Compliance officers often assume they're ready for Canada's Digital Technologies Accessibility Regulations under the Accessible Canada Act. They've got a plan and an owner assigned, so they think they're set for the December 2027 and 2028 deadlines.
But when I ask for their conformity assessment, procurement language, or training records, the conversation changes quickly.
These myths persist because accessibility compliance has historically focused on intent, publishing a plan, identifying barriers, and committing to improvement. The new ACA requirements shift the focus to execution and proof. You must produce technical evidence, maintain current records, and publish your gap list annually. Last year, the Accessibility Commissioner found 95 organizations non-compliant, mostly due to documentation and follow-through, not bad faith.
Here's what compliance officers often misunderstand, and what the regulations actually require.
Myth 1: "We tested our site, so we're compliant"
Reality: You need a conformity assessment with gap analysis that you can produce on demand, and it expires.
The regulations require conformance to CAN/ASC-EN 301 549, which includes WCAG 2.1 Level AA for web content. An automated scan isn't a conformity assessment. Neither is a developer's spot-check or a single-page audit.
You must retain the assessment in electronic form for four years after completion. If your last assessment is from 2023, it won't satisfy a 2028 compliance review. If you can't connect each barrier in your accessibility statement to a specific finding in your assessment, you lack the evidence the Commissioner expects.
Ask your team which properties have a current, documented gap analysis. If the answer is "we ran an automated tool last quarter," you're not ready.
Myth 2: "Our vendor said their product is accessible"
Reality: You must obtain a conformity assessment with gap analysis as part of procurement, not just ask a question.
For federal public sector entities and businesses with 500 or more employees, this rule applies when you buy products or services for a website or app you're responsible for. Starting December 5, 2028, you must obtain an accessibility conformity assessment with gap analysis during procurement.
A vendor questionnaire doesn't satisfy this requirement. Neither does a vendor's Accessibility Conformance Report on its own, an ACR states what the vendor tested, but a gap analysis identifies where the product falls short and what barriers remain.
The Accessibility Commissioner's 2025-2026 Annual Report made this clear: "Put formal measures in place that require your vendors and third-party providers to meet or exceed your accessibility standards."
The regulation doesn't obligate your vendors to hand you an assessment. Your contract language does. If your procurement templates don't include this requirement, start revising them now. Procurement templates take months to change and even longer to become standard practice across your organization.
Myth 3: "We identified barriers in our plan, so we're making progress"
Reality: Every barrier must connect to a specific action, current status, and owner.
The Commissioner has flagged this gap for two years: organizations identify barriers but don't demonstrate what they did about them. If a reader can't follow a specific barrier to the specific work that addressed it and understand where things stand now, there's no verifiable progress.
Your accessibility statement lists where your digital properties fall short. Your progress reports describe what you've been fixing. Both are public, and they need to tell the same story. If the barriers in one don't match the gaps in the other, anyone reviewing them will notice.
Go through every barrier in your plan and answer three questions: What did we do about this one? Where does it stand today? Who owns the work that remains? If you can't answer all three, you don't have a compliance-ready record.
Myth 4: "We'll train everyone before the deadline"
Reality: Training must be completed by the deadline, records must be kept for four years, and refreshers come due every three years.
For federal public sector organizations and federally regulated businesses with 100 or more employees, everyone involved in building, maintaining, or buying technology must complete accessibility training by December 5, 2027. For businesses with 100 or more employees subject to web page requirements, that deadline is December 5, 2028.
The regulation requires refresher training Assistive Technology least every three years. You must keep an electronic record of all training activities for four years. This isn't a one-time milestone, it's an ongoing obligation.
You need to produce a dated training record for every relevant employee on any given day. That includes the developer who joined last month and the procurement officer who almost slipped through the cracks. Take two questions to HR and engineering: Who needs to be on the list? How will you produce a dated training record for each of them?
Myth 5: "Once we're compliant, we're done"
Reality: Every required record expires, and you can become non-compliant without changing a thing.
Assessments go stale. Training refreshers come due every three years. Accessibility statements need republishing every year. Plans and progress reports must stay posted for seven years.
You could satisfy all five documentation requirements in 2027 and find yourself non-compliant in 2029 without changing anything. That's the case for governance, and it's not just a compliance case, it's a cost case.
Organizations without governance pay for accessibility over and over. Every deadline is a scramble. Every audit is a surprise. Every release ships defects that a component library would have prevented, and those defects get found late, by a customer or a regulator, when they're most expensive to fix.
Organizations with governance pay once and get compounding returns. Fix a pattern in your design system, and every page built on it inherits the fix. Put conformance criteria in your procurement template, and the market absorbs the work. Train the people who write and build, and new defects stop entering your pipeline.
What to do instead
Build a governance framework that treats accessibility as an operational requirement, not a project. That means:
- Scheduling conformity assessments on a defined cadence, not waiting until a deadline forces your hand
- Embedding accessibility requirements in procurement templates now, so every new contract includes gap analysis obligations
- Connecting every identified barrier to a named owner, a specific remediation action, and a current status
- Treating training as a rolling program with automated tracking, not a one-time event
- Publishing your accessibility statement as a living document that reflects your actual conformance posture, not your aspirations
The ACA's new requirements focus on documented evidence, current records, and public accountability. If you can't produce the proof, you're not compliant.
