The Canadian Accessibility Standards Development Organization (operating as “Accessibility Standards Canada”) standards are developed through a consensus-based standards development process approved by the Standards Council of Canada. This process brings together volunteers representing varied viewpoints and interests to achieve consensus and develop standards. 

Amendments and errata may have been or may eventually be developed in relation to this edition of the Standard, and published separately. It is the responsibility of the users of this document to verify if any amendments or errata exist.  

This document was developed as a reference document for voluntary use. It is the responsibility of the users to verify if laws or regulations make the application of this Standard mandatory or if trade regulations or market conditions stipulate its use, for example, in technical regulations, inspection plans originating from regulatory authorities, and certification programs. 

Although the primary application of this Standard is stated in its scope, it remains the responsibility of the users of this Standard to judge its suitability for their particular purpose. It is also the responsibility of the users to consider limitations and restrictions specified in the purpose and/or scope of this Standard. 

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Mahadeo Sukhai, researcher, self-employed (Chairperson)

Andrew Livingston, Chief Executive Officer, Dexterity Consulting (Vice Chairperson)

Monique Beaudoin, Consultant (semi-retired)

Norma McCormick, Founder and Principal, Corporate Health Works Incorporated

Don Gallant, National Director, Ready Willing and Able, Inclusion Canada

Emile Tompa, Senior Scientist, Population/Workforce Studies Program, Institute for Work & Health

Gary Malkowski, Director, Sign Language Institute Canada, Canadian Cultural Society of the Deaf, DEAF CULTURE CENTRE

Mark Wafer, Chair, Board of directors, Canadian Hearing Services

Wendy Lau, Chief Executive Officer, Leads Employment Services

Christine Lund, Policy and Program Analyst, Indigenous Services Canada (ISC)

Emmanuelle Lopez-Bastos, Human Rights, Equity and Diversity Coordinator, United Food and Commercial Workers Union

Glen Hayes, Senior Human Resources Advisor, Treasury Board Secretariat

Kelsey Baker, Compensation Consultant, Nova Scotia Education Common Services Bureau

Orelie Di Mavindi, Manager, Opportunities Fund for Persons with Disabilities, Employment and Social Development Canada

Seema Lamba, National Human Rights Officer, Public Service Alliance of Canada

Pamela Lahey (member October 2020-April 2024)

Jamie Burton, Chief Executive Officer, INNoVA

Rachel Desjourdy, Accessibility Lead, CBC/Radio-Canada

Steven Lewis, Manager, Senior Legal Counsel and Accessibility Advisor, Capital One Bank (Canada)

This Standard is based on the seven key phases of the “employment life cycle” and aims to help users of the Standard throughout all phases of the cycle, namely:

1. recruitment;
2. hiring;
3. onboarding;
4. retention;
5. promotion and career development;
6. performance management; and
7. separation.

Productivity to an organization means having performing workers who contribute to the organizational mandate and success. Inclusive employment emphasizes and values diversity and representation in the workforce, leading to more meaningful worker engagement and motivation, and therefore, a more productive and healthier workplace. This Standard examines how organizations identify, prevent, and remove barriers that persons with disabilities encounter within their employment journey. 

Accessibility and disability confidence are crucial for an inclusive workplace, but they should not be viewed in isolation. To create a truly inclusive environment, this Standard promotes integrating accessibility and disability confidence into broader diversity and representation efforts. This ensures that all interconnected elements essential to an inclusive workplace are addressed together.

Note: Disability confidence means an organization being willing and able to effectively manage the diverse spectrum of human needs. It means treating accessibility for persons with disabilities as a business priority by understanding how disability impacts every part of an organization. This is done by identifying and removing barriers and dismantling assumptions about the capabilities and potential of workers with disabilities. Disability confidence entails becoming comfortable and competent in managing a workforce that includes workers with disabilities.

To create a disability-confident workplace, organizations should strive to:

1. recognize the value of individuals with disabilities;
2. create an environment where employees feel comfortable and can choose if they want to disclose their disability;
3. provide training and resources to promote awareness and reduce biases; and
4. require leaders to lead by example and champion inclusion at all levels of the organization.

By embracing disability confidence, organizations can build a more inclusive and equitable workplace for everyone.

A comprehensive, proactive approach is promoted with continual improvement to enable employers to have a high-performing, inclusive labour force such that an employer can be at the forefront of inclusive employment. The concept of continual improvement involves recurring activities to enhance performance over time. Examples of these include the planning, implementation, and evaluation of projects, programs, policies, and practices in the workplace. This Standard is designed to facilitate a proactive and systemic approach where accessibility is embedded within the work environment.

The requirements within this Standard define a framework of systemic change through environmental solutions and policies to facilitate accessibility and inclusion in the workplace (see Clauses 10, 11, and 14):

1. Clause 10 of this Standard focuses on structural support, policy, and leadership in organizations by emphasizing the development of systems, policies, and practices.
2. Clause 11 discusses culture, engagement, and education within the workplace. This clause has been intentionally left blank in this edition of the Standard. The contents of this clause will be added in a future revision.
3. Clause 14 highlights the development and maintenance of an accessibility support system in the workplace. This clause has been intentionally left blank in this edition of the Standard. The contents of this clause will be added in a future revision.

This framework of systemic change is balanced by a person-centred, individualized approach to accessibility and accommodation throughout the employment journey (see Clauses 12 and 13).

• Clause 12 addresses identifying, preventing, and removing barriers encountered during recruitment, hiring, and onboarding.
• Clause 13 addresses the identification, prevention and removal of barriers encountered in worker retention, professional development, pay equity (compensation), performance management and job separation.

Both approaches, taken together, are necessary to achieve a truly inclusive work environment. This Standard demonstrates that both approaches (the systemic approach and the person-centred approach) are required in equal measure (as opposed to one approach predominating over the other).

Informative annexes provide additional information and context on concepts presented within this Standard:

1. Annex A (informative): Background and context;
2. Annex B (informative): Lived experience with disability;
3. Annex C (informative): Continual improvement;
4. Annex D (informative): Intersectional accessibility lens;
5. Annex E (informative): Anti-Ableism policies.
6. Annex F (informative): Stand-alone accessibility policies and accessibility elements integrated into existing policies; and
7. Annex G (informative): Bibliography.

Annex A, B, C, and F have been intentionally left blank in this edition of the Standard. The contents of these annexes will be added in a future revision.

The long-range objective of this Standard is to establish and maintain accessible, inclusive, barrier-free, and discrimination-free employment for all people, including anyone identifying as a person with a disability(ies).

The purpose of this Standard is to provide direction to organizations and other workplace parties in achieving the long-range objective by identifying, preventing, and removing barriers. This allows all persons to participate in employment fully and equitably, including anyone identifying as a person with a disability(ies).

The Standard respects and is complementary to the principles, purpose, and requirements of the Accessible Canada Act. It supports the end goal of achieving accessibility for persons with disabilities. The Standard considers the range of disabilities, the barriers, and any technical and fiscal considerations/impacts that may be associated with their implementation. Further to the principles of the Accessible Canada Act stated in Clause 1, there are additional principles that also apply to this Standard.

The following principles are extracted or adapted from the United Nations’ Convention on Rights of Persons with Disabilities: Article 27 Work and Employment; and the Canadian Human Rights Act:

1. Discrimination on the basis of disability is prohibited for all forms of employment, including conditions of recruitment, hiring, continuance of employment, career advancement, and safe and healthy working conditions.
2. The rights of persons with disabilities to just and favourable conditions of work, including equal opportunities and equal remuneration for work of equal value, safe and healthy working conditions, protection from harassment, and the redress of grievances, are protected, on an equal basis with persons without disabilities.
3. Persons with disabilities are able to exercise their labour and trade union rights on an equal basis with others.
4. Employment opportunities and career advancement are promoted for persons with disabilities in the labour market, as well as assistance in finding, obtaining, maintaining, and returning to employment.
5. Reasonable accommodation is provided in the workplace to persons with disabilities.
6. Persons with disabilities acquire work experience in the labour market.
7. Accessible employment is inclusive of all parts of the employment life cycle and is applicable throughout the work environment, workplace location, and workforce.
8. Intersectional identity is embedded in the development and design of workplace policies, programs, services, and structures.
9. Continual improvement principles are embedded in the development and design of workplace policies, programs, services, and structures.
10. Documents generated by the workplace are written in plain language and produced in an accessible format to ensure that they are readable by everyone.
11. Equitable processes are used to achieve full participation within the workplace for all workers, including those identifying as persons with (a) disability(ies).
12. Proactive approaches to identifying, preventing, and removing barriers for persons with disabilities in the workplace are used in concert with reactive, needs-based approaches to create and maintain accessible, and inclusive workplaces.
13. Accessible employment is in alignment with the principles and actions set out in the Calls to Action contained within the Truth and Reconciliation Commission report (2015).

The primary intended audience of this Standard includes, but is not limited to:

1. employers in federally regulated industries and workplaces listed in the Canadian Human Rights Act and the Accessible Canada Act;
2. third-party contractors in federal jurisdiction;
3. workplace parties;
4. skills training service providers;
5. employment service providers;
6. agencies that receive federal funding to provide service to persons with disabilities; and
7. unions.

“Work” is inclusive of permanent, full-time paid employment contracts, including temporary, casual, part-time, contract, gig, and any work-related activities that are under the control of the organization. Work-integrated learning and apprenticeship opportunities, paid or unpaid, are in scope.

For the purposes of this Standard, the work environment is inclusive of the physical or virtual settings or both, as well as the policies, practices, culture, procedures, resources, technologies, services, and programs in place for any given employer. This Standard addresses all work settings in federally regulated industries and workplaces.

In this Standard, three terms are defined as follows:

1. Shall: Expresses a requirement, or a provision that the user is obliged to satisfy to comply with the Standard.
2. Should: Expresses a recommendation, or that which is advised but not required.
3. May: Expresses an option, or that which is permissible within the limits of the Standard.

Notes accompanying clauses do not include requirements or alternative requirements; the purpose of a note accompanying a clause is to separate from the text explanatory or informative material.

Annexes shall be designated as normative (mandatory) or informative (non-mandatory) to define their application.

This clause establishes the requirement for an employment accessibility strategy with:

1. measurable objectives;
2. supporting policies; 
3. clear roles and responsibilities of the key workplace parties whose support is necessary for an inclusive and accessible employment system; and,
4. evaluation plans.

This clause emphasizes the importance of ensuring that the organization’s policies support accessibility and the inclusion of workers with disabilities. It provides direction for the development and review of organizational policies and identifies policy domains that are essential components of the organization’s policy structure to promote an accessible and inclusive workplace. See Clause 10.5.2 for more details and requirements regarding policy domains.

This clause also requires the organization to identify, remove, and prevent barriers to accessing information and to allocate resources to provide information in accessible formats. This includes the identification, removal, and prevention of barriers to accessibility in existing information technology tools, solutions, and equipment, as well as in those that are newly acquired or deployed. Where a Human Resources Information System or an Applicant Tracking System is used, the organization must identify and establish accessibility criteria to ensure that these systems support the organization’s accessibility objectives.

Finally, this clause identifies the need for emergency preparedness in the workplace by planning, preparing for, and responding to potential emergency situations. It requires the involvement of persons with disabilities in the development of the planned response to a specific emergency situation to ensure that emergency responses meet the needs of all workers, including workers with disabilities.

In the development, implementation, and monitoring of an organizational employment accessibility strategy, the organization shall:

1. develop an employment accessibility strategy with measurable objectives and supporting policies;
2. demonstrate accountability for implementing the employment accessibility strategy and honouring its commitments, including the health and safety of all workers;
3. publish the strategy;
4. monitor progress of this strategy;
5. review and update the strategy based on feedback and suggestions for improvement to accessibility in the workplace every three years; and
6. communicate any updates to the employment accessibility strategy to workers and interested parties annually.

For the employment accessibility strategy to be successful, the organization shall:

1. define and communicate the roles and responsibilities of all internal workplace parties required to support the inclusive and accessible employment system consistent with this Standard (refer to Clause 10.4 for further explanation of the inclusive and accessible employment system);
2. provide workplace parties with the necessary resources to effectively participate in establishing, implementing, maintaining, and continually improving the inclusive and accessible employment system. Such resources include, but are not limited to:
   1. the premises;
   2. equipment;
   3. communication tools; and
   4. work time; and
3. promote dialogue about inclusive employment issues among workplace parties, including persons with disabilities and lived experience, external experts, service providers, and program administrators, while respecting the worker’s right to privacy.

This clause details the roles and responsibilities of key workplace parties in support of inclusive and accessible employment policies, processes, programs, procedures, and practices (herein termed “the inclusive and accessible employment system”). The successful implementation of this Standard requires commitment from all levels and functions of the organization and by workers at all levels. Senior management shall demonstrate this commitment by allocating, in a timely and efficient manner, the financial, human, and material resources required to achieve its employment accessibility strategy and objectives and improve inclusive and accessible employment practices.

10.4.1 Role and responsibilities of senior management

Senior management shall develop, lead, and promote a culture of accessibility and inclusion within the organization by:

1. communicating to all workers on an ongoing basis:
   1. the value of working together to address and innovate accessibility in the workplace; and
   2. the value of ensuring equitable commitment to the Standard to benefit everyone;
2. actively engaging workers (with and without disabilities) in dialogue on all aspects of accessible employment;
3. providing anti-ableism training to reduce the impact of attitudinal barriers;
4. establishing or supporting committee(s) that promote accessibility, anti-ableism, and inclusion;
5. establishing a confidential complaints process;
6. designating one or more neutral representatives who, irrespective of other responsibilities, have defined roles, responsibilities, accountability, and authority to establish, implement, maintain, and continually improve the organization’s confidential complaints process;
7. protecting workers from reprisals when reporting incidents of discrimination based on disability;
8. protecting workers from reprisals when identifying barriers to accessibility;
9. supporting workers to demonstrate leadership in accessibility as it applies to roles and areas of responsibility;
10. implementing this Standard to achieve its intended outcome(s);
11. providing opportunities for confidential worker feedback and suggestions for improvement;
12. measuring, evaluating, and reporting progress toward achieving accessibility objectives to demonstrate continual improvement;
13. facilitating worker representative participation in the development, implementation, maintenance, and continual improvement of the inclusive and accessible employment system consistent with this Standard;
14. encouraging participation of both internal and external interested parties in the development, implementation, maintenance, and continual improvement of the inclusive and accessible employment system consistent with this Standard;
15. ensuring that persons with disabilities are consulted/included in the development, implementation, maintenance, and continual improvement of the organization’s inclusive and accessible employment system;
16. establishing a mechanism for regular reporting to senior management on the performance of the inclusive and accessible employment system, using this feedback to support continual improvement; and
17. including the leadership and implementation of an inclusive and accessible employment system in their performance management objectives.

10.4.2 Role and responsibilities of managers, supervisors, and internal experts

The organization shall ensure that managers, supervisors, and internal experts:

1. support the development, implementation, maintenance, and continual improvement of the organization’s inclusive and accessible employment system, considering the specific role they play within the system. This includes, but is not restricted to:
   1. policy development, implementation, maintenance, and continual improvement;
   2. proactive remediation of known and hidden systemic barriers and unconscious bias;
   3. development of an information system to support the evaluation of its effectiveness if no such system exists;
   4. oversight of day-to-day operational effectiveness;
   5. encouraging disclosure of accommodation needs as appropriate (excluding diagnosis and any non-relevant medical conditions);
   6. ensuring a process is in place for confidential disclosure of disability;
   7. ensuring accommodation plans are up-to-date; and
   8. promoting and supporting good faith in the accommodation process;
2. communicate policies, processes, programs, procedures, and practices for inclusive employment to workplace parties;
3. support workers in navigating inclusive employment policies, processes, programs, procedures, and practices;
4. ensure all workplace parties receive appropriate training for their role and responsibilities within the inclusive and accessible employment system;
5. promote an inclusive culture where workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences;
6. permit workers the time away from their work, as necessary, to contribute to the process of continually improving the inclusive and accessible employment system; and
7. consult with external experts, disability organizations, and persons with disabilities, as needed, to provide expertise on elements of the inclusive and accessible employment system to enhance effectiveness and impact.

10.4.3 The role of an organization in a unionized workplace

The organization shall provide clear, understandable, and relevant information about the inclusive and accessible employment system and consult with union representative(s) on ways to promote a culture of accessibility and inclusion within the organization by encouraging:

1. participation in developing, implementing, maintaining, and continually improving the inclusive and accessible employment system. This includes, but is not restricted to:
   1. participating in meetings with management to ensure the various stages of the inclusive and accessible employment system are collaborative and meet the needs of the workers;
   2. working with management to identify outdated policies and recommend new ones;
   3. ensuring that the inclusive and accessible employment system complements the collective bargaining process and does not contravene negotiated contract language;
   4. negotiating workplace-specific worker protections through the collective bargaining process; and
   5. holding employer representatives accountable for their responsibilities within the inclusive and accessible employment system;
2. promotion of work disability awareness and disability competency within the workplace;
3. promotion of a work environment where reporting or disclosing issues are done in a respectful and supportive manner;
4. support for workers throughout the accommodation process;
5. representation of members as per union responsibilities (as needed or as requested); and
6. promotion of an inclusive culture where workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences.

10.4.4 Worker Role

The organization shall support workers to promote a culture of accessibility and inclusion within the organization by:

1. participating in developing, implementing, maintaining, and continually improving the organization’s inclusive and accessible employment system. This includes, but is not restricted to:
   1. identifying barriers to participation, communicating these barriers through the appropriate channels, and, where appropriate, working to remove and prevent these barriers;
   2. following the policies, processes, programs, procedures, and practices as outlined in the system; and
   3. providing feedback on the effectiveness of the inclusive and accessible employment system;
2. actively engaging in the accommodation process in good faith; and
3. promoting an inclusive culture where all workers feel comfortable disclosing their need for accommodation without fear of reprisal or negative consequences.

Policies reflect the organization’s commitment and intention. Achieving a barrier-free workplace for all requires that the organization’s policies support accessibility and the inclusion of workers with disabilities.

10.5.1 Policy development

The organization shall:

1. review existing policies, including but not limited to the accessibility policy (refer to Clause 10.5.3) and the anti-ableism policy (refer to Annex E), to ensure they are consistent with accessibility objectives;
2. develop policies that facilitate the achievement of these objectives and are compatible with the requirements of this Standard;
3. reflect its commitment and intention to achieve a barrier-free workplace, and support accessibility and inclusion of workers with disabilities in its policies and practices;
4. review and assess policies using an intersectional accessibility lens (see Annex D) to identify policies that create or sustain barriers to the employment of workers with disabilities and revise policies as required; and
5. consult with workers representing diverse disabilities and unions in developing and modifying the organization’s employment policies and practices.

10.5.2 Policy domains

Policy domains are essential components of the organization’s policy structure that shall be present to promote an accessible and inclusive workplace.

The organization shall ensure that its policies address accessibility through the identification, removal, and prevention of barriers in the following policy domains:

1. anti-discrimination (includes anti-ableism);
2. pre-employment (e.g. recruitment, screening, interviewing, assessing, hiring, onboarding);
3. retention, career development, job exit;
4. individual accommodation (e.g. including devices and equipment);
5. performance management;
6. pay equity (see clause 13.5 compensation)
7. individual and organizational training, learning, and development;
8. internal communications, accessible communications, communications support;
9. workplace emergency response; 
10. service persons;
11. support persons;
12. guide dogs and service dogs;
13. procurement; and,
14. maintenance
    1. preventative maintenance; and
    2. cleaning.

10.5.3 Accessibility policy

10.5.3.1 Contents of accessibility policy

The organization shall develop an accessibility policy suitable to its purpose, size, and context that:

1. includes a commitment to providing an accessible workplace by identifying, preventing, and removing barriers to accessibility;
2. provides a framework for setting its accessibility objectives;
3. commits to fulfilling legal requirements and other requirements related to accessibility; and
4. identifies a process for measuring, monitoring, enforcing, and evaluating progress toward achieving accessibility objectives.

10.5.3.2 Development and publication of accessibility policy

The organization shall:

1. encourage the participation of workers and their representatives in the development of an accessibility policy;
2. document the policy; and
3. make it available to workers, communicate it within the organization, and publish it to communicate with the public (see Clause 10.6 item c).

The organization shall identify, remove, and prevent barriers to accessing information by:

1. ensuring there is accountability and resources for producing accessible format materials;
2. ensuring in-house workers or competent contracted external providers or both, can provide internal and external communications in plain language, signed languages, and accessible formatting;
3. planning and creating communication (continuous or temporary) with accessible formats (e.g., large print) and languages (e.g., braille, signed languages, protactile sign language, plain language);
4. maximizing full access by using universal design principles to deliver accessible communications;
5. documenting the process for requesting individualized accessible formats and communicating it to all workers;
6. providing job applicants and prospective workers with the same accessible communication formats offered to current workers;
7. providing information on work opportunities in accessible formats;
8. making digital information retrievable in the requested format by any worker; and
9. providing accessible document storage and archiving platforms.

10.6.1 Accessibility of communications

The organizations shall monitor and improve the accessibility of communications by:

1. designating those responsible for managing requests for accessible formats;
2. establishing a timeline for responding promptly to requests for accessible formats;
3. monitoring requests for accessible formats and the time taken to respond;
4. obtaining worker feedback and providing it to the continual improvement process on an annual basis; and
5. providing electronic communications in a format that meets CAN/ASC - EN 301 549:2024 Accessibility requirements for information and communications technology (ICT) products and services.

Information technology is the use of any computers, storage, networking and other physical devices, infrastructure, and processes to create, process, store, secure, and exchange all forms of electronic data. The commercial use of information technology encompasses both computer technology and telecommunications.

Everyone within the organization who designs, develops, deploys, recommends, procures, or manages electronic equipment and information technology has responsibilities to include accessibility of software and hardware throughout their use in the workplace.

The organization shall:

1. identify, remove, and prevent barriers to accessibility in existing information technology tools, solutions, and equipment;
2. prioritize identifying, preventing, and removing accessibility barriers when acquiring and deploying new information technology tools, solutions, and equipment;
3. integrate accessibility in the lifecycle management process for existing information technology solutions, tools, and equipment, including web content.
4. enable the accessibility features of tools and equipment to support the highest level of accessibility provided by information technology solutions;
5. follow and meet the requirements of CAN/ASC - EN 301 549:2024;
6. make accessibility a priority when acquiring or developing internal and public-facing information technology solutions, tools, and equipment to allow information technology to be useable by all; and

7. determine if products, services, and technology used in, or purchased for the workplace result in accessibility limitations for persons with disabilities.

   Note: Such products, services, and technologies may include but are not limited to:

   1. audiovisual content;
   2. websites;
   3. web applications;
   4. mobile apps;
   5. software; and
   6. kiosks.

10.7.1 Human Resource Information System

A Human Resource Information System is a software solution that maintains, manages, and processes detailed worker information and human resources-related policies and procedures.

The organization shall:

1. identify and establish accessibility criteria that support its accessibility objectives, in selecting a new Human Resource Information System; and
2. review and assess any existing Human Resource Information System using accessibility criteria to identify, remove, and prevent barriers to employment for workers with disabilities.

Note: A Human Resource Information System may be used as part of a Human Resource Management System.

This clause focuses on the first phase of the employment life cycle. It emphasizes the recruitment, hiring, and onboarding of workers, or prospective workers, with disabilities. When the recruitment process is fully accessible, it enables organizations to diversify the workplace, reach qualified applicants, and reduce the likelihood of discrimination. The principle of non-discrimination is to be respected throughout the recruitment and hiring process, to ensure maximal benefit to the organization and equitable opportunities for workers with and without disabilities.

12.2.1 Commitment statement

The organization shall:

1. develop a statement of commitment to accessibility, equity, and inclusion in recruitment procedures and job advertisements;
2. post its statement of commitment publicly and make it accessible to all applicants;
3. invite applications from underrepresented groups, including persons with disabilities; and
4. provide accommodations at no cost to applicants throughout every stage of the process (including recruitment, selection, and assessment, where applicable) to ensure full and equal participation.

12.2.2 Candidate recruitment process

The organization shall:

1. develop recruitment processes and advertising practices to attract applications from as many qualified people as possible;
2. publicize job vacancies in formats accessible to persons with disabilities, and consult with employment services for disabled persons or other relevant agencies to obtain feedback on an as-needed basis;
3. encourage candidates to identify any accommodations required throughout the recruitment process;
4. provide or arrange for suitable accommodation considering the candidate’s accessibility needs;
5. maintain privacy with respect to disclosure and the reason for it when a candidate self-identifies;
6. inform workers and the public of the accommodations available to candidates in its recruitment processes; and
7. provide all recruitment materials in an accessible format.

Note: As technology is updated periodically, accessibility present in earlier versions may be lost in later versions. Materials would need to be regularly reviewed and updated as technology advances.

12.2.3 Applicant Tracking Systems and Artificial Intelligence 

Organizations shall implement the following Applicant Tracking System and Artificial Intelligence requirements in conjunction with Clause 12 of this Standard.

Note: Where the organization uses an Applicant Tracking System or other Artificial Intelligence for job candidate recruitment, screening, and hiring, compliance with anti-discrimination legislation is required under the Canadian Human Rights Act. This demonstrates that the selection criteria of any hiring assessment tools are job-related, consistent with business necessity, and do not systemically disadvantage members of employment equity groups.

Where the organization uses an Applicant Tracking System or other Artificial Intelligence for job candidate recruitment, screening and hiring, the organization shall:

1. ensure that Applicant Tracking Systems and Artificial Intelligence screen applicants for bona fide occupational requirements as defined in Clause 8 of this Standard;

   Note: This requirement enables employers to test a worker's relevant skills or abilities, rather than appraising a person's potentially impaired sensory, manual, or speaking skills.

2. take reasonable steps to demonstrate the Artificial Intelligence or the Applicant Tracking System is not discriminatory, by:
   1. producing and making public evidence that they have required suppliers to demonstrate they have taken reasonable steps to make sure their products are not discriminatory to candidates with disabilities;
   2. routinely and regularly utilizing the following indicators of acceptable practice for Applicant Tracking Systems and Artificial Intelligence systems to remove bias in the hiring process, by:
      1. explaining to candidates if Artificial Intelligence is being used as part of the process, how they will be evaluated, and what protections are in place to ensure the use of the Artificial Intelligence is unbiased;
      2. telling candidates whether supplemental assessment tools as part of the Artificial Intelligence screening are accessible to persons with disabilities;
      3. providing clear guidelines on how to request accommodation; and
      4. ensuring every candidate is treated equitably when requesting accommodation, without prejudice, reprisal, or discrimination, and ensuring accommodations are delivered in a non-stigmatizing manner;
3. take steps to prioritize the mitigation of Artificial Intelligence bias, even when utilizing third-party tools, and
4. ensure that there are mechanisms for ongoing analysis of the Artificial Intelligence data and algorithms shared for fairness.

Note: Companies and organizations can increase transparency on how their Artificial Intelligence systems work and arrive at decisions while also participating in revisions by allowing code audits.

The organization shall ensure that external Artificial Intelligence hiring tools used to conduct screening and evaluation have been programmed and implemented with a data set that includes not only persons with disabilities but diversity within disabilities.

12.2.4 Job postings

The organization shall develop job postings that:

1. ensure inclusivity and do not exclude persons with disabilities;
2. list the job requirements for the position that have been reviewed and confirmed to be accurate by human resources and the hiring manager;
3. encourage candidates with different abilities, relevant alternative expertise or experience who can perform the essential and critical job functions, with or without support(s);
4. indicate the option, where appropriate, to provide a portfolio or work samples as an alternative to written descriptions of skills and experiences;
5. identify only bona fide occupational requirements that form part of the selection criteria, where such bona fide occupational requirements exist for the position; 
6. make the organization's accommodation policies available to applicants; 
7. identify a contact person who is aware of the organization’s commitment statement and who will answer questions about the essential job requirements;
8. frame requirements to highlight desired skills or outcomes rather than specific, potentially exclusionary, capabilities;
9. provide the contact details of the organization's representative managing the job posting;
10. describe the work environment, where relevant, in relation to accessibility considerations, including but not limited to office layout, scent policies, noise level, lighting, and workstation setup, to help applicants visualize the workspace; and
11. outline the subsequent stages of the recruitment process.

12.2.5 Job application process

The organization shall provide accessible job application processes by:

1. requiring the use of plain language for questions and to identify job requirements;
2. accepting candidate’s materials in alternate formats;
3. clearly identifying mandatory response fields and those that are optional;
4. identifying fields for which candidates can provide additional related information;
5. scheduling communication with candidates in advance to provide more time to process and respond to pre-screening questions;
6. informing candidates if they will be tested to demonstrate their ability to perform actual or simulated tasks and providing a description of the test format in advance, along with a notice that accommodations are available upon request;
7. focusing pre-employment tests and selection criteria on the specific skills, knowledge, and abilities that are essential to the position so that they do not inadvertently exclude persons with disabilities;
8. removing consideration of length of time to complete education from evaluation criteria in assessing an application;
9. assessing the candidate’s ability to do the job based on the required soft skills and attitude and not exclusively the outcome of a competence test; 
10. permitting alternatives to references, if used during the assessment process; and
11. identifying how an interested person can request support in completing the application at any time in the process.

The organization shall enable candidates to participate and perform in interviews and assessment processes on an equitable and inclusive basis by:

1. providing interviewers and assessors with disability awareness coaching and training, inclusive of how to relate appropriately with persons with disabilities in a disability-confident manner;
2. providing information on getting to the interview location, including but not limited to accessible parking options, accessible transit options and building accessibility features; 
3. providing information about relevant policies and protocols, including but not limited to chemical sensitivity policies and guide dog and service dog policies;
4. inviting the candidate to specify, in advance, any accessibility considerations for the location of the interview;
5. where virtual interviews are deemed appropriate, providing instructions regarding the preferred platform, means of access and usage, and any accessibility-related considerations;
6. providing candidates with an accessible format text copy of any oral interview instructions and questions;
7. providing an estimate of interview duration and expected end time to assist with facilitating transportation arrangements; and
8. encouraging candidates to self-identify any assistance or supports needed during the interview/selection process without asking about the exact nature of their disability, for example, by permitting a sign language interpreter, an advocate, or a support person to be present at an interview.

12.3.1 Interview panels

The organization shall remove barriers by:

1. establishing an interview panel of members with required training in diversity, equity, and inclusion, including at least one from the requesting team familiar with the role to be filled; and
2. providing interview panel members with guidance on making the interview and selection process accessible for all applicants.

12.3.2 Interview questions

The organization shall remove barriers by:

1. developing an interview scoring grid that reflects the job criteria and skills being assessed in an equitable, objective, and methodical process; 
2. scoring the responses consistently across all candidates in a way that mitigates the effect of biases;
3. focusing the development of the interview questions on determining how a candidate will:
   1. apply their skills to perform job tasks and core competencies; and
   2. apply their ability to perform specific job functions;
4. asking only questions that do not require a candidate to disclose a disability directly or indirectly, or discuss the use of assistive aids (guide dogs/service dogs/persons/equipment) or technologies, unless the question is related to fulfilling a bona fide occupational requirement;
5. assessing interpersonal skills as related to job requirements or the functions of the role and to promote an inclusive culture; and
6. preventing disqualification of candidates because they are unable to perform non-essential job functions.

Note: non-essential job functions are tasks or duties that are not bona fide occupational requirements. These tasks/duties can often be reassigned or removed without significantly affecting the job's core responsibilities or the overall business operation.

The organization shall:

1. notify the successful applicant of its current policies for accommodating workers when making offers of employment;
2. notify the successful applicant that tailored accommodations for their specific disability-related needs are available; and
3. ensure that the successful applicant receives pay equity (equal pay of equal value) commensurate with the job roles and responsibilities and is paid no less than minimum wage.

For each new worker, the organization shall:

1. provide an orientation that includes an introduction to the organization, familiarization with the work environment and job duties, and addresses specific individual accessibility requirements;
2. provide policies related to accommodations;
3. identify a support person, mentor, service provider, or “go-to” person who will assist in the onboarding process;
4. confirm that evaluation of the worker during the probationary period begins once accommodations have been provided;
5. communicate information essential to the job and workplace (including but not limited to job instructions, work manuals, information on staff rules, grievance procedures, and health and safety procedures) in accessible format(s);
6. confirm that the format(s) identified in e) meets the needs of the worker(s) (refer to Clause 10.6);
7. consult with the worker to understand their needs and whether additional accommodations are necessary before implementing any change(s);
8. provide the worker with the time and tools necessary to formulate their individualized accommodation request(s); and
9. provide a process for the worker to communicate to the employer the accommodations needed.

The organization shall:

1. provide all workers with training on disability awareness, equity, and inclusion;
2. provide follow-up services to promptly identify and resolve problems for the benefit of the organization and the new worker;
3. review and update accommodations if required following completion of orientation and onboarding; and
4. in cases where an accommodation cannot be provided directly by the employer and necessitates engaging a service provider, consult with the individual to consider their preferences in the selection of the service provider. 

This clause speaks to policies and practices that strengthen job retention and career advancement for all workers, with a focus on workers with disabilities. It details responsibilities for creating an accessible work environment that will:

1. foster the continued employment of workers;
2. provide workers with equitable training and promotion opportunities; and
3. ensure workers receive compensation based on merit.

In addition, this clause details senior management’s responsibility for providing accommodations that will not disadvantage workers with disabilities. This clause also provides senior management with direction on job exits, emphasizing learning job retention strategies during this part of the employment journey.

The organization shall support the retention of all workers, including persons with disabilities, and provide incentives to remain with the organization by:

1. providing updated information on changes to policies for job accommodations that impact a worker’s accessibility needs; and
2. providing a simple, inclusive, equitable, universally applicable, and dignified way for every individual, regardless of their specific needs or circumstances, to request accommodation at any stage of the employment lifecycle.

The organization should support retention by:

3. designing human resource policies and practices that maintain and improve the representation of persons with disabilities at all levels of the organization, from leadership to entry-level;
4. setting and communicating representation targets against workforce availability that is consistent with the retention rate and targets for the organization, and not related to attrition; and
5. reviewing these policies and practices at least once every three years in consultation with persons with disabilities to identify, remove and prevent barriers to retention.

The organization shall:

1. encourage the promotion of persons with disabilities into jobs at a higher organizational level, responsibility or pay based on merit, equity, and seniority;
2. consider seniority alongside merit to safeguard against the sole use of personal judgment to grant or deny a promotion;
3. provide career development support to enhance skills and experience and gain recognition through training, education, leadership, speaking engagements, and other opportunities;
4. remove barriers inherent in criteria for career development and promotional opportunities by using an intersectional accessibility lens;
5. provide support to workers with disabilities through individual accommodation plans as required for success to advance within the organization; and
6. measure the representation of persons with disabilities in the organization’s promotion and career development initiatives.

Note: Refer to Clause 12 for requirements applicable to promotions that require an internal application and interview process.

13.3.1 Redeployment

The organization should:

1. identify the need for a redeployment policy to facilitate continuing employment if a specific position is eliminated, or an entire team has transitioned or been outsourced; and
2. facilitate the reassignment of workers to other teams or functions as an alternative to laying them off.

13.3.2 Redeployment policy

Where organizations have a redeployment policy, the policy shall:

1. provide for employment stability by identifying opportunities for re-employment;
2. apply to all workers, with specific reference to persons with disabilities;
3. consider individual accommodation needs or plans; and
4. include consultation with the workers or the worker representatives or both, upon request.

The organization should use a performance management system to facilitate worker success when assessing and improving worker performance, productivity, and effectiveness by:

1. ensuring that the performance management process is accessible and inclusive to all, including workers with disabilities;
2. adjusting accommodations as requested by the worker or their representative, or both;
3. providing accommodations before assessing the worker’s performance and productivity level;
4. putting mitigation factors in place if the performance discussion reveals a potential need for accommodation so that the worker with a disability is not faulted negatively;
5. applying the performance management process in an equitable manner across the organization for all workers, including workers with disabilities;
6. supporting the movement of an accommodation(s) to a new role or area, including the worker’s accommodation plan, as appropriate, to make the transition as seamless a process as possible; and
7. identifying and addressing repercussions or negative consequences to a worker resulting from the organization’s delay or failure to provide an accommodation or failure to respond to an accommodation request.

The organization shall:

1. apply objective criteria to prevent and eliminate compensation discrepancies between persons with disabilities and other workers with the same responsibilities and job functions;
2. apply the equal wages provision as set out in the Canadian Human Rights act in such a way as to apply to workers with disabilities; and
3. pay their workers no less than minimum wage.

The organization shall:

1. ensure that job exit policies and procedures are accessible and equitable;
2. provide job exit policies and procedures in an accessible format;
3. apply these policies and procedures equally to workers with and without disabilities;
4. use job exit information to identify trends and opportunities to improve the retention of workers with disabilities;
5. report aggregate information of all job exits of workers with disabilities to senior management; and
6. request a statement from persons with disabilities on unresolved and removed barriers faced during their employment tenure.

The concept of intersectionality was coined by American legal and critical race expert Kimberlé Crenshaw in the late 1980s to explain how race intersects with gender to produce unique barriers for Black women not faced by White women or Black men.

An intersectional accessibility lens is the analytical framework that starts with/centres experiences of persons with (a) disability(ies). This analytical framework is used to examine the complex, cumulative ways multiple forms of discrimination and oppression overlap, interact, or intersect.

The following are the core components of an intersectional accessibility lens:

1. Various grounds of discrimination that may be included in an intersectional analysis may include, but are not limited to:
   1. Ableism;
   2. Racism;
   3. Sexism;
   4. Homophobia;
   5. Transphobia;
   6. Classism; and
   7. Ageism, etc.
2. Cumulative effects of these diverse types of discrimination produce a unique and distinct form of discrimination and oppression, which may otherwise not be clear and is different from each separate grounds of discrimination.
3. Intersectionality is not only about identity. It also considers the historical, social, and political context underlying systemic inequities and institutions and the power relationships that shape and affect the experiences of individuals and communities. This results in excluding some people and privileging others. For example:
   1. A racialized woman with a disability will experience oppression differently than a non-racialized man with a disability. In addition to ableism, a racialized woman with a disability also experiences racism and sexism, while a non-racialized man with a disability might experience ableism but have white male privilege.
   2. A blind transgender woman with a learning disability will experience oppression differently than an Indigenous woman with a mobility disability. A blind transgender woman with a learning disability will experience multiple forms of ableism and transphobia, while the Indigenous woman with a mobility disability will experience ableism and racism.
4. The identification, removal, and prevention of barriers considers both the environment and an individual's identity(ies).

At the individual and organizational level, the organization can:

1. Become more aware of accessibility issues and better understand inequities in the workplace for persons with disabilities with multiple identities, from accessing the workplace and in the workplace.
2. Have an inclusive, positive, and respectful work environment.
3. Identify how initiatives could be tailored to be inclusive of persons with disabilities.
4. Incorporate diverse perspectives of persons with disabilities to strengthen the capacity of work teams.
5. Recruit and retain workers who are representative of the communities.
6. Develop and provide better results in services and programs that are responsive to all clients and communities.
7. Identify and address systemic barriers and inequities in accessing and benefitting from the initiative.

Adopted from:  City of Ottawa and City for All Women Initiative, “Equity and Inclusion Lens Handbook.” Version 2018. Expanded from page 6.

Adopted from: Introduction to GBA Plus - Women and Gender Equality Canada.

Questions to ask at outset:

1. How does each element or stage (development, implementation, monitoring, and evaluation) of an initiative, policy, program, procedure, process, or service affect persons with disabilities in general? As a manager? As a worker?
2. Next, how does it affect diverse disabilities and diverse identities, such as for:
   1. Persons with multiple disabilities?
   2. Women with disabilities?
   3. Indigenous persons with disabilities? (First Nations, Inuit, Metis)
   4. Racialized persons with disabilities? (Black, South Asian, Chinese, etc.)
   5. 2SLGBTQI+ persons with disabilities?
   6. Muslims and other religious minorities with disabilities?
   7. Etc.
3. Taking a whole person approach which enables full and equitable participation of all workers by examining answers to the following questions:
   1. Are diverse disabilities and diverse identities represented and involved throughout all processes from planning to implementation, including in the decision-making process?
   2. What could be contributing to that exclusion?
   3. Who is important to be brought into the process in a meaningful way?
4. In asking these questions, do my experiences, biases, and assumptions limit my understanding of the impact on persons with disabilities in general and specifically persons with multiple disabilities and diverse identities?

Recognizing that an anti-ableism policy is distinct from an accessibility policy (refer to Clause 10.5.3), the goals of an anti-ableism policy are to: 

1. Ensure that organizational practices, systems, and communications do not reflect or perpetuate ableist exclusionary practices that may directly or indirectly promote, sustain, or entrench discrimination.
2. Establish and maintain hiring, promotion, and work-related policies that will build and support an inclusive employment environment where these individuals participate and contribute fully.
3. Ensure that services are provided in a fully respectful manner that addresses and removes any barriers to service and the workplace, including ableist practices and attitudes.
4. Meet the requirements of the Canadian Human Rights Act and the Accessible Canada Act.

By contrast, an accommodation policy is one that outlines the accessibility supports process. Its purpose is to outline for the organization their approach to addressing individual needs.

Ableism is discrimination and prejudice rooted in pathological thinking and attitude. This results in a negative stigma towards diverse persons with disabilities based solely on their abilities and attitudes in society that devalue and limit the potential of persons with disabilities. A set of practices and beliefs that assign inferior value (worth) to persons with disabilities.

Ableism refers to a belief system, similar to racism and other forms of discrimination, that sees persons with disabilities as being less worthy of respect and consideration, less able to contribute and participate, or of less inherent value than others. Perceived limitations on an individual’s ability to perform an activity may stem from permanent or temporary disability(ies), or disability(ies) that occur at various points in one’s life. Stigma towards persons with disabilities limits their potential and opportunities when societal attitudes devalue their abilities.

Ableism may be conscious or unconscious, may exist in individuals or be systemic, embedded in institutions or the broader culture of a society. Stereotyping, prejudice, stigma, and discrimination surrounding disability are interconnected. One can lead to the other, such as when stereotyping and prejudice result in stigma, which in turn could lead to discrimination and reduce a person’s full inclusion in communities. 

Ableism is the discrimination of and social prejudice against persons with disabilities based on the belief that typical abilities are superior. At its heart, ableism is rooted in the false assumption that disabled people require “fixing” and defines people by their disability.

Examples of ableism range from blatant hostility and aggression to less obvious everyday interactions and microaggressions. Some examples of these include but are not limited to:

1. asking someone what is “wrong” with them.
2. saying, “you do not look disabled,” as though this is a compliment.
3. viewing a person with a disability as inspirational for doing typical things, such as having a career.
4. assuming a physical disability is a product of laziness or lack of exercise.
5. using public facilities that are for persons with disabilities, such as parking spaces or toilets; and
6. questioning whether a person’s disability is real.

Employers may be biased against those with disabilities, believing they make less productive workers. They may also refuse disability accommodations to existing workers or allow workplace bullying to go unpunished.

When communicating about disability, some ways of avoiding casual ableism include but are not limited to:

1. learning from individuals with disabilities by listening when they share their lived experience;
2. focusing on abilities, not limitations;
3. remembering that people come first;
4. asking about an individual's language preferences;
5. using neutral language;
6. emphasizing the need for accessibility, not the presence of a disability; and
7. avoiding condescending euphemisms.