Planning your consultation: setting objectives

On this page

• Introduction
• Consulting on the planning and reporting requirements of the ACA
• Consulting for accessibility plans
• Consulting for progress reports
  • Feedback processes versus consultation input
• Consulting on the areas described in section 5 of the ACA
• Consulting to identify, remove, and prevent barriers

Introduction

Understanding that organizations have different resources, needs, and capabilities, there are different ways to consult. The Accessible Canada Act (ACA) and the Accessible Canada Regulations (regulations) do not require you to take a specific approach to your consultations. Given the range of possibilities and factors, planning an effective consultation can be a complex undertaking.

You will have to choose:

• the stage of preparing your accessibility plan or progress report in which you will consult
• the range of disabilities to represent when choosing whom to consult
• the types of questions to ask
• the format

When planning your consultations, you should determine some or all of the following:

• representation
  • who the persons with disabilities most involved with your organization are
  • who is most likely to encounter barriers specific to your organization
  • who has been marginalized, underserved or ignored in your industry/community
• venue
  • if your organization has an accessible meeting space for in-person consultations, or would need to book one
  • if you have a space, how many people, including those in wheelchairs, it can comfortably contain
  • if this venue is located somewhere that participants can get to easily
  • the annex on key disability concepts and accommodations has more tips, recommendations and details on best practices
• inclusivity
  • if your stakeholders would prefer a certain kind of consultation
  • if they have any privacy preferences:
    • if they would be comfortable expressing themselves in person through open discussions
    • if they would prefer the privacy of a phone call or an online survey
  • if opening your consultations to the public, rather than inviting individuals directly, would help or harm your process
  • there are more tips, recommendations and best practices in the annexes on inclusive language and intersectional and cultural considerations
• budget
  • the direct and indirect costs – in money, time, or resources – of the type of consultation you choose
  • if you will need to provide alternate formats of consultation materials
    • how much these will cost, and how long it will take to get them
  • the costs for interpreters (examples: sign language or Communication Access Realtime Translation (CART)), facilitators, or other staff
  • what professional services or support disability organizations might be able to provide for your consultation. For example:
    • interpreters' or CART services
    • services as independent facilitators
    • services to help assess the accessibility of your consultation’s physical or virtual spaces
• scheduling
  • if you are conducting in-person or live virtual events, when they will take place and how long they will last
  • how far in advance you must book interpreters, CART providers, or other support staff
  • if your schedule takes participants’ existing obligations and responsibilities into account
  • if your schedule avoids early-morning or late-evening events
  • if there are multiple components to an event, that you have left enough time between them for breaks, refreshments, and set-up
  • travel time for participants and staff
  • if any online or mail solicitations allow enough time for participants to prepare and submit their responses

Remember: you can use more than one form of consultation. In fact, you may want to use more than one if you are seeking responses from different people and groups. Learn more about some of the different types of consultations you may want to consider.

Consulting on the planning and reporting requirements of the ACA

The ACA requires that you consult persons with disabilities in the preparation of your accessibility plans and progress reports. This will help ensure you obtain information that is meaningful and useful for identifying, removing, and preventing barriers to accessibility. These consultations are not to gather opinions on marketing, consumer preferences, or policies that are unrelated to accessibility.

Remember that participants are investing their time and energy to help you. Respect their efforts by keeping your consultation focused on the subjects they agreed to discuss.

Remember as well that some participants may not be able to comment on every aspect of your policies, programs, practices, and services. For example, a client with a disability may be able to comment on your services, but not on your hiring practices. Persons with different disabilities may also have different experiences within the same area or subject. What is accessible for one person may not be accessible for all.

Consulting for accessibility plans

Your organization must prepare and publish accessibility plans. You must consult persons with disabilities in preparing these plans.

Your plans must include content under certain specific headings, including a “Consultations” heading. Under this heading, you must describe how you consulted persons with disabilities in preparing your plan.

Your plans must include content under specific headings, including a “Consultations” heading. Under this heading, you must describe how you consulted persons with disabilities in preparing your plan.

The regulations also require that your plans include headings for areas found in section 5 of the ACA. Your plans must address your policies, programs, practices and services in relation to the identification, removal, and prevention of barriers in these areas. Which areas you include in your plans, and how you address them, may depend on the regulatory authority or authorities you must notify.

For additional information on how to prepare and publish accessibility plans, consult our guidance on accessibility plans. You can also read the guidance subsection on different regulatory and enforcement authorities.

When scheduling consultations, keep in mind that there are deadlines by which entities must publish their first accessibility plans. Under the ACA, entities must publish their first accessibility plans within 1 year (12 months) after the day fixed in the regulations. The regulations fix different deadlines depending on entities’ nature and size:

• for government entities, including departments, agencies, Crown corporations, or government-related entities such as the Canadian Forces or Parliamentary entities
  • the regulations fix a date of December 31, 2021
  • those entities must therefore publish their first accessibility plans by December 31, 2022
• for large federally regulated private sector entities with an average of 100 or more employees
  • the regulations fix a date of June 1, 2022
  • those entities must therefore publish their first accessibility plans by June 1, 2023
• for small federally regulated private sector entities with an average of between 10 and 99 employees
  • the regulations fix a date of June 1, 2023
  • those entities must therefore publish their first accessibility plans by June 1, 2024

Your organization must take these deadlines into account when planning your consultations. There are at least 2 ways to do so.

One way is to consult persons with disabilities on a wide variety of barriers and other issues first. You would then write your plan based on the comments they provide. Read more on questions to ask about barriers.

Another way is to write a draft version of your plan first and then consult persons with disabilities on ways to improve it. If you do this, you could ask participants whether or not your plan:

• sets realistic and achievable goals
  • explains how your organization will achieve those goals
  • provides a rationale for why your organization made certain decisions and proposed certain actions
  • covers all of the topics that it ought to
• is similar to or different from any other accessibility plans participants may have seen
• demonstrates that the required consultations have been or will be meaningful
• is simple, clear and concise
• is laid out in a manner that they find accessible
• should receive more significant changes when your organization updates the plan in the future

You must allow enough time after the consultation to analyze the information you receive. You must also allow time to write the description of how you consulted to include in your plan.

Consulting for progress reports

Your organization must prepare and publish progress reports about the implementation of your accessibility plans. You must consult persons with disabilities in preparing these progress reports.

As with your accessibility plans, your progress reports must include content under specific headings, including a “Consultations” heading. Under this heading, you must describe how you consulted persons with disabilities in preparing your report.

The regulations also say that progress reports must include headings for areas found in section 5 of the ACA. Progress reports must provide information respecting the implementation of your organization’s accessibility plans, which also addressed these areas. Which areas you include in your plans and reports, and how you address them, may depend on the regulatory authority to which you report.

Additional guidance on progress reports will be available in 2022. You can also read the guidance subsection on different regulatory and enforcement authorities.

When planning consultations for your progress reports, remember that the regulations’ planning and reporting cycle determines when you must publish those reports. You must publish or update your accessibility plans on a 3-year (36-month) cycle. Section 13 of the regulations explains that you must publish a progress report in each of the years that fall between each version of your accessibility plan.

For example, if you are an entity that must publish its first accessibility plan by December 31, 2022, you would then be required to publish:

• a progress report on that plan by December 31, 2023
• another progress report on that plan by December 31, 2024
• an updated accessibility plan by December 31, 2025
• a progress report on that updated plan by December 31, 2026
• and so on

Remember: the deadline for publishing your first progress report depends on the deadline for publishing your first accessibility plan. The requirements and deadlines for publishing a first accessibility plan are not the same for all entities. Consult the guidance on accessibility plan deadlines to learn more.

One way is to consult persons with disabilities before writing your progress report. You would ask how they evaluate your progress in implementing your accessibility plan. You would then write your progress report based on the comments they provide.

Another way is to write a draft version of your report first and then consult persons with disabilities on ways to improve it. If you do this, you could ask them questions to determine some or all of the following:

• in which areas they identify progress that your organization has made
• if there are areas of success or continuing work that the progress report has not yet taken into account
• if there are better ways in which your organization can deal with barriers that people have identified for you
• if the report demonstrates that your consultations have been or will be meaningful
• if there are new questions they would like you to ask in future consultations
• if the report is simple, clear and concise
• if the report meaningfully describes and accounts for the feedback you received through your feedback process
• if there is more that your organization should do to improve accessibility

You should allow enough time after the consultation to analyze the information you received. You must also allow time to write the description of how you consulted to include in your report.

Feedback processes versus consultation input

For the purposes of the ACA and its regulations, keep in mind that there is a difference between:

• feedback you receive through your organization’s feedback process
• comments you receive when you consult persons with disabilities

The ACA says you must have a process for receiving and dealing with feedback on:

• how you are implementing your accessibility plan
• barriers that your employees or other persons who deal with your organization encounter

Your progress reports must include a “Feedback” heading. Your reports must provide information about the feedback you received through your feedback process, and about how you have taken it into consideration. Additional guidance on feedback processes will be available in 2022.

The information you receive when consulting persons with disabilities could pertain to many things. It will depend on the questions you choose to ask, and on the answers participants choose to give.

When you publish an accessibility plan or a progress report, it must include a “Consultations” heading. Your plan and report must provide information about how you consulted persons with disabilities in preparing that plan or report. Additional guidance on progress reports will be available in 2022.

Consulting on the areas described in section 5 of the ACA

To help achieve a Canada without barriers on or before January 1st, 2040, federally regulated entities should identify, remove, and prevent barriers in the areas described in section 5 of the ACA:

• 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
• transportation

Some accessibility barriers could fall within more than one of these areas. For example, an inaccessible hiring portal might fall under both employment and ICT.

Remember: your accessibility plans and progress reports must include headings for areas found in section 5 of the ACA. Your accessibility plans must address your policies, programs, practices and services in relation to the identification, removal, and prevention of barriers in these areas. Your progress reports must provide information on how you are implementing your accessibility plans. Which areas you include in your plans and reports, and how you address them, may depend on the regulatory authority to which you report. Consult the guidance subsection on different regulatory and enforcement authorities.

As you consult persons with disabilities, ask for advice on identifying, removing, and preventing barriers in all areas.

Consulting to identify, remove, and prevent barriers

When consulting persons with disabilities about identifying, removing, and preventing barriers, we recommend that you ask questions to determine some or all of the following:

• which barriers in your organization you still need to address
  • physical barriers on your organization’s property or in its physical structures
    • physical barriers make it difficult for someone to move around or interact with an environment, space, or objects; for example:
      • entrances without ramps
      • a sign-in process that requires a hand-written form
      • waiting or rest areas lit by bright, flashing lights
• attitudinal barriers in your organization’s policies, programs, practices and services
  • attitudinal barriers come from how people think about, speak to, or otherwise treat persons with disabilities; for example:
    • employees are not trained about hidden or invisible disabilities
    • managers assume an employee with a disability is less capable, and do not assign them important work or provide advancement opportunities
    • managers and employees pay less attention to clients with disabilities, or treat them with less respect
  • systemic barriers in your organization’s policies, programs, practices, and services
    • systemic barriers persist in an organization’s norms and practices; for example:
      • organization’s website or other publications regularly use images and tables without captions or alt-text
      • administrators make accessibility improvements only in reaction to complaints or requests, rather than proactively
      • organization’s website or other publications do not include images or acknowledgement of persons with disabilities
  • existing barriers that should be your priority for removal
  • potential future barriers that should be your priority for prevention
• how your organization could better understand, identify, remove, and prevent barriers
• if your organization is applying a diverse and intersectional lens to accessibility
• if your organization ensuring that steps taken to remove current barriers do not contribute to new barriers in the future