AODA Alliance Proposes 15 Specific Amendments to Bill C-22, the Canada Disability Benefit Act, to Make Improvements that Witnesses Asked for at Public Hearings

Accessibility for Ontarians with Disabilities Act Alliance

United for a Barrier-Free Society for All People with Disabilities




Twitter: @aodaalliance



AODA Alliance Proposes 15 Specific Amendments to Bill C-22, the Canada Disability Benefit Act, to Make Improvements that Witnesses Asked for at Public Hearings


November 21, 2022




Today, the AODA Alliance unveils a package of 15 specific and constructive amendments that we call on the House of Commons to make to Bill C-22, the proposed Canada Disability Benefit Act. Read them below.


We understand that the public hearings are now finished at HUMA, the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities. Next, HUMA does clause-by-clause review of the bill. That is when amendments can be made.


We were guided by the following when we designed these amendments:


  • They try to fix the concerns with Bill C-22 that we have raised, as well as those raised in the November 14, 2022 open letter from 37 organizations that we tabled with HUMA during our testimony.


  • They respond to concerns and recommendations that other witnesses discussed during the public hearings.


  • They make the bill do what the Government said it is trying to achieve during their speeches in the House of Commons and at the Standing Committee.


  • They speed up getting money into the pockets of people with disabilities who are living in poverty.


  • They each improve the bill, without delaying its swift passage. Any of these amendments would help, even if HUMA does not pass all these amendments. It is not an “all or nothing” situation, where HUMA must either pass them all or reject them all.


Any of the political parties can propose an amendment. We are sending our proposals for amendments to all the federal political parties. We are urging them all to bring motions to make the amendments we list here. In our strong commitment to non-partisanship, we are eager to work with any and all of the parties.


Normally, the minister responsible for the bill, Disabilities Minister Carla Qualtrough, begins the clause-by-clause review by announcing a list of amendments, if any, that the Government will propose. We do not know what, if anything, she will propose.


It is open to any of the opposition parties to propose amendments. Because Canada has a minority government, the opposition parties could pass an amendment to the bill, if they all support it at the Standing Committee, even if the governing Liberals oppose it. We call on the opposition parties to work together to find common ground on amendments, even if the Liberals don’t agree with them.


We would far prefer to get stronger amendments to the bill than the 15 we list here. However, we have carefully tailored this short list of amendments to fit within the strong message from so many people with disabilities and disability organizations: pass the bill quickly but be sure to get it right! We have also designed them to fit perfectly well within the bill itself.


When witnesses at the public hearings have called for this bill to be strengthened, and for more details and specifics to be added to it, Liberal MPs time and again kept saying that Bill C-22 is “framework legislation,” with the specifics to later come in regulations. They have incorrectly made it sound like to be “framework legislation,” it must include no details or specifics.


This is no reason why Bill C-22 cannot now be strengthened through amendments. In 2018, the same minister, Carla Qualtrough, brought forward the Government’s proposed Accessible Canada Act. She called that bill “framework legislation.” It was over 90 pages long, and included over 200 sections. In contrast, Bill C-22 is just six pages long and has only 15 sections. In 2018 Minister Qualtrough herself introduced a good number of amendments to her Accessible Canada Act bill, during clause-by-clause review at HUMA. No one claimed that that somehow meant that it was no longer “framework legislation.”


We always welcome your feedback. Write us at:


For more background, take a dive into:



  • The November 14, 2022 open letter on Bill C-22, signed by fully 37 organizations from six provinces across Canada, that the AODA Alliance tabled with the House of Commons Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities.




  • The AODA Alliance website’s Bill C-22 page, which shows our efforts to strengthen this proposed new law.




Proposed Amendments to Bill C-22, the Canada Disability Benefit Act


We propose that the bill be amended:


  1. To make the bill define “working age” as at least 70. The bill now states that the Canada Disability Benefit is available to “working age” people with disabilities. The bill would authorize Cabinet to pass regulations to raise “working age” above 70, but not below 70.


  1. Within 12 months of the passage of the bill, to require Cabinet to enact the regulations that are necessary to enable the CDB to begin to be paid, e.g. setting the actual CDB amount, the eligibility criteria, and the application/appeal processes.


  1. To specify a date by which the CDB must begin to be paid.


  1. To give Cabinet the power to pass regulations that would establish a Canada Disability Benefit for persons with disabilities who are not “working age”. This would, for example, let Cabinet in the future extend the Canada Disability Benefit to seniors who are no longer “working age.” This would not require Cabinet to do this. It would permit Cabinet to do this. This would all be on the understanding that the first step under the bill would be to now create the Canada Disability Benefit for working-age people with disabilities.


  1. To require Cabinet to create an interim emergency CDB benefit to be paid no later than fall 2023. This is intended to help people with disabilities who are living in poverty to cope during the delays in getting the permanent Canada Disability Benefit established. We anticipate that at the present rate, it may not be until some time in 2025 before people with disabilities would start to receive the permanent Canada Disability Benefit. This is because of the time it will take for Parliament to pass the bill, and then for the regulations to be enacted, and then for The Government to set up the paperwork and officials to receive and process applications for the Canada Disability Benefit, and then for decisions to be made on those applications, and finally for cheques to be cut and sent out to people with disabilities living in poverty.


  1. To provide for a two-stage approach to eligibility for the CDB. Those already receiving a provincial/territorial disability benefit such as ODSP should automatically qualify for the CDB, without having to go through a second application process. Those who are not now receiving a provincial/territorial disability benefit should be able to apply for the CDB, with the bill and regulations spelling out the eligibility criteria.


  1. To require that the application and appeal processes for the Canada Disability Benefit must be fully accessible, barrier-free, user-friendly and prompt, with a 30 day deadline for a decision.


  1. To set a deadline by when the applications and appeal processes for the Canada Disability Benefit must be designed, put in place and available for applicants to apply.


  1. To require that the Canada Disability Benefit be annually indexed to inflation, using the Consumer Price Index for Canada, as published by Statistics Canada under the authority of the Statistics Act.


  1. To specify in the bill the income that an eligible person with disabilities is entitled to receive when the Canada Disability Benefit is combined with any other federal, provincial or territorial benefits, with that total amount to exceed the poverty line as defined in the Poverty Reduction Act.


  1. To require the Federal Government to make public all Federal/Provincial/Territorial agreements regarding harmonization and regarding protection against claw-backs, upon the establishment of the Canada Disability Benefit.


  1. To require the Federal Government to establish an office to monitor and annually report to the public on compliance with Federal/Provincial/Territorial agreements regarding the Canada Disability Benefit. The bill should establish an accessible complaints process for people with disabilities to be able to file complaints if any of their provincial/ territorial or federal monetary or non-monetary benefits or services are clawed back or reduced directly or indirectly because they have received the Canada Disability Benefit. The office should be required to investigate and attempt to mediate those complaints. The office should be required to publicly report quarterly its findings and recommendations, anonymized to protect the confidentiality of persons filing complaints.


  1. To require that open, barrier-free and accessible consultations on the regulations be completed within three months of the passage of the bill, with the consultations to include the amount of the Canada Disability Benefit, who will be eligible to receive it, and the design of the application and appeal processes.


  1. To require that before the public consultation begins, the Government shall make public a list of possible options on the issues that are the subject of the consultation, to be available in an accessible plain language form.


  1. To require that as part of the consultation process, MPs shall each hold open accessible town hall meetings in their ridings on the issues listed above.