Federal jurisdiction · plans, feedback, progress reports
The Accessible Canada Act: who it covers, and what the website part requires.
Canadian organisations frequently conflate the federal Act with Ontario's provincial regime, and the two ask for different things from different people. This page separates them: who falls under federal jurisdiction, what the Act actually requires in terms of plans, feedback and progress reports, where information and communication technologies fit in, and what we can sign for the digital part of it.
Signed by Goldman Services INC, Richmond Hill, Ontario.
Federal or provincial? Start here
This single question determines everything else, and getting it wrong wastes months preparing the wrong documents.
| Your organisation | Likely regime | What it asks for |
|---|---|---|
| Bank or federal financial institution | Federal | Accessibility plan, feedback process, progress reports |
| Telecom or broadcaster | Federal, with sector regulator | Same, plus sector requirements |
| Air, rail, marine or interprovincial transport | Federal, with transport regulator | Same, plus transport accessibility rules |
| Federal department or Crown corporation | Federal | Same, on the public sector cycle |
| Retailer or service business in Ontario | Provincial | AODA standards and the compliance report |
| Company outside Canada selling to Canadians | Neither, usually | Contractual and human rights considerations |
If you are in the last two rows, the federal Act is not your obligation and the Ontario page is the relevant one. If you are in the first four, read on.
The three obligations, in plain terms
Strip away the regulatory language and the Act asks federally regulated organisations to do three things, repeatedly, in public.
- The accessibility plan. A published document setting out how the organisation will identify, remove and prevent barriers across the priority areas, prepared in consultation with persons with disabilities and available in accessible formats on request.
- The feedback process. A described, published way for employees and the public to give feedback about barriers and about the plan itself, with someone designated to receive it.
- Progress reports. Published between plans, saying what has been done, what the feedback said and what changed as a result. Reports that ignore the feedback received are the ones that attract attention.
Notice what is missing: there is no single conformance certificate to obtain. The Act is built around transparency and iteration, which means the documents you publish are the compliance, and their honesty is the thing being judged.
Where information and communication technologies fit
ICT is named as one of the priority areas, alongside employment, the built environment, procurement, programmes and services, communication other than ICT, and transportation. For most organisations the ICT section of the plan is the one with the most external visibility, because it covers the website, the mobile apps, the customer portal and the internal systems employees use.
That section is stronger when it rests on testing. A plan that says the organisation is committed to accessible technology is a sentence. A plan that says the public website was tested against WCAG 2.2 AA on a given date by an external party, that the findings are being addressed in a stated order, and that a verifiable record exists, is a section a reader can check.
Consultation, and why it changes the document
The requirement to consult persons with disabilities in preparing plans and reports is not procedural decoration. It is the part that makes the difference between a document written by a communications team and one that reflects what people actually encounter.
It also changes the ICT section specifically. Consultation regularly surfaces barriers that no audit would prioritise: a form that technically passes but takes twenty minutes to complete with speech input, a portal that logs people out during a long task, a help line that cannot be reached from the accessible channel. Testing finds criteria failures; consultation finds friction. A good plan contains both, and says which came from where.
What we sign, and what stays with you
The division of labour matters here more than in any other jurisdiction we work in, because the federal Act is organisational by design.
Goldman Services INC, an Ontario corporation, tests your public web content and signs a conformance record: pages and flows tested, assistive technology used, date, criteria met and not met, with a public verification code. That record is evidence you can attach to the ICT section of your plan and cite in a progress report.
What stays with you is everything organisational: the plan itself, the consultation, the feedback process as required by the Act, employment practices, procurement, the built environment. No external supplier can produce those, and any that offers to is describing something narrower than it sounds.
If your organisation also has employees in Ontario, the provincial compliance report is a separate duty described on the AODA 2026 page, and the same testing supports both.
A sensible order of work
Large organisations stall on this because everything is in scope at once. Sequencing solves that, and the sequence below is the one that produces something publishable soonest.
Start with the public website, because it is the most visible, the most testable and the part most likely to generate feedback from outside the organisation. Get it tested, get the record signed, and write the ICT section of the plan around real findings rather than intentions.
Then extend to the employee-facing systems, which is where most internal barrier reports come from and where consultation tends to produce the longest list. Finally, fold both into the progress report cycle, so that each report can point to something that changed rather than restating the commitment.
The cost of the digital part is fixed: 890 CAD a year for the Canadian plan, or 1,990 € if you also need the European statement and the British report with a single renewal date. Testing takes five business days, and the monthly re-test keeps the record current between progress reports.
What a weak ICT section looks like, and how to fix it
Having read a fair number of published plans, the difference between the thin ones and the credible ones comes down to four habits.
Published plans are public documents, which makes them easy to compare. The weak ones share a pattern: a paragraph of commitment, a reference to WCAG with no version or level, a promise to review technology purchases, and no dates. Nothing in it can be checked, which is precisely why it reads as thin to the people the Act was written for.
The strong ones do four things differently. They name what was tested and when, so the reader knows the statement is about the current site rather than an aspiration. They name the standard with its version and level, because WCAG without a version is ambiguous. They list what is not yet conformant, with the alternative available in the meantime, which converts a gap into a managed position. And they say what will be different by the next progress report, with enough specificity that the next report can confirm or explain it.
None of that requires the site to be perfect. It requires somebody to have looked, written down what they found, and committed to a sequence. An organisation that does this for two cycles ends up with something rarer than compliance: a public record showing measurable improvement, which is the outcome the legislation was actually designed to produce.
Accessible formats, and the trap inside them
The Act requires plans and reports to be available in accessible formats on request, and lists the ones expected. Organisations usually satisfy this by producing a tagged document alongside the web version, which is fine as far as it goes. The trap is that the web version is the one everybody actually reads, and it is frequently the least accessible of the set: a plan published as an image-based file, or as a page whose headings were chosen for size, fails for the very audience it was written for, while the alternative format sits behind a request form that is itself hard to use.
The simple test is to apply the plan to itself. Open your published accessibility plan with a keyboard and a screen reader. If reaching section three requires a mouse, or if the table of barriers is an image, the document has contradicted its own contents before anyone reads a word of it.
Employees, not only customers
One asymmetry worth naming: most accessibility budgets go to the public website, while most barrier reports inside federally regulated organisations concern internal systems. The intranet, the HR portal, the scheduling tool, the training platform bought from a vendor five years ago. These are where an employee with a disability spends the working day, and they are rarely tested because nobody outside sees them.
The Act covers employment as a priority area, and the feedback process applies to employees as much as to the public. If your consultation produces a list dominated by internal tools, that is the normal result and it belongs in the plan, even when the fix depends on a vendor's roadmap rather than on your own developers. Saying so honestly, with what you are asking the vendor for and by when, is a stronger position than omitting it.
Federal questions
What is the Accessible Canada Act?
Federal legislation aiming to identify, remove and prevent barriers in areas under federal jurisdiction, with a long-term goal of a barrier-free Canada by 2040.
Who is covered?
Federally regulated entities: banks, telecommunications, broadcasting, air, rail, marine and interprovincial transport, federal government departments and agencies, and Crown corporations.
Is my Ontario shop covered?
Almost certainly not by the federal Act. Provincial law applies to you, which in Ontario is the AODA.
What does the Act require?
Published accessibility plans, a feedback process, and progress reports, on a recurring cycle, in accessible formats.
What about websites specifically?
Information and communication technologies are one of the priority areas, and the federal standard for web content aligns with WCAG.
How is it different from AODA?
Different jurisdiction, different obligations. The AODA is provincial with a compliance report; the federal Act is about plans, feedback and progress reports.
Can both apply to us?
Yes. A federally regulated company with employees in Ontario can face both, which is why the scoping question is worth answering properly.
What are the deadlines?
Plans and reports run on a recurring cycle set by regulation for each class of entity, with the 2040 horizon for the overall goal.
Are there penalties?
The Act provides for administrative monetary penalties for non-compliance.
Who enforces it?
The Accessibility Commissioner within the Canadian Human Rights Commission, alongside sector regulators for transport and telecommunications.
Do we need to consult people with disabilities?
Yes. Consultation is built into the preparation of plans and progress reports, and the plan must say how it was done.
What do you provide?
The testing and documentation for the digital part: a conformance record for your web content signed by Goldman Services INC, with findings and a verifiable code.
Do you write our accessibility plan?
No. The plan is an organisational document covering employment, the built environment, procurement and more. We cover the web conformance element inside it.
Do you host the feedback process?
We host the accessibility feedback channel for the website. Your statutory feedback process is broader.
What does it cost?
890 CAD a year for the Canadian plan, or 1,990 € for the plan covering Canada, the EU and the UK together.
How long does it take?
Five business days from a complete form.
Which standard do you test against?
WCAG 2.2 level AA, which covers the web expectations comfortably.
Where do we start?
Free scan, then the audit with any credentials needed for secure areas.