Accessibility Factors

When you're putting together a solicitation, you need to think about whether the goods or services you're buying will work for everyone—including people with disabilities. That's what accessibility factors are all about. The Supply Manual lays out specific considerations you must evaluate, and as of the Accessible Canada Act's 2040 deadline, ignoring these isn't just poor practice—it's non-compliance.

How It Works

The Supply Manual provides the framework through Section 2.21 on Accessible Procurement and Requirements Definition, along with Annex 2.6 which lists specific factors and considerations. Here's the thing: the Technical Authority on your file must ensure accessibility gets baked into your requirements and specifications from the start. If you decide not to include accessibility criteria, you'll need to document why—and that justification better be solid.

In practice, this means evaluating your procurement through multiple lenses. Can people with visual impairments use the software you're buying? Does that furniture accommodate users with mobility devices? Will the training services you're contracting work for participants who are deaf or hard of hearing? The technical guides produced by Accessibility Standards Canada and PSPC break this down by category—one for goods, another for services—giving you concrete questions to ask at each stage.

The best approach involves consulting with actual end users who have disabilities, where feasible. They'll catch barriers you might miss. A procurement officer at PSPC might think a web application meets standards because it passes automated testing, but a user with a screen reader could immediately identify navigation problems that never showed up in the test results. That real-world input shapes better requirements definition and ultimately better outcomes.

Key Considerations

• Document your decisions early. If you're not incorporating specific accessibility criteria, you need written justification before your solicitation goes out. Waiting until someone questions your approach makes for awkward conversations with the Office of the Procurement Ombudsman.

• The 2040 deadline is firm. The Accessible Canada Act requires federal organizations to identify, remove, and prevent barriers in procurement by January 1, 2040. That sounds far away, but procurement practices take years to shift across government. Start now.

• Accessibility isn't just about compliance standards. Yes, you need to reference WCAG guidelines for digital products or CSA standards for physical spaces. But the factors go deeper—think about procurement timing that allows vendors to provide materials in alternate formats, or evaluation criteria that recognize accessible solutions without penalizing their cost.

• Technical Authority responsibility matters. This isn't something you can delegate away or handle as an afterthought during review. The TA needs to actively consider and document how accessibility shapes the requirement itself, not just tack on a compliance clause at the end.

Related Terms

Technical Authority, Requirements Definition, Mandatory Requirements, Evaluation Criteria, Statement of Work

Sources

• Supply Manual - Section 2.21 and Annex 2.6: Accessible Procurement

• Procurement of accessible goods Technical guide (Accessibility Standards Canada and PSPC)

• Procurement of accessible services Technical guide (Accessibility Standards Canada)

Bottom line: build accessibility evaluation into your procurement planning checklist, right alongside security requirements and official languages obligations. Your requirements package should reflect these considerations before it reaches contracting, not after.