What Federally Regulated Employers Need to Publish in 2026
As federally regulated employers continue navigating compliance under the Accessible Canada Act (ACA), 2026 marks an important transition point in the reporting cycle.
Depending on the size of your organization, your obligations this year may include:
- Publishing an updated accessibility plan;
- submitting a progress report;
- or, reviewing the accessibility barriers and initiatives identified in previous reporting cycles.
And while accessibility reporting may now feel more familiar than it did in 2023 or 2024, the expectations around transparency, accountability, and measurable progress continue to evolve.
If your organization published a progress report in 2025, your next requirement may not be another report. For some employers, 2026 is the year to revisit and update their full accessibility plan.
For more background on prior reporting obligations, read our breakdown of 2025 accessibility progress report requirements for federally regulated employers.
What Accessibility Document Is Required in 2026?
Your organization’s obligations under the Accessible Canada Act depend on the average number of employees your organization has.
| Organization Size | 2026 Requirement | Deadline |
| 100+ employees | Updated Accessibility Plan | June 1, 2026 |
| 10–99 employees | Progress Report | June 1, 2026 |
| Fewer than 10 employees | Generally exempt | N/A |
Why Some Employers Need Updated Accessibility Plans in 2026
Under the Accessible Canada Regulations, federally regulated employers must:
- publish accessibility plans every three years
- publish progress reports in the years between updated plans
For large federally regulated private-sector organizations (100+ employees), the reporting cycle looks like this:
- June 1, 2023: Initial Accessibility Plan
- June 1, 2024: Progress Report
- June 1, 2025: Progress Report
- June 1, 2026: Updated Accessibility Plan
For smaller federally regulated private-sector organizations (10–99 employees), the cycle is slightly delayed:
- June 1, 2024: Initial Accessibility Plan
- June 1, 2025: Progress Report
- June 1, 2026: Progress Report
- June 1, 2027: Updated Accessibility Plan
This means organizations are no longer all at the same stage of compliance. While some employers are preparing another annual progress report, others are expected to revisit, revise, and republish their broader accessibility strategy.
What Employers Should Revisit Before Publishing in 2026
Whether your organization is preparing a progress report or an updated accessibility plan, 2026 is a good opportunity to reassess the accessibility barriers, commitments, and initiatives identified in previous years.
Areas employers may want to revisit include:
- feedback received through accessibility feedback processes
- recruitment and accommodation practices
- digital accessibility and website accessibility updates
- consultation with employees or applicants with disabilities
- workplace communication practices
- accessibility barriers that remain unresolved
- measurable progress made since previous reporting cycles
Updated accessibility plans should reflect more than repeated commitments. They should demonstrate how your organization’s accessibility efforts have evolved over time and where additional work is still needed.
Common Accessibility Reporting Mistakes Employers Should Avoid
As organizations move further into recurring ACA compliance cycles, some common issues continue to appear in accessibility plans and progress reports.
- Repeating Previous Content Without Meaningful Updates
Accessibility plans and progress reports should reflect current initiatives, progress, and ongoing barriers, not simply restate previous commitments. - Failing to Show Measurable Progress
Employers should clearly explain: what actions were taken, what barriers were addressed, what improvements were made, where challenges remain. - Overlooking Employee Feedback
The Accessible Canada Act places significant emphasis on feedback and consultation. Employers should be prepared to explain how accessibility feedback was reviewed and considered. - Publishing Inaccessible Documents
Accessibility plans and progress reports themselves must be accessible. Employers should ensure documents meet accessibility standards and can be accessed by all users. - Waiting Until the Deadline to Begin Planning
Accessibility reporting often requires coordination across HR, leadership, operations, communications, and IT teams. Starting early can help organizations gather more meaningful updates and feedback.
Accessibility Reporting Is Becoming More Strategic
While accessibility reporting began as a compliance requirement for many employers, organizations are increasingly recognizing its broader impact on:
- employee experience
- inclusive hiring practices
- employer brand
- retention and engagement
- workplace culture
- accessibility governance
As reporting cycles mature, accessibility planning is becoming less about annual reporting obligations and more about building sustainable, inclusive workplace practices over time.
Need a Refresher on ACA Employer Obligations?
Download our guide: Accessible Canada Act Summary for Employers
Frequently Asked Questions About Accessible Canada Act Reporting in 2026
No. Some organizations are required to publish updated accessibility plans instead. Requirements depend on organization size and where the organization falls within the ACA reporting cycle.
For many federally regulated private-sector organizations, the deadline is June 1, 2026.
Under the Accessible Canada Act, accessibility plans must be updated every three years. Progress reports are published in the years between updated plans.
No. Under the Accessible Canada Act, organizations must continue making previous accessibility plans and progress reports publicly available for seven years. When publishing an updated accessibility plan, employers should keep earlier plans and historical progress reports accessible on their website alongside the new version.
Generally, yes. Most federally regulated private-sector organizations with fewer than 10 employees are exempt from ACA accessibility planning and reporting obligations.
Additional Accessible Canada Act Resources
Looking for more guidance on ACA compliance and accessibility reporting requirements? Explore our employer-focused resource for a clear overview of Accessible Canada Act obligations, reporting expectations, and compliance best practices.