How to operationalize your Accessible Canada Act commitments
This article was originally published on March 4, 2024, and was updated on February 23, 2026.
In 2019, the Accessible Canada Act (ACA) set an ambitious goal: create a barrier-free Canada by 2040. Most government organizations and the private companies that service them have now published one or more three-year Accessibility Plans. These plan outline how they will identify, remove, and prevent barriers for people with disabilities.
But publishing a plan isn’t the same as operationalizing it, and a tightening regulatory landscape adds even more pressure.
- In December 2025, the federal government amended the Accessible Canada Regulations under the ACA to include Digital Technologies Accessibility Regulations.
- In additional meeting the existing guidelines, organizations subject to the new rules must also remove and prevent accessibility barriers across web pages, mobile applications, and digital documents. Changes come into effect between December 5, 2027 and December 5, 2028.
For UX, design, and accessibility leaders already juggling competing priorities, there’s been a shift in the nature of the work to be done. Accessibility is no longer about checking a compliance box. It’s about demonstrating measurable progress over time.
In fact, the ACA requires that organizations publish yearly reports detailing how teams are putting accessibility commitments into practice. This level of accountability exposes real constraints. It also raises the harder question of how you know whether your digital services are actually usable for people with disabilities. Before outlining practical ways to move forward — including meeting the ACA mandate to work directly with people with disabilities — it’s worth exploring where accessibility work often gets stuck.
Multiple friction points stall accessibility progress
As digital accessibility commitments deepen, systemic gaps are harder to ignore.
Team capacity
Teams are lean, and accessibility expertise may be concentrated in a few individuals or absent altogether. Accessibility work competes with mandates like digital transformation, service delivery targets, and urgent policy changes. When everything is labelled “high priority,” accessibility work can get pushed down the priority list.
Cross-team ownership
An accessibility expert may have authored the three-year Accessibility Plan under ACA, but delivery depends on a wider team that could include IT, procurement, research, design, and even external vendors. Without shared ownership, accessibility can be treated as guidance instead of an integral part of how work gets done.
Technology and vendor constraints
Legacy systems, platform limitations, and vendor-controlled tools can create structural barriers to embedding accessibility into digital services. Teams may understand what needs to change but lack authority or technical access to act.
Systems are set up for stability and predictability
Securing funding for complex projects is an ongoing challenge in the public sector. Annual budget cycles rarely align with multi-year transformation efforts. Procurement processes are designed to reduce risk, which can make large-scale structural changes harder to initiate. Budget overruns erode trust and make future funding harder to justify.
These friction points are real, but they’re also solvable. There are practical steps teams can take to make meaningful progress on accessibility work.
Multiple friction points stall accessibility progress
As digital accessibility commitments deepen, systemic gaps are harder to ignore.
Team capacity
Teams are lean, and accessibility expertise may be concentrated in a few individuals or absent altogether. Accessibility work competes with mandates like digital transformation, service delivery targets, and urgent policy changes. When everything is labelled “high priority,” accessibility work can get pushed down the priority list.
Cross-team ownership
An accessibility expert may have authored the three-year Accessibility Plan under ACA, but delivery depends on a wider team that could include IT, procurement, research, design, and even external vendors. Without shared ownership, accessibility can be treated as guidance instead of an integral part of how work gets done.
Technology and vendor constraints
Legacy systems, platform limitations, and vendor-controlled tools can create structural barriers to embedding accessibility into digital services. Teams may understand what needs to change but lack authority or technical access to act.
Systems are set up for stability and predictability
Securing funding for complex projects is an ongoing challenge in the public sector. Annual budget cycles rarely align with multi-year transformation efforts. Procurement processes are designed to reduce risk, which can make large-scale structural changes harder to initiate. Budget overruns erode trust and make future funding harder to justify.
These friction points are real, but they’re also solvable. There are practical steps teams can take to make meaningful progress on accessibility work.
Five ways to operationalize digital accessibility
1. Secure executive sponsorship
Accessibility plans often sit with UX or accessibility leads who have limited power over budget allocations, vendor changes, and roadmap decisions. Sponsorship at the Assistant Deputy Minister or Deputy Minister level helps ensure accessibility work is funded, prioritized and treated as a delivery requirement rather than an advisory function.
2. Break down departmental silos
Since digital services implement policy decisions, barriers often originate upstream. Coordinating across policy, digital, and other service channels leads to more accessible outcomes.
- Cross-department working groups help distribute ownership and align priorities.
- Shared forums make it easier to pool resources and navigate funding constraints.
3. Embed accessibility into procurement
If vendors aren’t contractually accountable for accessibility, the compliance risk transfers to your organization. Procurement contract language should be specific. For example, “must meet WCAG” is vague, whereas “must work with screen reader technology” is a directive.
4. Train staff to succeed
Under the latest Accessible Canada Regulations amendments, federal public sector organizations and large and medium-sized businesses must train their employees on digital accessibility by December 5, 2027.
Accessibility training isn’t just about meeting the mandate. It equips teams with the knowledge to design and deliver accessible products from the outset, while helping them identify issues early and reduce costly rework.
The most effective training programs are:
- Ongoing
- Easy to access and digest
- Grounded in practical how-to’s that staff can easily connect to daily practice, regardless of role or skill level
5. Work directly with people with disabilities
Consulting with people with disabilities is a requirement under the Accessible Canada Act. It’s also an effective way to establish meaningful feedback loops. Done well, this type of consultation demonstrates progress and builds accountability into your accessibility efforts.
The Digital Technologies Accessibility Regulations now require conformance with CAN/ASC-EN 301 549, Canada’s ICT accessibility standard. For web content, this largely aligns with WCAG requirements and establishes a measurable technical baseline.
This baseline is necessary, but it doesn’t mean digital experiences will be usable for people with disabilities. Achieving usability requires testing digital products with people with disabilities. This allows teams to observe how web pages, mobile applications, and digital documents perform in real-world contexts with assistive technologies, diverse cognitive needs, and even varying levels of digital literacy.
There are a few potential barriers to doing this well, but once you recognize them, you can work around them.
How to overcome practical barriers to inclusive research
The most common blockers in inclusive research are operational, but the challenges are highly solvable.
Barrier: Recruitment challenges
Recruiting from community organizations or service providers is inconsistent, and it can be challenging to find a representative mix of participants.
Counting on internal staff to recruit slows momentum and pulls them away from higher-value activities.
Leveraging an internal employee network of people with disabilities to test digital experiences often requires them to do accessibility testing off the side of their desk. This can slow research momentum and cause undue pressure for the employee who is juggling primary job priorities.
Impactful workarounds
Build access to a reliable, external participant pool rather than relying on ad hoc community outreach or internal staff.
Platforms that maintain pre-vetted and trained communities of people with disabilities reduce recruitment time and improve participant fit.
Barrier: Lack of tester diversity
Teams may over index on a particular type of assistive technology (e.g., screen readers) when broader representation is required.
Digital accessibility isn’t just about working with assistive technologies. Cognitive disabilities affect how people perceive and interact with digital products. And cognitive is the most prevalent form of disability.
Cognitive needs also change as we age. By 2030, seniors could represent almost a quarter of the Canadian population. If accessibility under ACA is about measurable progress, cognitive needs should be part of the equation.
Impactful workarounds
Find a solution that allows you to customize your participant audience to match your research goals.
Use recruitment approaches that allow you to define vision, mobility, and cognitive accessibility needs and assistive technology use rather than defaulting to a single technology group.
Barrier: Team confidence
Some UX researchers may feel they lack the expertise required to test digital products with people with disabilities.
Impactful workarounds
Explore unmoderated research options, like self-guided tasks and unmoderated usability tests, which let you evaluate usability and accessibility without running a live interview.
Self-guided training can help your team get more comfortable conducting research with people with disabilities.
You can also go more hands-on and seek out an expert partner to teach your team how to do accessibility testing, co-conduct research with you, or even do it for you when deadlines and capacity are tight.
Turn accessibility commitments into practice
Publishing plans was the first Accessible Canada Act requirement. Now the work has shifted to operationalizing accessibility.
This means embedding accessibility into research, design, and delivery processes that can withstand staff turnover and funding cycles. Performative compliance creates risk exposure. Measurable progress, grounded in real usability for people with disabilities, is what distinguishes compliance from meaningful accessibility.
