All non-exempt telecommunications service providers (TSPs) and broadcasters registered with the Canadian Radio-Television and Telecommunications Commission (CRTC) must comply with the upcoming June 1, 2025, reporting deadline under the Accessible Canada Act (ACA), the CRTC’s Accessibility Reporting Regulations, and the Accessible Canada Regulations (ACR). Failure to meet these accessibility obligations can result in administrative monetary penalties (AMPs), enforceable against both organizations and individuals.
This year, every impacted provider must publish an Accessibility Progress Report. For some, this will be their first progress report, while others will be submitting their second progress report as part of the ACA’s three-year reporting cycle. Providers are also required to separately notify the Accessibility Commissioner within 48 hours of publishing their report through the My Accessibility Portal, as well as the CRTC.
2025 ACA Reporting Requirements
Your company’s specific reporting obligations depend on its current position within the ACA’s three-year compliance cycle:
- First Progress Report Due: If your company was required to publish its initial accessibility plan by June 1, 2024, its first accessibility progress report is due by June 1, 2025.
- Second Progress Report Due: If your company was required to publish its initial accessibility plan by June 1, 2023, its second progress report is due by June 1, 2025.
- New Entrants to the Market: If your company entered the Canadian telecommunications market in 2024, your first ACA deliverable, the description of your accessibility feedback process, is due by June 1, 2025.
- Catching up: If your company missed one or more prior ACA reporting deadlines and has not since come into compliance, we encourage you to seek legal counsel as soon as possible if you have not done so yet to discuss your options.
In all cases, providers must notify the CRTC within 48 hours of publishing their accessibility feedback process, accessibility plan, or progress report—or by June 1, whichever is earlier.
Key Compliance Actions
To meet the ACA’s requirements, TSPs should immediately begin preparations:
- Draft and Finalize Progress Reports: Progress reports must provide meaningful updates on efforts to identify, remove, and prevent accessibility barriers. This includes measurable progress on commitments made in the initial accessibility plan.
- Consult with Persons with Disabilities: As required by the ACA, accessibility plans and progress reports must be prepared in consultation with persons with disabilities. Engage stakeholders early to ensure meaningful input is incorporated.
- Notify the Accessibility Commissioner: Use the My Accessibility Portal to notify the Accessibility Commissioner of the report’s publication within 48 hours.
- Maintain Ongoing Compliance: Beyond reporting, TSPs must comply with ongoing accessibility obligations, including:
- Providing Teletypewriter Relay (TTY) and Internet Protocol (IP) Relay Services 24/7.
- Ensuring websites are compatible with assistive technologies, meeting the standard of reasonable accommodation.
- Supplying information in alternate formats (Braille, large print, audio, etc.) upon request.
Why This Matters
The ACA aims to achieve a barrier-free Canada by 2040, and the CRTC has made clear that non-compliance with accessibility obligations will result in enforcement actions and financial penalties. With the FCC and other regulatory bodies in North America stepping up enforcement of accessibility rules, it is critical for telecommunications providers to proactively meet their ACA obligations. Additionally, if your company does not take accessibility seriously, your employees with disabilities may not be able to perform the essential functions of their jobs, while disgruntled customers may shift to competitors who better meet their access needs.
What to Do Next
- Start Preparing Now: Begin compiling the necessary information for your accessibility progress report.
- Engage with Stakeholders: Schedule consultations with persons with disabilities to gather input for your report.
- Review Ongoing Compliance: Ensure that all accessibility services and accommodation are fully operational and meet ACA standards.
- Plan for Timely Submission: Publish the report by June 1, 2025, and notify both ACA regulators within 48 hours of publication.
Contact Our Firm Today to Ensure Compliance with Canadian and U.S. Accessibility Requirements
If you have questions about the applicability of the Accessible Canada Act or its implementing regulations, need assistance with preparing your compliance documentation, or need to ensure you are meeting your accessibility obligations in Canada or the U.S., please contact Michal J. Nowicki at (703) 714-1311 or mjn@commlawgroup.com.
