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Recommend that the standard be revised to better reflect the diversity of the
organizations to which it applies by:

1. Focusing on outcomes rather than processes.
• Define required accessibility results and guiding principles.
• Allow organizations flexibility in how those results are achieved.
 

Recommend that the standard be revised to better reflect the diversity of the
organizations to which it applies by:

1. Reducing prescriptive “shall” requirements related to procurement mechanics.
• Limit mandatory provisions to accessibility-specific elements.
• Convert process-oriented requirements into guidance (i.e., “should” rather than
“shall”).
2. Allowing integration with existing procurement frameworks.
• Recognize that organizations already have established procurement practices.
• Enable incorporation of accessibility within those frameworks without requiring
redesign.

To support implementation, organizations will need:
• sufficient lead time to communicate the intent of the standard to appropriate internal and external stakeholders, develop supporting materials, train those involved in procurement processes, and communicate more broadly as needed; and
• support from ESDC, including guidance and resource materials to assist with implementation.

A mechanism to resolve conflicts between accessibility standards arising from overlapping legislation should be referenced in the standard or in supporting materials.

The Standard should explicitly acknowledge that jurisdictions may be subject to their own accessibility and procurement requirements. The Standard may also want to suggest that organizations consult their legal counsel to confirm applicable legislative and policy obligations within their jurisdiction.

While the Standard establishes clear expectations, organizations may face challenges implementing accessibility requirements within existing procurement processes.

Accessibility considerations are not always incorporated early in the procurement lifecycle or assessed consistently during bid evaluation, increasing the risk that accessibility issues are identified later in the process, resulting in additional costs, project delays, and compliance risks.

The Standard emphasizes the importance of accessibility but provides limited practical guidance on how organizations should incorporate accessibility requirements. 

Additional implementation supports—such as guidance documents, sample procurement language, one-pagers for vendors, legislative compliance guidance, and digital accessibility tools (e.g., Web Content Accessibility Guidelines).

The Standard should also recognize that accessible solutions may not always be available in the marketplace. 

 

The Standard focuses on federally regulated entities under the Accessible Canada Act (ACA) and suggests that provinces, territories, municipalities, and private and non-profit organizations should be using the same standards.

The Standard may also want to suggest that organizations consult their legal counsel to confirm applicable legislative and policy obligations within their jurisdiction.

Procurement documents do not consistently prompt vendors to demonstrate how accessibility will be incorporated into their proposed solutions and deliverables.

Additional examples, practical guidance, and references to existing standards and resources would help organizations operationalize accessibility requirements more effectively.

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o Recognize the intent to set a standard for federally regulated entities and potentially a benchmark for other jurisdictions. However, it may be worthwhile to acknowledge that provinces, territories, municipalities, private and non-profit sectors may have their own standards (similar to section 3.3).

o Similar to the suggestion for 7.1, Ontario suggests re-emphasizing that organizations are also highly encouraged to confirm the accessibility and procurement requirements that apply to their respective entity and/ or jurisdiction.

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Bidder – Clarify that a “bidder” refers to an entity participating in a specific stage of the procurement process and may subsequently become the “supplier” once a contract is awarded. Consider including a corresponding definition or cross-reference to “supplier” to reflect this transition.

Client – Include a brief example of who may be considered a “client” (e.g., a department, program area, or end user of the procured goods or services).

Goods – Explicitly state that “goods” represent one category within procurement (alongside services and construction)

Procurement professional – Clarify whether all procurement professionals are responsible for entering into contracts or contractual agreements, or whether their roles may vary (e.g., advisory, administrative, or transactional functions).

Service – Consider aligning the definition with “goods” by identifying “services” as another category of procurement, rather than focusing on the method of acquisition.

Construction – If construction is intended to be included within the scope of procurement, it should be explicitly defined, particularly if it is considered a distinct category of procurement (alongside goods and services).

Technology – Consider adding technology as a good or service.

Clarify that accessibility should be considered at the earliest stage.

The intent of “flexibility” could be clarified. Provide clearer wording or examples to help ensure consistent interpretation.

Consider adding a separate provision stating that contractors are required to provide accommodations upon request, to ensure accessibility needs are met regardless of the overall accessibility of the deliverable.

consider changing “discretion” to “judgement”.

This content appears to focus on procedural requirements and may be better positioned toward the end of the Standard or in a dedicated procedural section.

Consider condensing this section or relocating it to an appendix. This would preserve the guidance while ensuring the core Standard remains focused on key accessibility expectations within procurement.

Provide clearer guidance on how accessibility considerations should inform early decision-making, particularly in assessing the cost and value of different procurement options.

Introduce a new subsection (e.g., section 12.4.4) to provide guidance on how clients should integrate accessibility considerations into bid evaluation, in particular in relation to cost.

Consider providing guidance on how to structure requests and evaluation criteria to account for accessibility (e.g., evaluate trade-offs such as considering total cost of ownership, long-term value, accessibility outcomes, and risk).

Reinforce that evaluation criteria should reflect the accessibility requirements and lifecycle cost considerations identified earlier in the process. Specifically, bid evaluation should: -Incorporate total cost of ownership, including remediation, compliance, and long-term accessibility impacts; - Assign meaningful weight to accessibility outcomes, not just upfront price; -Encourage vendors to demonstrate how accessibility is integrated into their solutions.

Where accessible options are available, selection of a less accessible solution should be limited to exceptional circumstances and supported by clear, documented justification that considers full lifecycle costs. This should include a requirement to assess accessibility using a lifecycle approach, taking into account upfront costs and longer-term factors (e.g., remediation, compliance risks, delays, and ongoing maintenance).

Where accessible options are available, selection of a less accessible solution should be limited to exceptional circumstances and supported by clear, documented justification that considers full lifecycle costs. Any decision to select a less accessible option should be limited to exceptional circumstances and supported by robust, well-documented justification that demonstrates consideration of full lifecycle costs and accessibility impacts.