Key Takeaways
- 1December 5, 2027: Federal government websites and mandatory accessibility training for all staff in digital roles
- 2December 5, 2028: Public-facing websites, mobile apps, digital documents, and procurement must conform for large and medium federally regulated organizations
- 3Canada adopted CAN/ASC-EN 301 549 — the same European standard (EN 301 549) that includes WCAG 2.1 AA
- 4Applies to banks, airlines, telecoms, broadcasters, and all federally regulated employers — some of Canada's largest organizations
- 5Penalties up to $250,000 per violation, enforced by Canada's Accessibility Commissioner — not through private lawsuits
What Is the Accessible Canada Act?
The Accessible Canada Act (ACA), formally known as Bill C-81, was enacted on June 21, 2019. Its stated goal is ambitious: to create a barrier-free Canada by January 1, 2040. The legislation establishes a framework for proactively identifying, removing, and preventing accessibility barriers across seven priority areas:
For digital accessibility specifically, the ACA's Phase 1 regulations — the Accessible Canada Regulations (SOR/2021-241) — set enforceable requirements for ICT, including websites, mobile applications, electronic documents, and digital procurement. These requirements move from planning (now) to technical conformity (2027–2028).
Unlike the US approach to web accessibility, which has evolved primarily through litigation and DOJ enforcement actions, Canada's framework is proactive and regulatory. Organizations don't wait to be sued — they're required to assess barriers, publish accessibility plans, and report progress on defined schedules.
The Complete Digital Accessibility Timeline
Here's the phase-by-phase breakdown of when digital accessibility requirements take effect under the ACA:
Already in Effect
June 1, 2026 — Annual Progress Reports Due
All federally regulated organizations (including private sector) must submit annual progress reports describing their accessibility efforts, barriers identified, and actions taken. This is a reporting requirement — not yet a technical conformity mandate — but it signals that organizations should already be assessing their digital accessibility posture.
December 5, 2027 — Training + Government Websites
Mandatory accessibility training for all staff in roles involving design, development, procurement, or management of ICT. This includes developers, designers, content creators, and procurement officers.
Federal government websites and web applications must conform to CAN/ASC-EN 301 549 (which includes WCAG 2.1 Level AA). Government leads by example before the private sector deadline.
December 5, 2028 — Full Private Sector Conformity
This is the big deadline. Federally regulated private sector organizations (large and medium) must achieve conformity across:
- ▸Public-facing websites and web applications — must conform to CAN/ASC-EN 301 549
- ▸Digital documents — PDFs, Word documents, spreadsheets published digitally must be accessible
- ▸New mobile applications — any app launched after this date must be accessible
- ▸Legacy mobile applications — existing apps must undergo a conformity assessment
- ▸Procurement — ICT procurement processes must demand accessibility conformance reports (ACRs/VPATs)
Timeline at a Glance
Jun 26
Progress reports
Dec 27
Training + gov sites
Dec 28
Full conformity
2040
Barrier-free Canada
Who Must Comply
The ACA applies to federally regulated organizations — entities that fall under federal jurisdiction rather than provincial. This covers a significant slice of Canada's economy:
🏦
Banks & Financial Institutions
All chartered banks (RBC, TD, BMO, Scotiabank, CIBC, National Bank), trust companies, and federal credit unions. The Big Five banks alone serve 80%+ of Canadians.
✈️
Airlines & Transportation
Air Canada, WestJet, Porter Airlines, and all interprovincial/international transportation providers including railways (VIA Rail, CN, CP) and marine shipping.
📱
Telecommunications
Bell, Rogers, Telus, Shaw/Freedom Mobile, Videotron, and all federally regulated telecom and internet service providers. Also includes broadcasting undertakings (CBC, CTV, Global).
🏛️
Federal Government
All federal departments, agencies, Crown corporations, and the Canadian Armed Forces. Parliament itself is also covered. Government websites have the earlier December 2027 deadline.
⚡
Energy & Extractives
Interprovincial pipelines, nuclear energy, and federally regulated energy companies. Includes major employers like Canada Post.
🌐
Interprovincial Businesses
Any business that operates across provincial or international borders in a federally regulated sector. This can include some technology companies depending on their structure.
Organization Size Tiers
The ACA differentiates requirements by organization size:
Large: 500+ employees
Full compliance required by December 2028. Must publish accessibility plans and annual progress reports.
Medium: 100–499 employees
Same December 2028 deadline for digital conformity. Slightly reduced planning and reporting requirements.
Small: 10–99 employees
Reduced requirements with longer timelines. Still must establish feedback processes and eventually meet digital accessibility standards.
The Technical Standard: CAN/ASC-EN 301 549
In May 2024, Canada adopted CAN/ASC-EN 301 549 as its national ICT accessibility standard. This is a direct adoption of the European standard EN 301 549 v3.2.1 — the same technical standard that underpins the European Accessibility Act (EAA). This means compliance efforts can be shared across multiple jurisdictions.
What CAN/ASC-EN 301 549 Covers
Web Content
Must conform to WCAG 2.1 Level AA — the same standard referenced by the ADA Title II rule and the EAA. This covers all web pages, web applications, and web-based content.
Software & Mobile Apps
Native mobile applications, desktop software, and other non-web software must meet additional accessibility requirements beyond WCAG — including platform accessibility APIs, closed functionality provisions, and assistive technology support.
Electronic Documents
PDFs, Word documents, spreadsheets, and other electronic documents must be accessible. This includes proper heading structure, alt text for images, reading order, and tagged PDF structure. See our Section 508 guide on PDF compliance.
Hardware & ICT Equipment
Self-service kiosks, ATMs, point-of-sale terminals, and other ICT hardware must meet physical and digital accessibility requirements.
Support & Documentation
User documentation, help desk services, and technical support must be accessible. This includes accessible formats for manuals, help pages, and customer service channels.
⚠️ WCAG 2.2 Update Expected
The current standard references WCAG 2.1, but an update to the European parent standard (EN 301 549 v4.1.1) is expected in 2026, which will incorporate WCAG 2.2. Canada is expected to adopt this update. For organizations planning compliance now, targeting WCAG 2.2 AA from the start avoids having to remediate twice.
Canada vs. US vs. EU: How the Laws Compare
Three major English-speaking markets now have enforceable digital accessibility requirements. Here's how they compare:
United States — ADA + Section 508
Law: Americans with Disabilities Act (1990) + ADA Title II rule (2024)
Standard: WCAG 2.1 AA (Title II rule); implied for Title III through litigation
Deadline: April 24, 2026 (state/local government); no explicit deadline for private sector
Enforcement: Private lawsuits + DOJ enforcement. 8,667 federal lawsuits in 2025
Model: Litigation-driven. No proactive regulatory oversight.
European Union — European Accessibility Act
Law: European Accessibility Act (Directive 2019/882)
Standard: EN 301 549 (WCAG 2.1 AA + additional ICT requirements)
Deadline: June 28, 2025 (enforced)
Enforcement: Market surveillance by national authorities in each EU member state. Varies by country.
Model: Regulatory + market-based. Covers products and services sold in the EU.
Canada — Accessible Canada Act
Law: Accessible Canada Act (Bill C-81, 2019)
Standard: CAN/ASC-EN 301 549 (same as EU's EN 301 549 — includes WCAG 2.1 AA)
Deadline: December 5, 2027 (government) / December 5, 2028 (private sector)
Enforcement: Accessibility Commissioner + administrative penalties up to $250K per violation
Model: Proactive regulatory. Plans → reports → conformity. No reliance on private lawsuits.
💡 The Convergence Point
All three jurisdictions converge on WCAG 2.1 Level AA as the technical standard. Canada and the EU share the exact same parent standard (EN 301 549). Organizations that achieve WCAG 2.1 AA conformity are positioned to comply across all three markets — a powerful efficiency argument for multinationals.
What US Businesses Need to Know
The Accessible Canada Act doesn't just affect Canadian companies. US businesses may be impacted if they:
1. Operate in Federally Regulated Sectors
If your US company has Canadian subsidiaries or operations in banking, telecommunications, transportation, or energy that fall under federal regulation, those operations must comply with the ACA. This includes US banks with Canadian branches and airlines operating Canadian routes.
2. Sell to Canadian Government
The ACA's procurement requirements mean Canadian federal agencies will increasingly require Accessibility Conformance Reports (ACRs/VPATs) as part of the procurement process. If you sell software, SaaS, or digital services to Canadian government agencies, you'll need to demonstrate CAN/ASC-EN 301 549 conformance.
3. Serve Regulated Canadian Customers
As Canadian banks, telecoms, and airlines implement their own accessibility requirements, they'll extend those demands to their vendors and partners. If your SaaS product is used by a Canadian bank, expect accessibility to become a contractual requirement.
4. Already Pursuing US Compliance
The good news: if you're already working toward WCAG 2.1 AA for US compliance (ADA, Section 508), you're largely covered for Canada as well. The technical requirements are the same. The additional effort is in documentation, training, and reporting — not in the technical accessibility work itself.
Compliance Roadmap: From Now to December 2028
Whether your deadline is December 2027 (government) or December 2028 (private sector), here's a practical roadmap:
Now: Baseline Assessment (Q1 2026)
Audit your current digital properties against WCAG 2.1 AA. Use automated scanning tools for a quick baseline, then supplement with manual testing using assistive technologies. Document everything — you'll need this for your annual progress report.
Time estimate: 2–4 weeks for initial assessment
Q2 2026: Accessibility Plan + Progress Report
Publish your accessibility plan (required under the ACA) and prepare your first annual progress report. The plan must describe your policies, identify barriers you've found, and outline your remediation timeline. This is due by June 1, 2026.
Time estimate: 2–3 weeks for documentation
Q3–Q4 2026: Remediation Sprint
Tackle critical accessibility barriers first: missing alt text, keyboard navigation issues, form labels, color contrast, and heading structure. These are the issues that affect the most users and are flagged by automated testing tools.
Time estimate: 3–6 months depending on scope
2027: Training + Government Conformity
Implement mandatory accessibility training for all staff in digital roles. Government organizations must achieve website conformity by December 5. Private sector should use this year to validate remediation and begin mobile app assessments.
Time estimate: Training rollout: 1–2 months; ongoing remediation
2028: Full Conformity + Ongoing Monitoring
Achieve full conformity across websites, mobile apps, digital documents, and procurement. Implement ongoing monitoring — the DOJ's Fashion Nova objection made clear that one-time fixes aren't sufficient. Regular scanning, documented audits, and compliance tracking are the new baseline.
Time estimate: Ongoing. Budget for continuous monitoring.
Enforcement and Penalties
Canada's enforcement model is fundamentally different from the US litigation-driven approach. Instead of waiting for lawsuits, the ACA creates proactive regulatory oversight:
Accessibility Commissioner
The Accessibility Commissioner (within the Canadian Human Rights Commission) has authority to investigate complaints, conduct compliance audits, issue compliance orders, and impose administrative monetary penalties. Unlike the US DOJ, which acts reactively, the Commissioner can initiate investigations proactively.
Administrative Monetary Penalties
Penalties of up to $250,000 per violation for organizations that fail to comply with ACA requirements. These are administrative penalties — no lawsuit required. The Commissioner can also publish the names of non-compliant organizations, creating reputational risk.
Compliance Orders
The Commissioner can issue orders requiring organizations to take specific actions — such as remediating a website, updating a mobile app, or revising procurement processes. Non-compliance with an order can result in additional penalties.
Individual Complaints
Individuals with disabilities can file complaints with the Accessibility Commissioner or the Canadian Human Rights Commission. While this isn't the same as the US private lawsuit model (no damages awards to individuals), it triggers regulatory action that can be equally consequential.
Provincial Laws: Beyond Federal Regulation
The ACA covers federally regulated organizations, but several Canadian provinces have their own accessibility legislation that applies to provincially regulated businesses:
🏛️ Ontario — AODA (2005)
The Accessibility for Ontarians with Disabilities Act was Canada's first provincial accessibility law. WCAG 2.0 Level AA has been required for large organizations since January 2021. Ontario is currently reviewing whether to update to WCAG 2.1 or 2.2.
🏛️ Manitoba — AMA (2013)
The Accessibility for Manitobans Act is modeled after Ontario's AODA and is phasing in accessibility standards for public and private sector organizations.
🏛️ Nova Scotia — NSAA (2017)
The Nova Scotia Accessibility Act aims for an accessible Nova Scotia by 2030, with standards being developed for ICT accessibility.
🏛️ British Columbia — Accessible BC Act (2021)
BC's newest accessibility law establishes a framework for accessibility standards development, with ICT standards expected in coming years.
For organizations operating across Canada, the practical approach is to meet the highest standard — CAN/ASC-EN 301 549 (WCAG 2.1 AA) — which will satisfy both federal and most provincial requirements.
The Global Accessibility Convergence
Canada's adoption of EN 301 549 — the same standard used by the EU — represents a significant moment in global digital accessibility. Three markets with a combined population of over 1.2 billion people now have enforceable accessibility requirements that converge on WCAG 2.1 AA:
🇺🇸
United States
~335M people
ADA + Section 508
April 2026
🇪🇺
European Union
~450M people
EAA + EN 301 549
June 2025 ✓
🇨🇦
Canada
~40M people
ACA + CAN/ASC-EN 301 549
Dec 2027–28
For organizations operating globally, this convergence is actually good news. Instead of meeting three different standards, a single WCAG 2.1 AA compliance effort — supplemented with the broader EN 301 549 requirements for software and hardware — covers all three jurisdictions. The investment in accessibility pays dividends across every market.
Start Your Accessibility Assessment Today
RatedWithAI scans your website against WCAG 2.1 AA — the same standard required by Canada's ACA, the EU's EAA, and the US ADA. One scan covers three jurisdictions.
Frequently Asked Questions
What is the Accessible Canada Act?
The Accessible Canada Act (ACA), also known as Bill C-81, is Canada's federal accessibility legislation enacted in 2019. It aims to create a barrier-free Canada by 2040, with enforceable digital accessibility requirements phased in between 2027 and 2028 for federally regulated organizations including banks, airlines, telecommunications companies, and broadcasters.
When do Canadian digital accessibility deadlines take effect?
There are two key deadlines: December 5, 2027 for federal government websites and mandatory accessibility training, and December 5, 2028 for federally regulated private sector organizations to achieve conformity for public-facing websites, mobile apps, digital documents, and procurement processes. Annual progress reports are due starting June 1, 2026.
What accessibility standard does Canada use?
Canada adopted CAN/ASC-EN 301 549 in May 2024, which is a direct adoption of the European standard EN 301 549 v3.2.1. This standard incorporates WCAG 2.1 Level AA as its web accessibility requirement, plus additional requirements for software, hardware, and documentation. An update to include WCAG 2.2 is expected in 2026.
Who must comply with Canada's digital accessibility requirements?
The ACA applies to federally regulated organizations in Canada, including the federal government, banks and financial institutions, airlines and transportation companies, telecommunications providers, broadcasting companies, and interprovincial or international businesses. Organizations are categorized by size: large (500+ employees), medium (100–499), and small (10–99), with different timeline requirements.
How does Canada's accessibility law compare to the ADA?
Unlike the Americans with Disabilities Act (ADA), which relies on litigation and court interpretations for web accessibility, Canada's ACA takes a proactive regulatory approach with specific technical standards (CAN/ASC-EN 301 549) and enforceable deadlines. The ACA also has a dedicated Accessibility Commissioner for enforcement, whereas ADA enforcement depends on DOJ action or private lawsuits.
Does the Accessible Canada Act affect US businesses?
Yes, if your US business operates in federally regulated sectors in Canada, serves Canadian customers through Canadian subsidiaries, or provides digital services to Canadian federal government agencies. Even if you're not directly regulated, accessibility is increasingly a procurement requirement for doing business with Canadian organizations.
What is CAN/ASC-EN 301 549?
CAN/ASC-EN 301 549 is Canada's national ICT accessibility standard, adopted in May 2024. It is a direct adoption of the European standard EN 301 549 v3.2.1, which includes WCAG 2.1 Level AA for web content plus additional accessibility requirements for software applications, hardware, documentation, and support services.
What are the penalties for non-compliance?
The Accessibility Commissioner can issue compliance orders, impose administrative monetary penalties of up to $250,000 per violation, and publish the names of non-compliant organizations. Unlike the US litigation-driven model, enforcement is primarily through regulatory action rather than private lawsuits, though individuals can also file complaints to the Canadian Human Rights Commission.