CAN-ASC-6.2:2025- Accessible and Equitable Artificial Intelligence Systems
11. Equitable AI
Information
Table of contents
Technical committee members
- Lisa Snider, Senior Digital Accessibility Consultant and Trainer, Access Changes Everything Inc.
- Nancy McLaughlin, Senior Policy Advisor on Accessibility, Canadian Radio-television and Telecommunications Commission
- John Willis, Senior Program Advisor, OPS Accessibility Office, Centre of Excellence for Human Rights.
- Jutta Treviranus (Chairperson), Director of the Inclusive Design Research Centre and Professor, OCAD University
- Alison Paprica, Professor (adjunct) and senior fellow, Institute for Health Policy, Management and Evaluation, University of Toronto
- Gary Birch, Executive Director, Neil Squire Society
- Lisa Liskovoi, Senior Inclusive Designer and Digital Accessibility Specialist, Inclusive Design Research Centre, OCAD University
- Clayton Lewis, Professor, University of Colorado
- Julia Stoyanovich, Associate Professor and Director, Tandon School of Engineering, New York University
- Anne Jackson, Professor, Seneca College
- Kave Noori, Artificial Intelligence Policy Officer, European Disability Forum
- Mia Ahlgren, Human Rights and Disability Policy Officer, Swedish Disability Rights Federation
- Sambhavi Chandrashekar (Vice-Chairperson), Global Accessibility Lead, D2L Corporation
- Julianna Rowsell, Senior Product Manager, Product Equity, Adobe
- Kate Kalcevich, Head of Accessibility Innovation, Fable
- Saeid Molladavoudi, Senior Data Science Advisor, Statistics Canada
- Merve Hickok, Founder, President and Research Director, Alethicist.org, Center for AI and Digital Policy, University of Michigan
Resources
Trust Meter Technical Specification – Version 1
The Trust Meter Technical Specification is a resource designed to support organizations in implementing ASC-6.2 – Accessible and Equitable Artificial Intelligence Systems. This resource was developed by the Inclusive Design Research Centre (IDRC).
The Trust Meter helps people who implement Artificial Intelligence (AI) systems identify and reduce the risk of inaccurate or unfair outcomes. It focuses on situations where individuals or small groups may be treated differently because the data used to train an AI system does not represent them well.
Training data is the information used to teach an AI tool how to make predictions, recognize patterns or generate content.
The Trust Meter can help organizations:
- understand and address gaps or limitations in training data
- build an AI system that is more transparent
- include strategies to monitor how AI systems perform and make sure people can step in when needed
These practices can contribute to more reliable, accurate, and fair outcomes, particularly for people who may not be well represented in training data.
Access the Trust Meter Technical Specification project on the IDRC website.
Accessibility Standards Canada is not responsible for the content of the Trust Meter.
When AI systems make decisions about, or otherwise impact, people with disabilities, those decisions and uses of AI systems shall result in equitable treatment of and outcomes for people with disabilities.
Note: Doing so will result in benefits to individuals and population groups, as well as to society at large, by helping ensure that all individuals are able to lead productive lives and contribute to society.
Principles: Equitable treatment requires that people with disabilities:
- experience equitable benefits from AI systems;
- do not experience inequitable harms from AI systems;
- do not experience a loss of rights and freedoms due to the use of AI systems; and
- are given agency and are treated with respect in their interactions with AI systems, including the right to choose equitable alternatives.
11.1 Equitable access to benefits
Building on the principle that people with disabilities should be able to benefit from AI systems at least comparably to others, organizations shall make efforts to ensure that people with disabilities experience equitable benefits from AI systems.
11.1.1 Preventing underrepresentation and misrepresentation in training data
Organizations shall ensure that people with disabilities are not underrepresented or misrepresented in the training data, including:
- avoiding biased proxies;
- biased data labels; or
- synthetic data
that fails to reflect actual disability experiences, diversity, and variability.
11.1.2 Equitable performance across user groups
Organizations shall validate and tune AI systems to perform comparably along the dimensions of:
- accuracy;
- reliability; and
- robustness for people with disabilities as well as for others.
11.1.3 Disaggregated performance metrics
Organizations shall assess and report AI system performance using disaggregated results for people with disabilities.
11.1.4 Monitoring of real-world impacts on people with disabilities
Organizations shall continuously monitor both the performance of AI systems according to validation criteria and the real-world impacts of AI-assisted decisions on people with disabilities, complying with Clause 12.8.
11.1.5 System improvement through feedback and refinement
Organizations shall use monitoring and performance data including data collected in the public registry complying with Clause 12.8, to:
- improve system usability;
- gather additional data;
- enhance data quality; and
- refine validation criteria,
thereby creating positive feedback loops.
11.2 Assessment and mitigation of harms
Organizations shall assess and mitigate potential harms that AI systems may pose to people with disabilities throughout the AI lifecycle. This includes:
- identifying;
- prioritizing; and
- addressing risks
that may disproportionately affect people with disabilities due to their status as statistical minorities or outliers in data-driven systems.
- Organizations shall ensure that harm assessments are not limited to high-impact decisions but also account for cumulative, indirect, or context-specific harms. These harms may include, but are not limited to:
- discrimination;
- loss of privacy;
- reputational damage;
- exclusion; or
- erosion of agency and autonomy.
11.2.1 Equitable risk assessments
Where risk assessment frameworks are employed to determine the risks and benefits of AI systems, risks for people with disabilities, who feel the greatest impact of harm, shall receive priority. The risk assessment shall not be based solely on the risks and benefits to the majority.
11.2.2 Mitigating cumulative harms
Care must be taken to recognize that people with disabilities may experience higher levels of harm than others, caused by the aggregate effect of many cumulative harms that intersect or build up over time as the result of AI-assisted decisions that are not otherwise classified as high impact.
Where there are threats of serious or irreversible harm, lack of quantifiable certainty (e.g. in risk assessment) shall not be used as a reason for postponing effective measures to prevent harmful impacts to people with disabilities.
11.2.3 Equitable accuracy assessment criteria
- Organizations shall select accuracy assessment criteria in line with the risk assessment results, taking care to capture the actual or potential harms to people with disabilities who are outliers in the data.
- Accuracy assessment should:
- include disaggregated metrics for people with disabilities;
- consider the context of use; and
- consider the conditions relative to people with disabilities.
11.2.4 Information security for people with disabilities
- Organizations shall develop plans to protect people with disabilities in the case of data breaches or malicious attacks of AI systems. The plans shall identify risks associated with disabilities as well as clear and swift actions to protect people with disabilities.
- People with disabilities should not have to consent to a lower level of information security to benefit from AI systems.
Note: Disability data is highly unique, making it easily identifiable. As a result, the data of people with disabilities requires a higher level of protection.
11.2.5 Fairness and non-discrimination in AI decision-making
Care must be taken to recognize that people who are discriminated against in AI-assisted decision making are often people with disabilities.
Organizations shall ensure that AI systems are not negatively biased against people with disabilities due to:
- biased choices during data modelling;
- misrepresentation in the training data;
- use of biased proxies;
- biased data labelling;
- unrepresentative synthetic data;
- biased design of the systems;
- tuning of the systems according to incorrect or incomplete criteria; or
- biases that arise in the context of use of the system.
11.2.6 Mitigating statistical discrimination
Even with full proportional representation in the data, people with disabilities will likely remain outliers or marginalized minorities in the context of AI-assisted decisions.
For this reason, to mitigate statistical discrimination, organizations shall not subject people with disabilities to AI-assisted decisions without their informed consent, understanding and access to equivalent alternatives.
11.2.7 Reputational harms
Organizations shall ensure that AI systems do not repeat or distribute stereotypes or misinformation about people with disabilities.
11.3 Upholding of rights and freedoms
Organizations shall uphold the fundamental rights and freedoms of people with disabilities in all uses of AI systems. This includes ensuring that AI systems are not used in ways that compromise privacy, dignity, and autonomy.
11.3.1 Freedom from surveillance
Organizations shall refrain from discriminatory use of AI tools for surveillance.
11.3.2 Freedom from discriminatory profiling
Organizations shall refrain from using AI tools for:
- biometric categorization;
- emotion analysis; or
- predictive policing of people with disabilities.
11.4 Preservation of agency and respectful treatment
- Organizations shall ensure that people with disabilities retain agency, autonomy, and dignity in all interactions with AI systems. This includes:
- meaningful participation in decision-making processes;
- access to accurate and understandable information; and
- the ability to choose equitable alternatives to AI-assisted decisions.
- AI systems shall be designed and deployed in ways that respect the rights of people with disabilities to:
- engage;
- understand; and
- influence the systems that affect them.
- Organizations shall provide mechanisms for:
- informed consent;
- contestability; and
- human oversight.
- Organizations shall prevent the use of AI systems to misinform or manipulate.
11.4.1 Engagement and participation
Organizations shall solicit input from, and encourage the involvement of, individuals with disabilities during all stages of AI system:
- consideration;
- planning;
- design;
- development;
- use; and
- operational management, including continuous monitoring post deployment.
11.4.2 Information and disclosure
Organizations shall inform people about their intended or actual use of AI systems that make decisions about, or otherwise impact, people with disabilities. This information shall be provided in a manner that is:
- accurate;
- accessible; and
- understandable, complying with Clause 10.
11.4.3 Consent, choice, and recourse
- When AI systems are used to make or assist in decisions, organizations shall offer a multi-level optionality mechanism for:
- clients;
- employees; and
- other impacted individuals.
- These mechanisms shall enable the people identified in 11.4.3 a) to request an equivalently full-featured and timely alternative decision-making process that is, at the individual’s choice, either performed:
- without the use of AI; or
- made using AI with direct human oversight and verification of the decision.
People shall be given information in accessible formats about ways to:
- correct;
- contest;
- change; or
- reverse an AI-assisted decision or action that impacts them (see Clause 11.2).
Note: Accessible formats include formats that will be accessible to the requestor. Alternate formats that may be requested under the Accessible Canada Regulation include audio formats, braille, large print, and electronic format.
11.4.4 Freedom from misinformation and manipulation
Organizations shall ensure that AI systems are not used to specifically misinform or manipulate people with disabilities.
11.4.5 Support of human control and oversight
Organizations shall ensure there is a traceable chain of human responsibility that makes it clear who is accountable for the accessibility and equity of decisions made by an AI system.
11.5 Supporting research and development of equitable AI
Where organizations support research and development of AI, they shall include support of research and development of accessible and equitable AI systems.