Accessible Canada Act: What Your Website Needs

The Accessible Canada Act (ACA), S.C. 2019, c. 10, came into force on July 11, 2019. It is Canada's first national accessibility law. For federally regulated organizations, it changes the question from "do we have to comply?" to "what progress are we demonstrating this year?"

What the ACA Is and Is Not

The ACA is a proactive framework law, not a prescriptive technical standard. Unlike Ontario's AODA, which says "meet WCAG 2.0 AA by this date," the ACA says "identify your barriers, plan to remove them, and report on your progress annually."

This distinction matters for how you approach digital accessibility under the ACA. There is no single moment of compliance. There is an ongoing obligation to demonstrate that you are identifying and removing barriers, including digital barriers on your websites, apps, and digital systems.

The ACA applies to seven priority areas:

1. Employment
2. The built environment
3. Information and communication technology (ICT)
4. Communication (other than ICT)
5. The procurement of goods, services, and facilities
6. The design and delivery of programs and services
7. Transportation

Your website and digital content fall primarily under areas 3 (ICT) and 6 (design and delivery of services).

Reference: Accessible Canada Act, S.C. 2019, c. 10 — laws-lois.justice.gc.ca

Who the ACA Covers

The ACA applies exclusively to entities under federal jurisdiction. Provincial governments, provincially regulated businesses, and organizations operating solely within a single province are not covered by the ACA (though they may be covered by provincial laws like AODA).

Covered entities include:

Federal government: All federal departments, agencies, Crown corporations, Parliament, and the Canadian Forces and RCMP. This includes all canada.ca websites, ministerial websites, and the digital services of every federal department. Banking and financial services: All banks chartered under the Bank Act and federally regulated financial institutions, including RBC, TD, Scotiabank, BMO, CIBC, National Bank, and Desjardins for its federal credit union operations. Telecommunications and broadcasting: All companies licensed by the CRTC, including Bell, Rogers, Telus, Videotron, SaskTel, CBC/Radio-Canada, and all other broadcast licensees. Airlines and airports: Air Canada, WestJet, Porter Airlines, and federally regulated airport authorities. Also covered are other federally licensed air carriers. Interprovincial transport: Bus lines, railways, and ferry services that operate across provincial boundaries and are regulated by the Canadian Transportation Agency. Crown corporations: Canada Post, VIA Rail, Canada Mortgage and Housing Corporation (CMHC), Export Development Canada (EDC), Business Development Bank of Canada (BDC), and others.

What the ACA Requires for Digital Content

The ACA does not name a specific WCAG version in the legislation itself. However, two sources establish the practical technical standard:

For the Government of Canada: The Treasury Board of Canada Secretariat's Standard on Web Accessibility requires conformance to WCAG 2.1 Level AA for all Government of Canada websites and web applications. This standard applies to all federal departments covered by the Treasury Board. For other regulated entities: Accessibility Standards Canada (ASC), an independent organization created by the ACA, is developing sector-specific standards. These standards are expected to reference WCAG 2.1 AA or WCAG 2.2 AA as the baseline for digital accessibility. Organizations in regulated sectors should plan toward WCAG 2.1 AA as the emerging standard.

In practical terms: any federally regulated organization that wants to demonstrate genuine progress on digital barriers should target WCAG 2.1 AA conformance for its public-facing websites, customer portals, and digital communications.

The ACA Reporting Cycle

Accessibility Plans

Organizations subject to the ACA were required to publish their first accessibility plans by June 1, 2023. These plans must:

• Identify the barriers to accessibility the organization has found
• Describe how the organization will prevent and remove those barriers
• Be published in an accessible format
• Include a description of the feedback process

Accessibility plans must be updated every three years.

Annual Progress Reports

Organizations file annual progress reports in the years between plan updates. First progress reports were due June 1, 2024. These reports must describe what the organization did in the previous year to implement its accessibility plan.

The 2026 reporting cycle is the second annual progress report for organizations that published plans in 2023 and filed first progress reports in 2024. Progress reports must demonstrate measurable activity: barriers identified, barriers removed, feedback received and how it was addressed.

Feedback Mechanisms

All covered organizations must establish a process for receiving feedback about accessibility barriers. This feedback mechanism itself must be accessible — meaning the digital submission method on your website must be operable by people with disabilities.

What Counts as Digital Barrier Removal

Removing a digital barrier means fixing a WCAG violation or otherwise making a piece of digital content accessible. For your annual progress report, demonstrable activities include:

• Completing a WCAG audit of your primary website
• Remediating identified violations (with before/after documentation)
• Making specific previously inaccessible content accessible (PDFs, videos, forms)
• Training web staff on accessibility requirements
• Adding accessibility checks to your development and publishing workflows
• Addressing accessibility complaints received through your feedback mechanism

None of this requires achieving perfection. The ACA framework explicitly recognizes that barrier removal is an ongoing process. What it requires is genuine, measurable effort documented in your annual report.

ACA Penalties and Enforcement

The Accessibility Commissioner within the Canadian Human Rights Commission (CHRC) has authority to:

• Receive and investigate complaints about ACA non-compliance
• Conduct audits of covered organizations
• Issue compliance agreements and orders
• Recommend administrative monetary penalties up to CAD $250,000 per contravention

The Canadian Transportation Agency has parallel enforcement authority for transport-sector entities.

Separately, the CRTC has authority over broadcasting and telecommunications accessibility. The CRTC has required broadcasters and telecom providers to file accessibility plans and report on them as part of existing regulatory frameworks.

Organizations that publish accessibility plans and file progress reports but do not actually take steps to remove digital barriers face both enforcement risk and reputational risk. The plans are public documents. Advocacy organizations monitor them.

ACA vs. AODA: Which Applies to You

If you are a bank, telecom, or airline operating in Ontario, you must comply with both. Meeting WCAG 2.1 AA satisfies both regimes.

Getting Started

If your organization is federally regulated and has not yet addressed digital accessibility in your accessibility plan:

1. Run automated scanning across your public websites to identify current barriers
2. Document findings — this is your starting point for the accessibility plan's ICT section
3. Prioritize and fix critical violations (missing alt text, unlabeled forms, missing skip navigation)
4. Track what you fix — this documentation goes into your annual progress report
5. Establish a process for ongoing accessibility monitoring to maintain compliance

Scan your website free with OnePageAudit to identify current WCAG violations on your public-facing site. Results take under 60 seconds and identify the barriers your accessibility plan should address. Related reading:

• AODA Website Compliance Guide 2026
• Canadian Website Accessibility Laws: Complete Guide
• How to Do a Website Accessibility Audit