New Guidance on Employee Training Requirements Under the Digital Technologies Accessibility Regulations

On June 30, 2026, Employment and Social Development Canada (ESDC) published Guidance for Providing Training on Digital Accessibility Fundamentals (Guidance) pertaining to the new employee training requirements under the Regulations Amending the Accessible Canada Regulations (Digital Technologies Accessibility Regulations), which were made under the Accessible Canada Act. For an overview of the new Digital Technologies Accessibility Regulations, see our Blakes Bulletin: Federal Government Finalizes New Digital Technologies Accessibility Regulations.

Effective December 5, 2027, regulated private sector organizations, such as banks, federally regulated transportation businesses including airlines, and telecommunications and broadcasting sectors, will be required to provide training on accessibility fundamentals for all employees involved in the maintenance, development or purchasing of information and communication technologies. This new requirement will apply to federally regulated public-sector organizations regardless of size and federally regulated private-sector organizations that had an average of 100 or more employees during the preceding three-year period. 

The Regulations do not prescribe a specific type, level or classification of employee that must receive training. The new Guidance confirms that every regulated organization must identify the employees who are responsible for or contribute to the development, maintenance or purchase of the digital technologies and ensure they receive training on digital accessibility fundamentals.

Notably, the Guidance does not offer a definition of “digital accessibility fundamentals,” but it does provide reference to the Accessibility Fundamentals Overview as a helpful resource. The Guidance further includes a “frequently asked questions” section and a best practices checklist to help readers navigate the training obligations for their organization.

The Regulations do not specify how training must be delivered. Under the Guidance, it is suggested that training may include interactive webinars, self-paced learning, workshops or any other format that is effective for the organization and its employees. However, the Guidance provides that ultimately, by the end of employee training, employees should understand the legal and regulatory requirements of the Regulations, including the relevant clauses of the ICT Standard that are intended to prevent and remove digital accessibility barriers from the outset.

All regulated organizations subject to the Digital Technologies Accessibility Regulations are required to maintain digital records of completed employee digital accessibility training for at least four years. The Guidance indicates that organizations should retain sufficient information to demonstrate that the training was complete, including the employee’s name and their role in the maintenance or purchase of digital technologies, as well as the type, content, format and duration of the training and its date of completion.

ESDC has also published more general guidance on the Digital Technologies Accessibility Regulations. 

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