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On December 17, 2025, the Regulations Amending the Accessible Canada Regulations (the "Regulations") pertaining to the Accessible Canada Act (the "Act") were posted in the Canada Gazette. The Regulations are designed to improve the accessibility of digital technologies for persons with disabilities.
The Regulations will come into force December 5, 2027, with certain sections coming into force December 5, 2028. The compliance obligations and timing of those obligations depend on whether and where an entity is included in section 7 of the Act. For example, the majority of the new regulations will come into force for some federally regulated entities with 100 or more employees during the preceding three-year period on December 5, 2028.
This Insight provides a general overview of the amendments, but it is recommended that organizations review the Act directly to determine the applicability of the Regulations to their specific entity and any exceptions that may apply.
Information and communication technologies
The Regulations add a new section titled "Information and Communication Technologies," adopting the Accessibility requirements for ICT products and services (the ICT Standard), which outlines accessibility requirements for information and communication technology products and services.
Under the Regulations, entities must ensure that any new or updated webpages, mobile applications, and non-web documents (Items) are in compliance with the ICT Standard. An entity will be required to publish an accessibility statement pertaining to all Items that are required to be in compliance with the ICT Standard by the date that the Regulations come into force for that entity. The entity must also post an accessibility statement once every 12 months thereafter.
In summary, an accessibility statement must:
- Be written in simple, clear and concise language
- Include its publication date
- Provide the entity's contact information
- Include an acknowledgement of the entity's obligations
- Describe the accessibility features
- Provide an overview in cases where obligations to conform to the ICT Standard are not met
- Include any alternative means established
- Include plans and timelines for any gaps in the entity's conformity with the ICT standard
- Be accessible from a prominent location
The Regulations require employers to provide training to employees who are involved in the development, maintenance or procurement of information and communication technologies on accessibility fundamentals regarding those technologies and provide refresher training at minimum once every three years. An electronic record of the training must be retained. The training requirements come into force for all applicable entities on December 5, 2027.
Regulations concerning procurement will come into force December 5, 2028. This regulation will require applicable entities who are purchasing products or services related to new or updated web pages and mobile applications to conduct or obtain a conformity assessment that includes a gap analysis against the ICT Standard.
Failure to comply with the Regulations is classified as a minor violation which includes penalties for non-compliance.
Key takeaways for employers
Employers subject to the Act and its Regulations should begin preparing to implement accessibility statements and ensuring their organizations new or updated webpages, mobile applications, and non-web documents will be in compliance with the Regulations to avoid penalties.
The labour and employment team at MLT Aikins would be happy to assist with all aspects of compliance with the Regulations, including creating accessibility statements. Our team has extensive knowledge regarding the Act and Regulations and has previously assisted clients with implementing accessibility plans.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
