[Home](/)/[Resources](/resources)/Accessible Canada Act CanadaAccessibility compliance guide # Accessible Canada Act: What Electronics Hardware Companies Need to Know Canada's Accessible Canada Act targets a barrier-free Canada by 2040. For electronics hardware companies, the most direct implications are in federal procurement — where ICT accessibility standards (EN 301 549) are increasingly required — and, for federally regulated companies, in mandatory accessibility plans and ICT interface compliance. With Canada aligning to the same EN 301 549 standard as the EU, a single accessibility compliance effort increasingly serves both markets. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fcanada-accessible-canada-act) At a glance Law Accessible Canada Act (2019) ICT standard EN 301 549 / WCAG 2.1 AA Target Barrier-free by 2040 Procurement Federal accessibility requirements ## ACA obligations for electronics companies ### What the Accessible Canada Act requires The Accessible Canada Act (ACA), in force since 2019, aims to realise a barrier-free Canada by 2040. It requires federally regulated entities — federal government departments, Crown corporations, federally regulated employers (banks, telecoms, broadcasters, transportation companies), and organisations in the federal legislative authority — to identify, remove, and prevent accessibility barriers in seven priority areas: employment; the built environment; information and communication technologies (ICT); communication other than ICT; the procurement of goods, services, and facilities; the design and delivery of programs and services; and transportation. ### Who is covered: federally regulated employers and entities The ACA's proactive obligations (accessibility plans, progress reports, feedback mechanisms) apply to organisations within federal jurisdiction. This includes federally regulated employers with 10 or more employees. Electronics hardware companies incorporated in Canada and engaged in federally regulated activities (banking, telecom, broadcasting, interprovincial transport) are subject to ACA obligations. Electronics hardware companies that are not federally regulated employers — most product manufacturers without regulated activities — are not directly required to publish ACA accessibility plans, but they may be subject to accessibility requirements as suppliers to federal government through the Government of Canada's accessible procurement framework. ### ICT and connected device accessibility The ICT priority area under ACA is directly relevant to electronics hardware companies selling devices with interfaces to Canadians. Accessibility standards for ICT being developed by the Accessibility Standards Canada organisation (with reference to EN 301 549, the European accessibility standard for ICT) will apply to electronic products sold to or used by federal entities. Connected device manufacturers should assess their products against EN 301 549 / WCAG 2.1 AA for any ICT interfaces — touchscreens, apps, voice interfaces, web portals — as federal procurement increasingly requires these standards. ### Accessible procurement for federal supply The Government of Canada's accessible procurement policy requires that goods, services, and facilities procured by federal departments meet accessibility standards. For electronics hardware companies seeking federal government contracts in Canada, this creates a direct accessibility compliance requirement: your product must meet the applicable accessibility standards (currently evolving towards mandatory EN 301 549 adoption for ICT) to be eligible for federal procurement. Federal buyers increasingly include accessibility requirements in tender specifications and evaluate supplier compliance as part of the award process. ## Accessibility compliance steps 01 Determine whether your organisation is a federally regulated entity under the ACA: if you operate a bank, telco, broadcaster, interprovincial transport company, or federal Crown corporation in Canada, you have direct ACA obligations — publish an accessibility plan within the legislated timeframe and file progress reports every 3 years. 02 If you are a hardware manufacturer without direct ACA entity obligations but you supply to the federal government or federal entities, review the Government of Canada's accessible procurement requirements: your products must meet applicable ICT accessibility standards for federal procurement eligibility. 03 Assess your connected device ICT interfaces (touchscreens, apps, companion software, web portals) against EN 301 549 / WCAG 2.1 AA — this is the international standard Canada is aligning to for ICT accessibility and is increasingly referenced in federal procurement requirements. 04 Review your product's physical accessibility features: button size and tactile differentiation for users with motor disabilities, audio output levels and hearing aid compatibility, display contrast ratios and text size options, and physical connector accessibility all fall within hardware accessibility design. 05 Establish a feedback mechanism for accessibility concerns: even if not directly required by ACA, having a documented process for receiving and acting on accessibility feedback from Canadian customers demonstrates good faith accessibility commitment and aligns with the ACA's feedback mechanism requirements for regulated entities. 06 Monitor Accessibility Standards Canada for published accessibility standards: AS Canada develops binding standards in the ACA priority areas — monitor their published and draft standards for ICT, built environment, and employment to anticipate requirements that may become mandatory for regulated entities and influence voluntary standards for others. 07 For provincial compliance: Ontario's Accessibility for Ontarians with Disabilities Act (AODA), Nova Scotia's Accessibility Act, and other provincial equivalents may create additional obligations for electronics companies operating in those provinces — ACA is the federal layer, but provincial accessibility law operates alongside it. ## Frequently asked questions ### Is the Accessible Canada Act the same as AODA? No — the Accessible Canada Act (ACA) is federal legislation that applies to federally regulated entities and federal government organisations. AODA (Accessibility for Ontarians with Disabilities Act) is Ontario provincial legislation that applies to businesses operating in Ontario (including private sector businesses, not just federally regulated ones). A hardware company selling in both Ontario and to the federal government may need to comply with both AODA's customer service and ICT standards and the ACA's procurement accessibility requirements. Other provinces have their own accessibility frameworks. ### What accessibility standard applies to ICT products under ACA? The Government of Canada has adopted EN 301 549 (Accessibility requirements for ICT products and services) as its reference ICT accessibility standard — this is the same standard that underlies the EU's European Accessibility Act requirements. EN 301 549 V3.2.1 incorporates WCAG 2.1 success criteria for web and software content, and adds hardware-specific requirements for interactive voice response, electronic documents, two-way voice communication, and physical hardware. For electronic hardware with digital interfaces, EN 301 549 Chapter 8 (hardware) is the primary reference. ### Does ACA create private right of action for accessibility discrimination? ACA creates a complaints-based enforcement mechanism through the Canadian Human Rights Commission (CHRC) and the Accessibility Commissioner. Individuals can file complaints about accessibility barriers maintained by federally regulated entities. ACA does not create a broad private right of action for product accessibility in the way that some US accessibility lawsuits under the ADA target websites and apps. However, the Canadian Human Rights Act's prohibition on discrimination based on disability applies to federally regulated entities and provides a separate complaints route. ### What should a hardware company do to prepare for Canada's accessible procurement requirements? The most practical preparation is to conduct an EN 301 549 conformance assessment of your products' ICT interfaces and document the results in an Accessibility Conformance Report (ACR) using the Voluntary Product Accessibility Template (VPAT) format or equivalent. Federal procurement officers increasingly request ACRs from technology vendors. Where your product does not conform to EN 301 549 requirements, documenting the gaps and your roadmap to address them demonstrates transparency and good faith — and often satisfies procurement accessibility requirements better than silence. **Disclaimer:** Educational resource only. ACA obligations differ between federally regulated entities and private sector suppliers. Consult a qualified Canadian accessibility law specialist and EN 301 549 conformance assessor for product-specific compliance planning. 🇨🇦 Canada roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇨🇦 Canada compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/47-canada-ised-ic-certification-radio-equipment)[Prefer to read? Get the book — $24.99](/books/47-canada-ised-ic-certification-radio-equipment) Related guides * [Canada CASL Connected DevicesCanada CASL for connected hardware: Section 8 computer program installation consent requirements, OTA firmware update CASL analysis, CEMs from device companion apps, $10M maximum penalty per violation, and CRTC enforcement priorities for IoT devices.](/guides/canada-anti-spam-casl-connected-devices) * [Canada CBSA Import ProceduresCanada CBSA import procedures for electronics: CARM portal B3 accounting document submission, CUSMA/USMCA tariff preference origin rules, CAD $20 de minimis threshold for commercial imports, advance rulings, and CBSA audit risk for electronics importers.](/guides/canada-cbsa-import-procedures) * [EU Accessibility Act HardwareEU Accessibility Act (EAA) for hardware: product accessibility requirements under Directive 2019/882, functional accessibility criteria, conformity assessment, and the 2025 deadline for placing products on the EU market.](/guides/eu-accessibility-act-hardware) * [Australia Notifiable Data BreachesAustralia Notifiable Data Breaches (NDB) scheme under Privacy Act 1988 for connected hardware: eligible data breach criteria, 30-day OAIC notification, Privacy Act reform removing small business exemption, and penalties up to AUD $50M or 30% of turnover for serious violations.](/guides/australia-notifiable-data-breaches) * [Canada Product Accessibility RequirementsThe Accessible Canada Act and provincial regimes like AODA applied to hardware: barrier-free product design standards, packaging and documentation accessibility, ACA compliance timelines, and AODA technical standards.](/guides/canada-accessibility-requirements-products)