AODA Alliance
Accessibility for Ontarians with Disabilities Act Alliance Update
United for a Barrier-Free Ontario for All People with Disabilities
Website: www.aodaalliance.org
Email: aodafeedback@gmail.com
Twitter: @aodaalliance
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Federal Government Enacts New Digital Accessibility Regulation under the Accessible Canada Act While the Ford Government Hasn’t Updated Ontario’s 2011 Counterpart, Despite Receiving Recommendations on This Almost Six Years Ago
December 17, 2025
SUMMARY
On December 17, 2025, the Federal Government announced that it had enacted new federal regulations under the Accessible Canada Act on the important topic of digital accessibility. See the Government’s email announcement and the executive summary below. We need to verify this fact, but this appears likely to be the first regulations that the Federal Government has enacted under the Accessible Canada Act for the purpose of setting specific accessibility requirements for any sector of the economy. The ACA was enacted six and a half years ago.
We have not had the time to undertake a detailed analysis of these regulations. At first read, they appear to include some good features. Unlike Ontario’s Information and Communication Accessibility Standard, they commendably cover mobile apps, not just websites.
Yet these new federal regulations also appear to have worrisome shortcomings. They exempt transportation providers like airlines and communication providers such as Bell Canada or Rogers, because they are under the Canada Transportation Agency and the CRTC, respectively. This is yet more of the harmful splintering of the ACA over multiple regulatory agencies. It adds costs and burdens to the public, the taxpayer and the disability community.
We commend the Federal Government for enacting regulations regarding digital accessibility. Back in 2011, the Ontario Government was the first Canadian jurisdiction to do so, acting under the Accessibility for Ontarians with Disabilities Act. However, since then, the Ontario Government has made no revisions to update and modernize that 2011 regulation. The Ford Government has unjustifiably and inexcusably sat on the excellent final report of the Government-appointed Information and Communication Standards Development Committee which it received on or around February 23, 2020. The AODA required the Ford Government to make that report public upon receiving it. In violation of the AODA, the Ford Government kept it secret for eight months. It has announced no amendments to the Information and Communication Accessibility Standard after that.
How You Can Help
- Give the Federal Government feedback on these new federal regulations. Sign up for the technical briefings on them, described below, that the Federal Government will be offering in the new year if you want to learn more about them.
- Write your Ontario MPP. Tell them it’s well past time the Ford Government strengthened and modernized the 2011 Information and Communication Accessibility Standard, using the good recommendations from the Government’s Information and Communication Standards Development Committee.
- Learn more about the AODA Alliance’s advocacy efforts for accessible information and communication by visiting the AODA Alliance website’s information and communications page.
MORE DETAILS
December 17, 2025 Broadcast Email from the Government of Canada
I am pleased to share that the Phase 1 Digital Technologies Accessibility Regulations (the Regulations) under the Accessible Canada Act are now in force.
You can view the Regulations in the Canada Gazette, Part II. These Regulations apply to all federal public sector organizations regardless of size. They also apply to large and medium-sized federally regulated private sector businesses such as banks, airlines and telecommunications service providers with 100 or more employees. Small private sector businesses with 99 or fewer employees are exempt from the new Regulations.
Technical Briefings on the New Regulations
Employment and Social Development Canada will hold four bilingual technical briefing sessions via Zoom to explain the regulatory requirements and answer questions.
The sessions will be held on February 3, 5, 9 and 11, 2026 from 1 p.m. to 2:30 p.m. EST.
Please mail us directly with the following information to attend a session:
- Date of the session you want to attend
- Your first and last name
- Your organization name (if applicable)
- Your email address
- Your phone number (optional)
- Any accessibility requirements, including ASL/LSQ interpretation and captioning.
We will send Zoom meeting details by email prior to the sessions.
We look forward to your participation in these briefings. If you have any questions, please reach out to the Accessible Canada Directorate.
Sincerely,
Rupa Bhawal-Montmorency
Director General
Accessible Canada Directorate
Employment and Social Development Canada
Excerpt of Executive Summary of Government of Canada’s Regulatory Impact Statement
REGULATORY IMPACT ANALYSIS STATEMENT
(This statement is not part of the Regulations.)
Executive summary
Issues: More than one in four Canadians aged 15 years and over have a disability, yet 45% of persons with disabilities in Canada have reported experiencing digital accessibility barriers when interacting with federal sector entities. Digital accessibility barriers have significant negative impacts on the livelihood and well-being of persons with disabilities and other Canadians. They make it challenging to manage finances independently; apply for, access and retain jobs; and obtain information about or access programs and services.
Description: The amendments (“Phase 1 Regulations” hereafter) to the Accessible Canada Regulations (ACARs) introduce a new part titled “Information and Communication Technologies” (ICT), which sets out the first phase of new requirements for both public and private sector federally regulated entities regarding digital accessibility. ICT is sometimes referred to as “digital technologies.”
The Phase 1 Regulations set accessibility requirements for three areas of digital technologies that are priorities for persons with disabilities. These areas are the following: (1) web pages, including web applications; (2) mobile applications; and (3) non-web documents (hereafter referred to as “digital documents”).
In addition, federally regulated entities must provide training on digital accessibility fundamentals to their employees who develop, maintain or purchase digital technologies; publish accessibility statements about their web pages, mobile applications and digital documents; and assess the accessibility of certain digital technology products and services they purchase.
Private sector federally regulated entities with 99 employees or fewer (“small businesses” hereafter) are exempted from the Phase 1 Regulations. First Nations band councils have a time-limited exemption from the Phase 1 Regulations and from the planning and reporting requirements of the ACARs until December 31, 2033. This aims to provide sufficient time and space to continue engaging First Nations partners and other Indigenous stakeholders on accessibility barriers faced by Indigenous persons with disabilities and develop a tailored approach to the application of the Accessible Canada Act (ACA) on reserve.
Rationale: Removing persistent digital accessibility barriers for persons with disabilities and preventing new ones are a priority under the ACA. This is particularly important because, for most people, digital technology is key to accessing programs and services, finding jobs and staying employed. To this end, the aim of the Phase 1 Regulations is to ensure equitable access to jobs, programs, and services for persons with disabilities by promoting the use of accessible digital technologies in the federal public and private sector, thus enabling their full participation in Canadian communities and workplaces.
Extensive consultations with the disability community and regulated entities made it clear that inaccessible web pages, mobile applications and digital documents continue to create significant barriers to equitable access to information, services and programs. Consequently, these three areas were identified as priorities for regulatory action.
Having requirements around accessibility statements, training and assessing the accessibility of digital technologies that federally regulated entities purchase were identified by the disability community and regulated entities as crucial steps to enhance digital accessibility. These help support accessibility improvements and enable a shift to a culture where digital technology is designed to be accessible from the start. In addition, these lay the foundation for future amendments to the ACARs that will address more complex digital technology areas (e.g. legacy or pre-existing digital technology, application software, artificial intelligence).
While the administrative and compliance costs that will result from the Phase 1 Regulations are considered significant, the benefits are expected to outweigh the costs. Over 10 periods of 12 months, the expected total present value (PV) costs to federally regulated entities are projected to be approximately $309.95 million in 2022 constant dollars (the purchasing power of Canadian dollars in 2022). The expected total PV benefits are projected to be approximately $1,209.78 million. This results in a net PV benefit of approximately $899.83 million.
Ensuring digital accessibility from the start enables persons with disabilities, and to a lesser extent persons without disabilities, to benefit from time savings by reducing the need for in-person visits and phone calls to federally regulated entities to obtain information and conduct transactions.
Based on available information from international jurisdictions and expert consultations, federally regulated entities are expected to benefit from reduced phone calls, email exchanges, demands for production of documents, and in-person visits to their service delivery locations. In addition, since digital technologies are key tools for workers, federally regulated entities are expected to benefit from increased productivity and lower turnover rates when employees with disabilities have barrier-free access to these technologies.