After becoming law in 2019, the Accessible Canada Act (ACA) started a new era of disability inclusion in nationally controlled organizations. Its simple goal is to remove all barriers in Canada by 2040. To achieve this goal, you have to meet strict deadlines! The Accessible Canada Regulations have a lot of important dates coming up soon, and many groups are still not ready.
If you operate in the banking, telecommunications, transportation, or federal public sector, these rules apply to you. This article explains who the ACA covers, what the 2026 deadlines require, and how this federal law differs from Ontario’s AODA.
Table of Contents
Defining ‘The Accessible Canada Act’
The Accessible Canada Act (ACA), passed in 2019, aims to create a barrier-free Canada by January 1, 2040. It marked a major shift in accessibility policy by encouraging organizations to identify and remove barriers before they exclude people, especially individuals with disabilities.
It is a federal law that applies to organizations under federal jurisdiction. Unlike provincial laws that cover broader public sectors, the ACA targets specific industries and entities that fall under federal authority.
The Act aims to identify, remove, and prevent barriers in seven priority areas:
- Employment – ensures inclusivity in hiring, training, and other workplace practices
- The built environment – ensures physical spaces are accessible to all
- Information and communication technologies – ensures digital property is accessible
- Communication (excluding ICT) – ensures communication in non-digital format such as Braille or sign language.
- Procurement of goods and services – ensures accessibility in purchasing policies and contracts
- Design and delivery of programs and services – ensures that all services are accessible throughout
- Transportation – accessibility for all in transportation modes
The ACA is based on a plan of effective compliance. Instead of waiting for complaints, businesses should embed accessibility into its plans, ask for feedback, and update on their progress.
Who Must Comply?
Whether you run a large corporation or a small business in a federally regulated sector, compliance with the ACA is a legal requirement.
This includes:
- Canada’s government institutions: All federal departments, agencies, and Crown businesses.
- Political Bodies: The Senate, House of Commons, and Parliamentary libraries.
- Companies in the private sector: Any business in the banking, transportation, or telecommunications sectors that is under federal control.
To be precise,
- Banks & financial services providers (all federally chartered banks)
- Companies offering logistics service: Airways, railways, and interprovincial bus-trucking companies
- Telco Organizations: Internet service providers, phone companies, and broadcasters
- Broadcasting Giants: Radio and television stations
If you operate in these sectors, you are legally obligated to comply, regardless of your organization’s size.
Timelines for 2026
The ACA regulations are being introduced in phases, and many organizations have already published their first accessibility plans. But compliance does not stop there. In 2026, organizations will need to focus on ongoing responsibilities like updating plans, tracking progress, and continuing to remove barriers to accessibility.
Heads Up!
The due date for your first progress report is June 1, 2026, if your initial accessibility plan was published by June 1, 2023. You have to keep submitting progress reports every two years; the next one is due in 2028.
What the Progress Report Must Include:
- A summary of the feedback you received since your last plan.
- How you addressed that feedback.
- Updates on the implementation of your accessibility plan.
- Any barriers you have removed during the reporting period.
Consultation is Necessary: Have a detailed conversation with people who are disabled before making any changes to your accessibility strategy. Take note of this consultation and include it in your plans.
The Three Core Documents
The ACA requires organizations to maintain three distinct documents.
They are:
- Accessibility Line Up: Describes your strategy to identify, remove, and prevent barriers. This is your roadmap.
- Feedback Process: You must establish a way for the public to give feedback on accessibility barriers and your response to them. This process must be accessible itself.
- Progress Reports: Updates published every two years detailing what you have accomplished and what barriers you have removed.
Failure to publish any of these documents on time constitutes a violation. The Accessibility Commissioner has the power to order compliance and impose penalties.
How the ACA Differs from the AODA?
While both the ACA and AODA aim to create more accessible spaces for people with disabilities, they differ in who they apply to, how compliance is enforced, and what organizations are expected to do over time. Understanding these distinctions can help businesses and institutions build a clearer and more effective accessibility strategy.
- The ACA (Accessibility Canada Act) applies to federally regulated entities in Canada (e.g., banks, telecommunications), while the AODA (Accessibility for Ontarians with Disabilities Act) applies to all sectors in Ontario.
- The ACA uses a cyclical compliance model requiring accessibility plans and updates every three years, while the AODA has fixed deadlines for compliance actions based on organization size and type.
- Enforcement of the ACA is managed by the Accessibility Commissioner under the Canadian Human Rights Commission, whereas the AODA is overseen by the Directorate of the Ministry for Seniors and Accessibility in Ontario.
- The ACA follows a principles-based approach with gradual regulations, while the AODA outlines detailed technical standards, including WCAG 2.0 compliance for websites.
- Reporting obligations differ: ACA mandates public access to accessibility plans and progress reports, while AODA requires compliance reports to be filed directly with the government.
What Organizations Need to Do Now
Staying compliant with the ACA in 2026 requires more than a one-time effort. If you are a federally regulated organization, waiting until 2026 is a mistake. Here is your action plan.
Step 1: Confirm Your Status
Verify whether your organization falls under federal jurisdiction. If you are a bank, airline, telecom, or federal contractor, the ACA applies to you.
Step 2: Review Your Accessibility Plan
If you published a plan in 2023, it is time to review it. Has your organization changed? Have you identified new barriers? Update your plan based on current realities and new consultation feedback.
Step 3: Consult with Persons with Disabilities
Do not write your progress report in a vacuum. Reach out to disability organizations, employees with disabilities, and customers. Document their input and show how it shaped your updates.
Step 4: Draft Your 2026 Progress Report
Start drafting your first progress report now. Gather data on the barriers you have removed and the work your team has completed. A well-drafted report demonstrates good faith and reduces your risk of enforcement action.
Step 5: Train Your Team
Ensure your employees understand the ACA requirements. Procurement teams need to buy accessible products. HR needs to remove hiring barriers. IT needs to ensure digital properties meet accessibility standards.
Consequences of Non-Compliance
The Accessibility Commissioner possesses strong enforcement powers against non-compliance.
Possible consequences include:
- Issuing a notice of violation.
- Ordering compliance.
- Imposing administrative monetary penalties (fines).
- Entering into a compliance agreement with the organization.
Non-compliance also adversely affects organizational reputation.
- Canadians anticipate accessible services from institutions like banks, airlines, and government entities.
- Failing to meet these expectations reflects a lack of commitment to inclusion.
Conclusion
The Accessible Canada Act is more than a legal requirement. It is a commitment to building a country where accessibility is part of everyday systems, services, and experiences.
Also, understand that the Accessible Canada Act (ACA) is completely different from AODA; both are separate laws, and depending on certain conditions, you might need to comply with both of them. The ACA is for federally regulated organizations (anks, transport, etc.), and the deadline for the first progress report is in June 2026 (if the first plan is published in 2023).
Therefore, it is time you start preparing by reviewing the plan, consulting the persons with disabilities, and documenting your progress. These three simple steps will help you to become compliant and build a more inclusive organization for all Canadians.
As the 2026 deadlines approach, federally regulated organizations must start treating accessibility as an ongoing responsibility woven into their operations and culture. Reach out to us at AEL Data to make that happen!
