Plans, feedback processes and reporting

Planning and reporting cycles

As a federally regulated organization, your accessibility planning and reporting cycle is determined by the Accessible Canada Regulations. Each cycle lasts three years. The three-year cycle looks like this:

  • Year 1: Accessibility Plan
  • Year 2: Progress Report
  • Year 3: Progress Report

At the end of each cycle, a new cycle begins. Accessibility is an ongoing practice.

In year one of the first cycle, you must publish what is called your initial accessibility plan. The deadline for publishing this first accessibility plan is determined by the Accessible Canada Regulations and varies depending on the type of organization.

Accessibility plans

Initial accessibility plan

An initial accessibility plan is the first plan that an organization prepares and publishes under the Accessible Canada Regulations. To prepare their plan, the organization must consult people with disabilities and take the principles of the Act into account. The organization must look at its policies, programs, practices and services to identify and remove barriers and to prevent new barriers. An explanation of what to include in an accessibility plan is available on the page: Notifying the Accessibility Commissioner.

Updated accessibility plan

An updated accessibility plan addresses the feedback received from employees, clients, and members of the public since the initial plan was put into place. The updated plan deals with the same areas as the initial plan. Organizations must consult people with disabilities and take the principles of the Act into account, just as they did with their initial plans.

Publishing updated accessibility plans

An organization must publish an updated accessibility plan every three years. More specifically, it must publish its updated plan no later than 36 months after the date on which the last accessibility plan had to be published. To find out when an organization’s updated accessibility plan must be published, look at when its last accessibility plan had to be published and calculate 36 months from that date.

Amended accessibility plan

An amended accessibility plan is not considered a new or an updated plan. Amendments correct the text of the original plan. For example, an amended updated plan is a correction of that updated plan. A regulated organization must notify the Accessibility Commissioner each time it changes and publishes its accessibility plan.

Organizations may decide to amend their accessibility plans for a variety of reasons. For example, they may be required to amend their plans to correct non-compliance that was identified as part of an inspection. They may also decide to amend their plans in response to feedback they received.

Amendments of accessibility plans do not change the planning and reporting cycle.

The feedback process

A feedback process is how an organization receives and deals with feedback:

  • on its accessibility plan, and
  • on the barriers employees and other people (for example, customers, clients, suppliers, the public) face when dealing with the organization (for example, online, in person, by phone).

Organizations must establish a feedback process that:

  • assigns a person responsible for receiving feedback on behalf of the organization and provide the position title of that person
  • allows people to give feedback anonymously (without giving personal information)
  • allows people to provide feedback by:
    • mail
    • telephone
    • email
    • or any other means the organization uses to communicate with the public
  • acknowledges feedback in the same way the feedback was received (except for anonymous feedback)

Publishing descriptions of feedback processes

Organizations must publish the description of their feedback process when they publish their initial accessibility plans.

Amending the feedback process

Organizations may amend their feedback process at any time. A description of the new version must be published as soon as possible after any change. Organizations must also notify the Accessibility Commissioner within 48 hours after publishing an amended description of the feedback process.

Progress reports

Progress reports explain the progress organizations have made in carrying out their accessibility plans. They contain information received through the feedback process and how the organization has considered that feedback. Organizations must consult people with disabilities in the preparation of their progress reports.

Publishing progress reports

Organizations must publish progress reports in the second and third year of each planning and reporting cycle (i.e., each year in between publishing their accessibility plans). Organizations must publish their first progress report one year after the deadline for publishing their last accessibility plan. They must publish their second progress report two years after the deadline for publishing their last accessibility plan.

Publication requirements

Accessibility plans, feedback process descriptions, and progress reports must be published:

  • in simple, clear, and concise language
  • in a format that meets Level AA conformance set out in the Web Content Accessibility Guidelines (WCAG); this means the most recent version that is available in both English and French of WCAG, published by the World Wide Web Consortium
  • on the main digital platform that the organization uses to communicate with the public (for example, a public-facing web site)
  • in a way that makes these items accessible
    • directly on the home screen or home page of the digital platform OR
    • by a hyperlink from the home screen or home page of the digital platform

If an organization does not have a digital platform that the public can access, it must publish its accessibility plans, feedback process description, and progress reports by displaying a printed copy of these items in the reception area or entrance of each of its places of business and in a location that is clearly visible and accessible to the public.

Accessibility plan deadlines

Organization type 1

If your organization is a:

  • Ministerial department
  • Parliamentary entity
  • Departmental agency
  • Departmental corporation or service agency
  • Crown corporation
  • Federal public administration
  • Royal Canadian Mounted Police
  • Canadian Forces

Your organization’s initial accessibility plan is due December 31, 2022. ACR s. 4(1)(a)

Organization type 2

If you or your organization is operating a federally regulated service or business and is:

  • a person (including, for example, a corporation such as a bank);
  • privately owned (for example, a trucking company or a shipping company);
  • a partnership;
  • an unincorporated organization; or
  • acts in the name of, or for the benefit of, an organization listed above,
    and
    had an average of 100 or more employees in 2021.

Your organization’s initial accessibility plan is due June 1, 2023. ACR s. 4(1)(b)

(This definition does not include organizations that conduct any work, undertaking or business of a local or private nature in Yukon, the Northwest Territories, or Nunavut.)

Organization type 3

If your organization is operating a federally regulated service or business and is:

  • a person (including, for example, a corporation such as a bank);
  • privately owned (for example, a trucking company or a shipping company);
  • a partnership;
  • an unincorporated organization; or,
  • acts in the name of, or for the benefit of, an organization listed above
    and
    had an average of 10 to 99 employees in 2021.

Your organization’s initial accessibility plan is due June 1, 2024. ACR s. 4(1)(c)

(This definition does not include organizations that conduct any work, undertaking or business of a local or private nature in Yukon, the Northwest Territories, or Nunavut.)

Organization type 4

Your organization became subject to the Accessible Canada Act during any year after 2021.

Your organization’s initial accessibility plan is due on June 1st, two years after your organization became subject to the Act. ACR 4(2)

For example: if your organization was established in November 2022. Your initial accessibility plan is due on June 1, 2024.

Organization type 5

Your organization was exempt from publishing an accessibility plan because it had an average of fewer than 10 employees.

If your employee count changes throughout the year and you are unsure whether this means that you are now subject to the Act and need to publish a plan, contact us for clarification. ACR 4(3)

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