Federal Government Finalizes New Digital Technologies Accessibility Regulations

On December 5, 2025, the federal government registered amendments to the Accessible Canada Regulations made under the Accessible Canada Act (ACA). These amendments (the Digital Technologies Accessibility Regulations), which generally come into force in 2027 for federal public-sector entities and in 2028 for large federally regulated private-sector entities, add significant digital accessibility compliance obligations for such entities.

The objectives of the Digital Technologies Accessibility Regulations include removing and preventing accessibility barriers in three areas of digital technologies: web pages and web applications, mobile applications, and digital documents such as PDFs. Additionally, the Digital Technologies Accessibility Regulations seek to raise awareness and build capacity by establishing new training and procurement requirements.

In this bulletin, we highlight the new compliance obligations for regulated entities and discuss considerations for businesses, including expected guidance from Employment and Social Development Canada.

Applicability of the Digital Technologies Accessibility Regulations

The Digital Technologies Accessibility Regulations create a new part under the Accessible Canada Regulations titled “Information and Communication Technologies” with new obligations for:

• Federal public-sector entities, including certain federal Crown corporations
• Large federally regulated private-sector entities, which are defined as regulated entities that had an average of 100 or more employees during the preceding three-year period

In keeping with the approach of the ACA, the applicability of many requirements depends on the entity’s average number of employees over the previous three years, and other obligations depend on the sector in which the entity operates. Federally regulated private-sector entities with an average of 99 or fewer employees over the previous three years are exempt from the Digital Technologies Accessibility Regulations’ requirements, whereas some obligations apply only to federally regulated private-sector entities with an average of 500 or more employees. As noted below, many of the new obligations do not apply to transportation service providers and broadcasting or telecommunications entities, including the requirements for public-facing websites and mobile applications, procurement, and training (except for broadcasting and telecommunications entities).

Adoption of ICT Standard

The Digital Technologies Accessibility Regulations adopt Accessibility Standards Canada’s CAN/ASC - EN 301 549, titled Accessibility Requirements for ICT (Information and Communication Technology) Products and Services (ICT Standard). The ICT Standard defines requirements that digital technologies should meet to enable their use by everyone, particularly persons with disabilities. In general terms, digital technologies that meet the requirements of the ICT Standard are compatible and work seamlessly with assistive technologies used by persons with disabilities, such as screen readers, text-to-speech software and Braille keyboards.

Importantly, the ICT Standard incorporates web accessibility conformity requirements set out in the Web Content Accessibility Guidelines (WCAG), which are incorporated into existing accessibility standards under provincial accessibility laws. This means that compliance with the ICT Standard will not frustrate compliance with WCAG conformity obligations under provincial laws.

New Obligations

The Digital Technologies Accessibility Regulations establish four key new obligations.

1. Web Page, Mobile Application and Document Accessibility Conformity

All regulated entities must ensure that employee-facing web pages created or updated on or after the day on which the obligation first applies conform, to the extent feasible, to the applicable requirements in clauses 4 to 7 and 9 of the ICT Standard.

Regulated entities that are not transportation service providers or broadcasting or telecommunications entities are subject to similar obligations in respect of any:

1. Non-employee facing web pages
2. Mobile applications that it launches on or after the day on which the obligation first applies conform
3. For entities with an average of 500 or more employees, non-web documents (i.e., PDFs, Word documents) made available for download on any of the entity’s web pages or mobile applications that are not employee-facing

These obligations do not apply in respect of “heritage content” (content maintained primarily for reasons of historical, artistic or aesthetic interest), user-generated content or content accessed through a collaborative digital environment.

The relevant factors when determining the feasibility for conforming with the ICT Standard include:

1. The availability of technology that would permit conformity
2. The existence of significant obstacles to the implementation of the technology and any efforts by the regulated entity to overcome those obstacles
3. The regulated entity’s degree of control over the web page, mobile application or non-web document, including under any agreement with a third party

To the extent that conformity with the applicable requirements of the ICT Standard is not feasible in respect of non-employee-facing web pages, the entity must, if this non-conformity imposes barriers on users or potential users of the web page, mobile application or non-web document, ensure that other reasonable measures to remove those barriers are taken. This includes establishing alternative means for accessing the key information that is provided on the web page, mobile application or non-web document or for performing the tasks associated with the web page, mobile application or non-web document. Exceptions regarding alternative measures apply for maps, mapping services, technical drawings or images on the web pages.

2. Accessibility Statements

Regulated private-sector entities with an average of 500 or more employees, and public-sector entities, must publish an accessibility statement no later than the day on which the obligations begin to apply. These accessibility statements must be refreshed on an annual basis, and must, among other things:

• Acknowledge the entity’s digital accessibility obligations under the ACA
• Describe the accessibility features of the web page, mobile application or non-web document to which it relates
• Provide an overview of any instances of non-conformance with the ICT Standards
• If any non-conformance with the ICT Standards imposes barriers on users, describe the other measures taken to remove barriers, including alternative means for accessing information or performing tasks
• Describe clearly plans for addressing any non-conformity with the ICT Standards
• Be accessible in a prominent location on each web page to which it relates, or, in the case of a mobile application, on the application’s home screen.

3. Conformity Assessments

Regulated entities must conduct or obtain a conformity assessment, including a gap analysis, against the applicable requirements in the ICT Standard in respect of any web page or mobile application subject to the Digital Technologies Accessibility Regulations, as well as any mobile application the entity continues to make available for download that was launched before the day on which the Digital Technologies Accessibility Regulations’ obligations first apply.

Additionally, when regulated entities (except broadcasting or telecommunication entities) with an average of 500 or more employees procure products or services in connection with the development or provision of any web page or mobile application subject to the Digital Technologies Accessibility Regulations, they must, as part of the procurement process, obtain a conformity assessment, including a gap analysis, against the applicable requirements of the ICT Standard with respect to the web page or mobile application.

Any conformity assessment must be retained in electronic format for four years.

4. Training

Regulated entities (except certain transportation service providers) must ensure that all employees involved in the development, maintenance or procurement of information and communication technologies, receive training on accessibility fundamentals in relation to those technologies at least once every three years. Regulated entities must retain electronic records of all training provided for four years.

Timeline for Compliance

The new obligations established for federal public-sector entities, except in respect of mobile applications and non-web documents, come into force on December 5, 2027.

The new obligations established for the private sector, and for the federal public sector in respect of mobile applications and non-web documents, come into force on December 5, 2028.

Additional Considerations

The Digital Technologies Accessibility Regulations helpfully clarify that a regulated entity described in paragraph 7(1)(f) of the ACA that acts in the name of, or for the benefit of, an entity that has obligations under the new regulations must also comply with those same obligations. If the entity acting for the other entity fails to comply, then it is subject to the same enforcement and administrative monetary penalty scheme as the entity it acts for.

The Regulatory Impact Analysis Statement that accompanies the Digital Technologies Accessibility Regulations makes clear that the federal government intends to issue guidance to regulated entities on how to conduct conformity assessments, provide information in alternative formats, provide training and draft accessibility statements, among other topics. Regulated entities should pay close attention to this guidance when preparing to comply.

For more information, please contact the authors of this bulletin.