The ACA Is Not Voluntary
The Accessible Canada Act (S.C. 2019, c. 10) came into force in 2019. By now, most federally regulated organizations have published their first accessibility plan — the initial legal requirement. But publishing a plan was only the beginning.
The Accessibility Commissioner's office has begun actively following up with organizations that submitted plans but showed no measurable progress in their annual reports. Non-compliance is now being tracked.
Which Organizations Are Covered
The ACA applies to federally regulated organizations:
- Financial institutions — banks and federal credit unions regulated by OSFI
- Telecommunications — carriers and broadcasters regulated by the CRTC
- Transportation — airlines, interprovincial rail, bus and ferry operators regulated by Transport Canada
- Crown corporations — federal government entities
- Federal government departments — all federal public service departments
If you're regulated by OSFI, CRTC, Transport Canada, or the CHRC, the ACA applies to you.
Provincial businesses — including Ontario companies regulated only by provincial bodies — fall under AODA, not the ACA. Some large organizations in Ontario may be subject to both.
The Key Deadlines
| Requirement | Deadline |
|-------------|----------|
| Publish initial accessibility plan | Already passed |
| Annual progress reports | Ongoing — due each year |
| Feedback mechanism operational | Already required |
| Digital accessibility (large orgs, 500+ employees) | December 2027 |
| Digital accessibility (small orgs, under 500 employees) | December 2028 |
The December 2027 digital deadline covers websites, web apps, mobile apps, intranets, and digital documents available to employees or clients. The standard: EN 301 549 / WCAG 2.1 Level AA.
What Your Accessibility Plan Must Cover
The ACA requires plans that identify barriers in six areas:
- The built environment — physical spaces employees and clients access
- Employment — hiring, onboarding, accommodation, and advancement
- Information and communications — digital properties, documents, signage
- The procurement of goods, services, and facilities — requiring accessibility from vendors
- The design and delivery of programs and services — how you serve clients with disabilities
- Transportation — where applicable to your sector
Your plan must identify barriers in each area and describe how you'll remove them. Plans must be updated every three years.
Annual Progress Reports
Each year, your organization must publish a progress report describing:
- What barriers were identified and removed in the past year
- How many accessibility-related complaints were received
- How complaints were resolved
- What you plan to address in the coming year
The Commissioner is examining whether reported progress matches what's actually happening. Vague or unchanged reports from year to year are raising flags.
The Penalties
The Accessibility Commissioner can issue compliance orders and assess administrative monetary penalties:
- CAD $250 to $75,000 per violation
- Penalties can be applied per unresolved complaint, per missing report, or per documented barrier that wasn't addressed
Beyond penalties, the Commissioner can also name non-compliant organizations publicly — reputational risk for regulated financial and telecom brands is significant.
The Digital Gap Most Organizations Are Missing
The most common gap we see in ACA compliance work: organizations have a plan and submit annual reports, but their digital properties remain inaccessible.
Testing a website against WCAG 2.1 AA takes under five minutes. Many organizations have never done it. Missing alt text, inaccessible forms, poor contrast, and broken keyboard navigation are present on the majority of federal org websites we've scanned — and the December 2027 deadline is not far off.
What to Do Now
- Scan your website against WCAG 2.1 AA — know your current baseline before the Commissioner asks
- Complete the ACA checklist — covers all 18 requirements across info & comms, employment, programs, and procurement
- Publish your accessibility statement — required as part of the public-facing feedback mechanism
- Log staff training — demonstrate your team understands their accessibility obligations
- Export your annual report — a structured document of barriers identified, progress made, and next steps
AODACheck provides all five tools tailored to ACA requirements, with report export formatted for regulatory submission.