Further compliance deadlines for federal employers under the Accessible Canada Act (the "Act") are on the docket for 2024.
In 2023, federal employers saw new obligations come into play under the Act, as discussed in a previous insight on the matter. That trend will continue in 2024. In addition, 2024 will bring further obligations for federal employers under the Pay Equity Act and Pay Equity Regulations.
Accessibility plans
In 2023, federal employers with at least 100 employees in the previous calendar year were required to take the following steps to comply with the Act:
- Publish an accessibility plan that describes its policies, programs, practices and services aimed at removing barriers in the above priority areas;
- Develop the plan in consultation with persons with disabilities;
- Make available copies of the plan to the public upon request;
- Update the plan every three years;
- Implement a process for dealing with feedback on the plan and the barriers individuals face when dealing with that organization; and
- Consult with persons with disabilities to publish annual progress reports on the implementation of the plan and the feedback received on the plan.
This year, federal employers with 10-99 employees will be required to do the same, while federal employers who published accessibility plans in compliance with the Act in 2023 will be required to prepare and publish a progress report describing actions they have taken to implement their plan. The accessibility plan and progress reports, as the case may be, must be published by June 1, 2024. This year's progress report will be the first installment of what will be an annual obligation.
Pay Equity plans
In addition to their responsibilities under the Act, this year federal employees will also have obligations under the Pay Equity Act and Pay Equity Regulations. Federal employees with over 10 employees will be required to publish a pay equity plan by September 3, 2024. However, employers must prepare a draft plan for late spring 2024, which is to be posted for at least 60 days to allow for employee feedback to be included in the final plan.
Next steps
If you have any questions about your organization's legal obligations under federal or provincial accessibility legislation, please contact one of the members of our MLT Aikins Labour & Employment group to learn how we can help.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
