Under the Canadian Human Rights Act (1985) federal employers and service providers must prevent discrimination based on disability (s.7). This applies to Crown corporations, banks, telecom and all federally regulated workplaces, regardless of size. The Accessible Canada Act (2019) expands this to proactive barrier removal in areas such as employment, built environment and information and communications technology (s.2). In both laws, “disability” covers physical, mental and sensory impairments that limit life activities.
Federal employers have a duty under the Canadian Human Rights Act to offer reasonable accommodations to employees with disabilities unless it poses undue hardship. The Accessible Canada Act adds a requirement to identify, prevent and remove accessibility barriers across all operations. Common forms of reasonable accommodations include workspace modifications, flexible work hours, assistive technology, sign language interpretation and adjusted training materials.
An employee request may be verbal or written. Employers should start an interactive dialogue promptly, discussing needs and possible adjustments. Medical documentation may be requested only to clarify functional limitations, not to diagnose. While the Canadian Human Rights Act does not specify precise deadlines, the Accessible Canada Act requires acknowledging requests within 30 days and removing barriers within a reasonable period, typically not exceeding 12 months for structural changes.
Anyone who believes their right to reasonable accommodations has been breached can file a complaint with the Canadian Human Rights Commission. The Commission investigates, attempts mediation and can refer cases to the Canadian Human Rights Tribunal. Remedies include orders to provide accommodations, monetary compensation for injury to dignity, and public interest measures. Under the Accessible Canada Act, non-compliance may attract administrative monetary penalties up to CAD 250,000 per violation.
Managing reasonable accommodations requests under the Canadian Human Rights Act (1985) & Accessible Canada Act (2019) can be complex—multiple forms, strict timelines, and cross-team coordination all add burden.
Disclo centralizes every case in one dashboard:
Ready to streamline your Canada reasonable accommodations workflow? Request a demo today.
Train managers and HR staff on both Acts and on removing unconscious bias. Early education builds confidence in handling requests.
Document each step of the interactive process. Clear records help demonstrate good faith efforts if a complaint arises.
Work with employees to explore low-cost solutions first, such as schedule adjustments or software tools before considering structural changes.
Review policies annually to reflect changes in accessibility standards and technology advances. Small updates can prevent big gaps.
Avoid common mistakes like requiring overly detailed medical reports or assuming an accommodation is unnecessary. Open dialogue is key.
