Digital accessibility is no longer just a best practice for federally regulated organizations in Canada. With the amendments to the Regulations Amending the Accessible Canada Regulations: SOR/2025-255, digital accessibility is becoming a clearer, more measurable compliance obligation under the Accessible Canada Act. These changes introduce new requirements for web pages, mobile applications, and digital documents, and they signal an important shift in how organizations need to think about accessibility online.

For many organizations, accessibility planning has focused on publishing accessibility plans, creating feedback processes, and preparing progress reports. Those requirements remain important. However, the new amendments add a more technical layer. Organizations will need to look closely at the digital tools, websites, web applications, intranets, mobile apps, and downloadable documents they create or update. The focus is no longer only on saying how barriers will be identified, removed, and prevented. Organizations will also need to show how their digital technologies conform to accessibility requirements.

The amendments create a new part in the regulations focused on Information and Communication Technologies, often called ICT. This new part requires certain federally regulated organizations to make covered digital technologies accessible by following the ICT Standard, formally called CAN/ASC-EN 301 549, Accessibility requirements for ICT products and services. The summary provided by the government identifies three priority areas covered by the new digital accessibility rules: new and updated web pages, new mobile applications, and new and updated digital documents.

This matters because digital barriers can prevent people with disabilities from accessing jobs, programs, services, information, and participation. A website that cannot be navigated by keyboard, a PDF that is not readable by a screen reader, or a mobile app that does not support accessible interaction can all create real exclusion. The new rules are designed to reduce those barriers by making digital accessibility a built-in requirement, not an afterthought.

The regulations focus on three broad categories of digital assets.

First, they cover web pages, including public-facing web pages and, for certain entities, employee-facing web pages. Employee-facing web pages are pages primarily intended for use by employees, which means intranet pages and internal portals may be captured where the requirements apply. For web pages, the rules apply to pages that are created or updated on or after the applicable date.

Second, the rules cover mobile applications. The summary of the changes explain that federal public sector organizations and large businesses must make new public-facing mobile applications follow the digital standard, and must also assess the accessibility of certain existing public-facing mobile applications by December 5, 2028.

Third, the rules cover non-web documents. This includes files such as PDFs that are made available for download from public-facing websites or mobile applications. The rule applies to covered digital documents that are made available for download on or after the applicable date.

One of the most important new requirements is the accessibility statement. This is not the same as an accessibility plan. An accessibility plan is broader and explains how an organization identifies, removes, and prevents barriers. An accessibility statement is more specific. It is a public explanation of how the organization’s covered digital technologies are accessible, where gaps remain, and what the organization is doing about those gaps.

The accessibility statement must be written in simple, clear, and concise language. It must include the date it was published and provide contact information for accessibility matters. The regulation requires at least two forms of contact information from the following options: an email address, a telephone number, or a mailing address.

The statement must also acknowledge the organization’s obligations under the ICT part of the regulations. It must describe the accessibility features of the web pages, mobile applications, or digital documents it covers. It must also provide an overview of any areas where the organization is not meeting the ICT Standard.

Where full conformity is not feasible and that lack of conformity creates barriers, organizations must describe the alternative measures they have taken. This may include alternative ways for a person to access key information or complete a task. The statement must also describe plans and timelines for addressing gaps in conformity with the ICT Standard.

The statement must be published no later than the day the digital accessibility obligation first applies to the organization, and then updated once every 12 months. Organizations must also keep an electronic copy of the statement for four years.

The safest way to think about this is that the accessibility statement must be easy to find from the digital assets it covers. The regulation says the statement must be accessible from a prominent location on each web page to which it relates. That does not necessarily mean a completely separate accessibility statement is required for every individual page or every individual digital product. In many cases, one central statement may be able to cover multiple websites, apps, intranet pages, and downloadable documents, as long as it clearly explains what it covers and is prominently available from the relevant places.

For public websites, this could mean placing an “Accessibility Statement” link in the footer or main navigation. For intranets or employee portals, it could mean making the statement available in a consistent and easy-to-find location for employees. For mobile applications, organizations should consider how users will find accessibility information inside the app, such as through a help, settings, legal, or accessibility section. This implementation approach is a practical recommendation, not wording taken directly from the regulation.

The regulations recognize that full conformity with the ICT Standard may not always be feasible. They identify factors that are relevant when determining feasibility, including whether technology is available to support conformity, whether there are significant obstacles to implementing that technology and efforts to overcome them, and the organization’s degree of control over the digital asset, including through agreements with third parties.

This is important because “not feasible” does not mean “not required to think about accessibility.” Where conformity is not feasible and barriers are created, organizations may still need to take reasonable alternative measures to remove those barriers. The accessibility statement is where those gaps, alternative measures, plans, and timelines need to be communicated clearly.

The amendments also introduce training requirements for employees involved in the development, maintenance, or procurement of information and communication technologies. These employees must receive training on accessibility fundamentals for those technologies, and refresher training must be provided at least once every three years. Organizations must keep electronic records of this training for four years.

This is a major signal for employers. Digital accessibility cannot sit only with one accessibility lead or one compliance department. It needs to be understood by the people who buy, build, manage, update, and approve digital tools.

The requirements do not apply equally to every organization. The summary on these updates says the new digital accessibility rules apply to federal public sector organizations, federally regulated private businesses with 500 or more employees, and federally regulated private businesses with 100 to 499 employees, depending on the specific rule. It also states that federally regulated private businesses with 99 or fewer employees do not have to follow these rules, and that First Nations Band Councils do not have to follow them until December 2033.

The timing also varies. Federal public sector organizations must publish an accessibility statement for their websites by December 5, 2027, and that by December 5, 2028 the statement must also include mobile apps and digital documents. Large businesses must publish their first accessibility statement by December 5, 2028, covering websites, mobile apps, and digital documents.

Organizations should start by creating an inventory of their digital assets. This means identifying public websites, employee-facing intranet pages, web applications, mobile applications, and downloadable digital documents. They should also identify which assets are being created, updated, launched, or made available after the applicable dates.

Next, organizations should review how digital accessibility is handled in procurement, design, development, content creation, document publishing, and quality assurance. The goal should be to make accessibility part of the normal workflow, not something checked only at the end. We can support organizations with this process and their practices.

Organizations should also prepare their accessibility statement early. A strong statement should clearly name what it covers, explain accessibility features, identify known gaps, describe alternatives, and include realistic timelines for improvement. It should be written in plain language and reviewed every year.

These changes are not just about compliance. They are about access. Digital tools are now one of the main ways people apply for jobs, access services, complete forms, receive information, participate in training, and connect with organizations. If digital spaces are not accessible, people with disabilities are excluded from opportunities that others may take for granted.

The new requirements give organizations a clearer roadmap. They also raise expectations. Accessibility statements, digital conformity, training, assessments, and records all point in the same direction: accessibility needs to be planned, documented, maintained, and improved over time.

For employers and service providers, the best time to prepare is before the deadline. Organizations that act early will be better positioned to meet the rules, support employees and customers with disabilities, and build digital experiences that are more usable for everyone.