Open Letter Regarding the Need to Strengthen Bill C-81 – Accessible Canada Act

October 30, 2018

Dear Minister Qualtrough and HUMA Committee Members:

We the undersigned commend the Federal Government for committing to enact national accessibility legislation.  As provincial and national disability rights organizations, we write to express significant concerns regarding Bill C-81. The following highlights our key concerns and reflects the concerns raised by our communities before the HUMA Committee. Amendments are essential to effectively remedy these concerns.

  1. Bill C-81 requires timelines. Timelines are essential to ensure that key accessibility measures are taken. Timelines are also required so that progress on accessibility can be measured. In particular, we support recommendations for the Bill to include a timeline for achieving a Canada without barriers, and timelines by which accessibility standards are developed and enacted into law. Timelines are also needed for establishing the infrastructure necessary to implement the Bill.
  2. Bill C-81 imposes no duty on Government to use the powers available in the Bill. We support recommendations to change the word may to shall to ensure that the Government implements key steps for achieving accessibility.
  3. Bill C-81 requires federally-regulated organizations to establish accessibility plans. However, the Bill does not require these to be good plans. It does not require an organization to implement its accessibility plan.
  4. Bill C-81 wrongly splinters the power to make accessibility standards (regulations) and the power to enforce the Bill across numerous Federal agencies. This splintering will make the Bill’s implementation and enforcement less effective, more confusing, more complicated, more costly, and will increase delay.
  5. Bill C-81 wrongly gives the Federal Government and various federal agencies the sweeping, unjustified and unaccountable power to exempt organizations from a number of important accessibility obligations. The Government can even exempt itself.
  6. The Bill does not require the Federal Government to use its readily-available power to ensure that federal money is never used by any recipient to create or perpetuate barriers. The Bill must be amended to leverage the federal spending power, in order to promote accessibility.
  7. The Federal Government is the largest organization that will have to obey this legislation. Therefore, the key federal agencies that will develop accessibility standards, oversee and enforce this legislation must be independent of the Federal Government. Under the Bill, they are not. They all report to the Federal Government. We support recommendations for amendments to ensure that CASDO, the Accessibility Commissioner and other key agencies are sufficiently independent.
  8. Bill C-81 does not sufficiently address barriers created by poverty and intersectional discrimination. Nor does it address the unique barriers experienced by Indigenous and First Nations persons with disabilities.
  9. Bill C-81 does not recognize ASL/lsq as the official languages of people who are Deaf.

We believe that if these priority changes are made, among the amendments to Bill C-81, this Bill has the potential to truly advance accessibility and inclusion of persons with disabilities in Canada. We ask that the Bill be amended to address the concerns and objectives outlined above. These amendments are indispensable to ensure that the Bill achieves its purpose and potential.


In Solidarity,

Council of Canadians with Disabilities (CCD)

Communication Disabilities Access Canada (CDAC)

In addition to the concerns outlined in this open letter, CDAC recommends that Bill C-81 address communication as a domain across all federal jurisdictions and includes the needs of people with speech and language disabilities. ARCH, CCD and other disability organizations support CDAC’s recommendations. 


Canadian Association for Community Living (CACL)

National Network for Mental Health (NNMH)

Independent Living Canada (ILC)

March of Dimes Canada

Canadian National Institute for the Blind (CNIB)

Barrier Free Canada – Canada sans Barrières

Alliance for Equality of Blind Canadians (AEBC)

People First of Canada

AODA Alliance

ARCH Disability Law Centre

Québec Accessible

Views for the Visually Impaired

Physicians of Ontario Neurodevelopmental Advocacy (PONDA)

Unitarian Commons Co-Housing Corporation

Citizens with Disabilities Ontario (CWDO)

Community Living Ontario (CLO)

Barrier-Free Manitoba

Regroupement des associations de personnes Handicapées de l’Outaouais (RAPHO)

Barrier Free Saskatchewan

DeafBlind Ontario Services

Community Living Toronto (CLT)

Ontario Autism Coalition

Confédération des organismes de personnes handicapées du Québec (COPHAN)

Canadian Multicultural Disability Centre, Inc. (CMDCI)

Community Legal Assistance Society (CLAS)

Northwest Territories Council for Disability

Voice of Albertans with Disabilities

North Saskatchewan Independent Living Centre Inc.

Older Women’s Network

Centre for Independent Living in Toronto

Ontario Disability Coalition

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