be perfect and you can still be in breach on a missing document.

Key dates

Jul 11, 2019ACA in force
2022 to 2024First accessibility plans and feedback processes fall due, a year after each group's fixed day
Dec 5, 2027Federal public sector web pages: CAN/ASC-EN 301 549:2024
Dec 5, 2028Mobile apps and documents, plus private entities with 100+ employees

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

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This law does not set the web requirement itself. It points at EN 301 549, the European accessibility standard, and that is where the requirement actually lives. Clause 9 of the standard carries WCAG 2.1 Level AA, so a site that already meets Level AA has met the web part of it. The rest of the standard covers ground WCAG never touches, including hardware, two-way voice, documents that are not web pages, and the support channels a customer reaches once the site has already failed them. Several countries adopt the standard under their own national designation, which carries the same requirements under a different name.

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.