The Accessible Canada Act and the Accessible Transportation Planning and Reporting Regulations: A Guide on Progress Reports

Table of contents

Plain language Summary

A plain language summary of the Accessible Canada Act and the Accessible Transportation Planning and Reporting Regulations: A Guide on Progress Reports is available.

Introduction

A progress report provides updates on the implementation of a Transportation Service Providers (TSP) accessibility plan, and on other accessibility-related progress that has been achieved which may not have been captured in the previous accessibility plan.

The purpose of this guide is to explain TSPs’ obligations under the Accessible Transportation Planning and Reporting Regulations with respect to the development of progress reports. In particular, this guide explains:

  • The contents of progress reports;
  • The preparation of progress reports, including consulting persons with disabilities;
  • The requirements for the publication of progress reports; and,
  • Best practices related to progress reports.

For information on accessibility plans and feedback processes, please see:

For information on who the ATPRR applies to, classes of entities, and the corresponding publication timelines for each class, please see the guidance on Who does the ATPRR apply to?, and Publication Timelines.

This is not a legal document. The explanations and definitions it provides are for general guidance purposes only. The obligations for progress reports are established in the Accessible Canada Act (ACA) and the ATPRR. In case of differences between this guide and legislation or regulations, the legislation and regulations prevail.

Contents of Progress Reports

Progress reports must include information about feedback received by TSPs through their feedback process and consultations with persons with disabilities, including feedback received from people who have not travelled with them. Furthermore, they must include the following headings, which correspond to content requirements:

Different organizations have different resources, needs and capabilities. As such, the ACA and the ATPRR do not mandate overly specific content that a TSP must include in its progress report beyond the headings. This flexibility allows TSPs to develop their progress report in a way that works best for their organization.

This Guide provides additional information on the content to be included under each of these headings in the sections below, and examples of matters falling within each subject can be found in the Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Accessibility Plans. Furthermore, this Guide includes a progress report template and checklist, which can respectively be found in Annexes A and B, as well as a section titled Best Practices for Progress Reports.

The CTA encourages TSPs to exceed minimum requirements wherever possible. The references to best practices, examples and sources may also inspire regulated transportation entities to go farther in eliminating barriers to accessibility.

The information set out in this Guide is specific to the federal transportation sector. For information related to the ACA’s planning and reporting requirements for employment, please refer to the Accessible Canada Regulations and its related guidance on Employment and Social Development Canada’s website

General

In this section of their progress report, a TSP must include the following information:

  • the name of the person designated to receive feedback on behalf of the entity or the position of the person who is designated to receive feedback on behalf of the entity;

    and

  • how the public can provide feedback and request an alternate format of the accessibility plan, or an alternate format of the description of the feedback process. This must include a:
    • mailing address
    • telephone number, and,
    • an email address.

Regarding the following heading sections which are required to be in every progress report, a TSP must set out information about its progress in implementing the elements of its accessibility plan related to each of these headings.

In addition, a TSP must set out any other accessibility-related progress that has been accomplished in each of these headings which may not have been captured in the previous accessibility plan.

Information and Communication Technologies (ICT)

Information and communication technologies includes the accessibility of all telecommunication systems, computer systems and networks owned, operated or controlled by the TSP. This also includes websites and mobile applications owned operated or controlled by the entity, as well as announcements made in terminals and onboard.

Communication, Other than ICT

Communication other than ICT addresses communication in language that is informed, respectful and accessible to persons with disabilities. It includes spoken, written, signed, and other forms of communication.

Where possible, the information in this section should touch on a TSP’s progress in implementing the elements of its accessibility plan related to information using non-ICT methods (i.e., communicating information without the use of technology, such as providing information verbally or by using signage) and:

  • information and communication technologies;
  • the procurement of goods, services and facilities;
  • the design and delivery of programs and services; and,
  • transportation.

Procurement of Goods, Services and Facilities

Procurement refers to the act of purchasing, including the overall evaluation process leading up to the purchase. The procurement of goods, services and facilities can include purchasing equipment (e.g., lifts, wheelchairs, or aircrafts and rail cars), putting contracts or arrangements in place for the provision of services (e.g., ground handlers who package, load and unload mobility aids, ground transportation service providers, such as taxi drivers, who provide service to and from terminals), and for specifications and requirements related to newly built or renovated terminals and any related facilities.

Design and Delivery of Programs and Services

This includes the details about how a TSP considers and includes accessibility when designing and delivering its services and programs to its clients. Additionally, this also applies to feedback received from TSP personnel on the design and delivery of the TSP’s programs and services. This may overlap with some of the other priority areas.

Transportation

In this section of their progress report, a TSP must set out information about its progress in implementing the elements of its accessibility plan related to the transportation used to access the TSP’s services. For some TSPs, this would include the provision of accessible transportation to and from a terminal, such as wheelchair accessible taxis or shuttle buses. This would also include any transportation provided between terminals at some airports.

In addition, a TSP must set out any other accessibility-related progress that has been accomplished in this area which may not have been captured in the previous accessibility plan.

Built Environment

The built environment refers to human-made structures, features, and facilities. In the case of the CTA, the built environment can include:

  • passenger aircraft
  • passenger trains
  • passenger buses
  • passenger vessels (ferries)
  • aerodrome passenger terminals (airports)
  • railway passenger station
  • bus passenger station, and
  • marine passenger terminals.

With respect to foreign air, rail, ferry and bus carriers, the accessibility of the built environment can include:

  • passenger aircraft, passenger trains, passenger buses, and passenger ferries used to provide services to and from Canada, and ancillary services provided in relation to such transportation; and,
  • programs that foreign carriers may have in place to ensure accessibility of Canadian and foreign airports, if applicable.

Provisions of CTA Accessibility-Related Regulations

In this section of their progress report, a TSP must identify or list all provisions of the CTA regulations made under ss. 170(1) of the Canada Transportation Act (Act) that apply to them, or in other words, the CTA accessibility-related regulations which apply to them.

In addition, this section must set out information about a TSP’s progress in implementing its accessibility plan regarding the provisions that apply to it. TSPs have the flexibility to determine how the content of the progress report is addressed, and what level of detail is included.

The regulations that the CTA has made under ss. 170(1) of the Act are:

Feedback Information

TSPs must include information about the feedback received through its feedback process, and how that feedback was taken into consideration.

For more information on the feedback process, please see Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Feedback Processes.

Note:

While TSPs are required to report on the feedback received through their feedback process and how that feedback was taken into consideration, TSPs have the flexibility to determine how this content is set out and addressed.

Feedback outside of the TSP’s responsibility:

It is possible that some TSPs may receive feedback that concerns matters that are outside of the TSP’s responsibility. For example, if a comment is submitted to an air carrier regarding the provision of wheelchair services in a foreign airport when the responsibility to provide the wheelchair service falls under the terminal or airport operator and not the carrier.

Although TSPs must report on the feedback received and how that feedback was taken into consideration, TSPs have the flexibility to determine how they address the feedback received in the progress reports, including in circumstances as the example noted above.

The intent of the ACA, and the principles set out under section 6 of the ACA, should be considered when addressing feedback received.

Consultations

This section must set out information on how a TSP consulted with persons with disabilities in the preparation of its progress report.

For best practices related to progress reports and consultations, please see the best practices section below.

Publication of Progress Reports

For information relating to the timelines for publishing an accessibility plan, please see the guidance on Publication Timelines.

General Requirements for Publication

A TSP must publish its most recent progress report in clear, simple and concise language. This means that sentences should be short, grammar should be simple, and technical words should be avoided where possible, such that the text is easily understandable. For more information on creating accessible documents, you could consult the following resources: the Digital Accessibility Toolkit and the Canada.ca Content Style Guide.

TSPs who use a digital platform must electronically publish their progress reports on the main digital platform that they own, operate or control and that they use to communicate information to the public. In most cases, this will be a TSP’s website.

A TSP must publish this information in a manner that makes the progress report accessible on the digital platform either directly on the homepage or home screen, or by way of a hyperlink from that homepage or home screen.

A TSP must ensure that its progress report meets the requirements of Level AA conformance that are set out in the Web Content Accessibility Guidelines (WCAG) in the most recent version that has been published in both French and English by the World Wide Web Consortium .

No Digital Platform

TSPs who do not use a digital platform to communicate information to the public must publish a print copy of the most recent progress report. Same as the progress reports that are published on digital platforms, print copy progress reports must also be published in clear, simple and concise language.

The hard copy publication must be displayed in a conspicuous location in the main reception area of each of its publicly accessible business locations.

Feedback Process

Don’t forget! – a TSP must publish a description of its feedback process with its accessibility plan or progress report, in a format that meets the requirements of Level AA conformance that are set out in the WCAG version 2.0. The ATPRR reference the most recent version of WCAG that has been published in both French and English by the World Wide Web Consortium.

Notice to the Agency

A TSP must notify the CTA by electronic means (e.g., email) within 48 hours of publication of each version of its progress report, and include in the notice:

  • a hyperlink to the URL of the progress report;

    OR

  • the addresses of the publicly accessible business locations where a print copy of the progress report is available.

TSPs should submit their notice to the CTA using the following email address: OTC.REPRTA-ATPRR.CTA@otc-cta.gc.ca.

Alternate Formats

  • print
  • large print
  • braille
  • audio format, or
  • an electronic format that is compatible with adaptive technology that is intended to assist persons with disabilities.

A person may make the request for an alternative format of a TSP’s progress report through any means by which the regulated transport entity communicates with the public, including by mail, by telephone, or via electronic means, such as email.

A TSP must make its progress report available to the person in the alternate format requested as soon as feasible after the request is received, but no later than:

  • For braille or an audio format: 45 days after the day that the request is received;
  • For any other format:
    • for Class 1 and Class 2 TSPs: on the 15th day after the day that the request is received, and
    • for Class 3 TSPs: on the 20th day after the day that the request is received.

For best practices related to progress reports and alternative formats, please see the best practices section below.

Best Practices for Progress Reports

General Best Practices:

  • A progress report is intended to provide updates on the progress made in implementing a TSP’s accessibility plan, as well as on other accessibility-related progress that has been accomplished. In order to prepare a comprehensive and complete progress report, a TSP should refer to the content set out in its accessibility plan while composing its progress report.
  • A TSP should actively evaluate the success of its accessibility plan’s individual elements throughout the plan’s lifecycle. This will assist with the preparation of both the progress reports and the updated version of a TSP’s accessibility plan.
  • In general, the progress report should address information such as:
    • What was the outcome or result of each element or item identified in the accessibility plan?
    • How each element or item identified in the accessibility plan was implemented and the objectives set out in the accessibility plan were achieved?
      • Mention concrete steps that were taken to implement a given element of an accessibility plan.
    • What was or is the timing of implementation related to each element?
    • Were there any barriers or obstacles during implementation?
      • If so, what?
      • Were these barriers or obstacles challenges in implementing the plan in general, or were additional accessibility-related barriers identified? If so, what were/are the new barriers, and how will they be addressed?
    • If an element was not implemented, or if there was a delay, a TSP should ask these questions:
      • What has prevented this action from being undertaken or completed by the proposed deadline?
      • When will this action be completed?
      • What additional resources may be required to complete this action?
      • What steps can be taken to reduce or prevent obstacles to completing this action?

Note: It will be easier to address the progress of an accessibility plan which sets out clear and measurable targets (e.g., including specific implementation dates).

Best Practices for Consulting Persons with Disabilities

  • TSPs could look into establishing an advisory committee which would include representatives from the disability community, ideally providing representations of various disabilities and experience. In addition to providing insight and feedback on a TSP’s progress report, an advisory committee could provide feedback on a TSPs accessibility-related programs and services based on their lived experience.
  • In general, the consultation section in a progress report should address the following information:
    • Whom you consulted (i.e., the names of any disabilities organizations, advocates, or experts who participated)

      Note: The names of other participants and their identified disabilities should be omitted for the sake of privacy.

    • The number of participants
    • When you consulted
      • the dates or period of time during which the consultation(s) took place
    • How you consulted
      • a description of the consultation process and activities (for example, whether you used in-person events, virtual meetings, group discussions, digital surveys, or other means.
    • What you consulted on
      • description of questions asked and answers received
      • specific details of how those questions and answers informed decisions made about your accessibility plan.

Best Practices for Alternative Formats

  • Large print usually refers to 16 point font and sans serif (for example, Arial or Calibri are both sans serif fonts).
  • Information provided in an electronic format must be compatible with adaptive technology, including software that converts text voice (screen readers) for persons who are blind or have low vision.
  • If the type of alternative format needed has not been made clear in the request, it is always best to discuss with the person as to what format is accessible to them. For example, some persons may require 24 point font instead of 16 point font for large print, and other persons may find a plain text or html document reads better with a screen reader than a PDR version.

How the ATPRR relates to the ATPDR and other CTA regulations (ATR and PTR)

The provisions set out in the Accessible Transportation for Persons with Disabilities Regulations (ATPDR) and the planning and reporting requirements set out in the ACA and the ATPRR are complementary.

Though also forward looking, the ATPDR include an extensive range of specific provisions for which large domestic and international transportation service providers are required to comply. This sets a specific threshold that these transportation service providers must meet in their provision of accessible transportation for persons with disabilities.

There are also the Personnel Training for the Assistance of Persons with Disabilities Regulations and Part VII of the Air Transportation Regulations that set specific accessibility requirements and apply to TSPs who are not captured under the ATPDR.

The ACA and the ATPRR complement the provisions in the ATPDR, the PTR and Part VII of the ATR, by requiring transportation service providers to fulfill planning and reporting requirements that will enable them to take substantive steps to eliminating any remaining barriers, and preventing new barriers, that persons with disabilities may face when accessing their transportation services.

We're here to help

For more information and guidance about accessible travel and the CTA's dispute resolution services, please contact us at info@otc-cta.gc.ca.

Annex A: Progress Report Template

Note: The below template sets out the headings or sections that the ATPRR requires a Transportation Service Provider (TSP) to include in its progress reports. The text below each heading are intended as notes to set out what information a TSP is required to include in each respective section.

For further information on progress reports and the specific sections identified below, as well as suggestions on best practices and additional information that could be included in a progress report, please see Accessible Transportation Planning and Reporting Regulations: A Guide on Progress Reports.

General - Annex A

This section must include the following information:

  • the name of the person designated to receive feedback on behalf of the TSP or the position whose incumbent is designated to do so;

    and

  • how the public can provide feedback or request an alternate format of the accessibility plan, an alternate format of the description of the feedback process, or an alternate format of the progress report. This must include a:
    • mailing address
    • telephone number, and
    • email address.

Information and communication technologies (ICT) - Annex A

This section must set out information about a TSP’s progress in implementing the elements of its accessibility plan related to information and communication technologies, as well as any other accessibility-related progress that has been accomplished in this area.

Communication, other than ICT - Annex A

This section must set out information about a TSP’s progress in implementing the elements of its accessibility plan related to communication other than ICT, as well as any other accessibility-related progress that has been accomplished in this area.

The information in this section should touch on a TSP’s progress in implementing the elements of its accessibility plan related to information using non-ICT methods and:

  • information and communication technologies;
  • the procurement of goods, services and facilities;
  • the design and delivery of programs and services; and,
  • transportation.

Procurement of goods, services and facilities - Annex A

This section must set out information about a TSP’s progress in implementing the elements of its accessibility plan related to the procurement of goods, services and facilities, as well as any other accessibility-related progress that has been accomplished in this area.

Design and delivery of programs and services - Annex A

This section must set out information about a TSP’s progress in implementing the elements of its accessibility plan related to the design and delivery of programs and services, as well as any other accessibility-related progress that has been accomplished in this area.

Transportation - Annex A

This section must set out information about a TSP’s progress in implementing the elements of its accessibility plan related to transportation, as well as any other accessibility-related progress that has been accomplished in this area.

Built environment - Annex A

This section must set out information about a TSP’s progress in implementing the elements of its accessibility plan related to the built environment, as well as any other accessibility-related progress that has been accomplished in this area.

The built environment includes:

  • passenger aircraft,
  • passenger trains,
  • passenger ferries,
  • passenger buses,
  • airports or aerodrome passenger terminals,
  • railway passenger stations,
  • ferry or marine passenger terminals, and
  • bus passenger stations.

Provisions of CTA accessibility-related regulations - Annex A

This section must identify or list all provisions from the CTA accessibility-related regulations that apply to a TSP.

In addition, this section must set out information about a TSP’s progress in implementing its accessibility plan regarding the provisions that apply to it. TSPs have the flexibility to determine how the content of the progress report is addressed, and what level of detail is included.

Feedback information - Annex A

This section must set out information about the feedback that a TSP received through its feedback process, and how that feedback was taken into consideration.

Consultations - Annex A

This section must set out information on how a TSP consulted with persons with disabilities in the preparation of the progress report.

Annex B: Progress Report Checklist

The following checklist is intended to assist transportation service providers (TSPs) in completing their progress reports. The below items are set out in the order in which it is suggested that TSPs approach their progress reports in order to meet all requirements.

This is not a legal document. The explanations provided are for general guidance purposes only. The obligations for progress reports are established in the ATPRR and the ACA, and in Annex A of this guide. In case of differences between this guidance material and legislation or regulations, the legislation and regulations prevail.

Step 1: Required headings for your progress report

Include the following headings in the progress report:

  • General
  • Information and communication technologies (ICT)
  • Communication, other than ICT
  • Procurement of goods, services and facilities
  • Design and delivery of programs and services
  • Transportation
  • Built environment
  • Provisions of CTA accessibility-related regulations
  • Feedback information
  • Consultations

Step 2: Required contents for the headings of your progress report

Required contents for the “General” heading

Under the “General” heading, include the following information:

  • The name of the position or person designated to receive feedback on behalf of the entity
  • The means by which the public can provide feedback
  • The means by which the public can request an alternate format of the accessibility plan or an alternate format of the description of the feedback process

    These "means" must include: a mailing address, telephone number, and an email address

Required contents for other headings of your progress report

Include all relevant information under each heading as described in the Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Progress Reports. TSPs have the flexibility to determine how this content is addressed and what level of detail is included. Examples of best practices related to progress reports can also be found in the Guide. For examples of specific content related to the CTA that can be addressed under each heading, please refer to the Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Accessibility Plans.

  • Information and communication technologies (ICT)
  • Communication, other than ICT
  • Procurement of goods, services and facilities
  • Design and delivery of programs and services
  • Transportation
  • The built environment
  • Provisions of CTA accessibility-related regulations

Required contents for the “Feedback information” heading

Under the “Feedback information” heading, set out information about:

Step 3: Publishing your progress report

Before publishing your progress report, review and confirm:

  • it is written in clear, simple and concise language.
  • the document meets the requirements of AA conformance that are set out in the WCAG.

When publishing your progress report, confirm:

For TSPs who use a digital platform:

  • Publish the progress report on the main digital platform, either directly on the homepage or home screen, or by way of a hyperlink from that homepage or home screen.

For TSPs who do not use a digital platform:

  • Publish a print copy of your most recent progress report and display it in a conspicuous location in the main reception area of each of its publicly accessible business locations.

Feedback process – don’t forget!

  • Publish a description of your feedback process together with your progress report, in a format that meets the requirements of AA conformance that are set out in the WCAG.

Step 4: Notice to the Agency

  • Within 48 hours of publication, notify the CTA by electronic means that a new version of the accessibility plan has been published.

    TSPs should submit their notice to the CTA using the following email address: OTC.REPRTA-ATPRR.CTA@otc-cta.gc.ca.


  • Include in the notice a hyperlink to the URL of the description or updated description

    OR

    the addresses of the publicly accessible business locations where a print copy of the progress report is available.

Step 5: Alternate formats

A TSP must provide the description of its feedback process in an alternate format upon request. Please see the Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Feedback Processes for additional information on alternate formats, including required response times and best practices.

Should you receive a request, confirm that you are prepared to make the description of your feedback process available in the following formats and on time:

  • Print (for class 1 and class 2 TSPs – on the 15th day after the day that the request is received; for class 3 TSPs – on the 20th day after the day that the request is received)
  • Large print (for class 1 and class 2 TSPs – on the 15th day after the day that the request is received; for class 3 TSPs – on the 20th day after the day that the request is received)
  • Braille (45 days after the day that the request is received)
  • Audio format (45 days after the day that the request is received)
  • Electronic format that is compatible with adaptive technology that is intended to assist persons with disabilities (for class 1 and class 2 TSPs – on the 15th day after the day that the request is received; for class 3 TSPs – on the 20th day after the day that the request is received)

A TSP must accept a request for a progress report in an alternative format made through any means by which the TSP communicates with the public. This includes by mail, by telephone, or via electronic means, such as email.

As applicable, depending on the means by which you communicate with the public, confirm there is a mechanism in place to ensure all requests made:

  • by mail are met
  • by telephone are met
  • via email are met
  • via any other electronic means used to communicate with the public are met

Step 6: Start work on next progress report or updated accessibility plan

  • Initiate review and begin work on next year’s progress report or the updated accessibility plan.
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