Contracting for Accessibility (CFA) refers to the practice of embedding accessibility requirements into federal contracts so that the goods, services, or construction being procured help identify, remove, and prevent barriers for persons with disabilities. While you won't find "CFA" as a formal label in federal policy documents, the obligation is very real—it's woven throughout the Supply Manual and backed by the Accessible Canada Act. If you're drafting a solicitation or evaluating bids, you need to consider accessibility where appropriate, or document why you didn't.
How It Works
The foundation sits in two key sections of the Supply Manual. Section 3.135 (Accessibility considerations) tells you to consider accessibility criteria when specifying requirements, evaluating bids, and awarding contracts, in line with the Accessible Canada Act and the Treasury Board Policy on the Planning and Management of Investments. Section 4.70.15 (Accessible procurement) goes further: when procuring goods, services, or construction, you're required to take applicable accessibility standards into account and apply accessibility requirements in solicitations and resulting contracts—unless it's genuinely not appropriate, in which case your file should explain why.
In practice, this means building accessibility into your Statement of Work or technical specifications. Are you buying software? You'll want to reference WCAG standards or ensure compatibility with assistive technologies. Procuring furniture or renovating a building? Consider physical accessibility features. Hiring a contractor to deliver training programs? Think about how materials and sessions accommodate people with different needs. PSPC's Accessibility Plan (2022–2025) commits the department to integrating these considerations across procurement instruments, and they expect the same from other federal departments using their common services.
Here's the thing: the Accessible Canada Act explicitly lists "the procurement of goods, services and facilities" as one of seven priority areas where federal organizations must identify and remove barriers. The Accessible Canada Regulations require entities to publish accessibility plans describing how they'll tackle barriers in procurement, which feeds directly into contract requirements. So when you're drafting that RFP, you're not just checking a box—you're operationalizing a statutory obligation.
Key Considerations
- Not every procurement needs the same level of accessibility requirements. The Supply Manual says "where appropriate"—use judgment based on what you're buying and who will use it. Document your rationale either way.
- Accessibility isn't just about the end product. It also applies to how contractors deliver services, communicate with users, and design the built environment. A contract for public-facing services should address how the contractor will serve people with disabilities.
- Evaluation criteria matter. If accessibility is part of your requirement, it should show up in your evaluation criteria. You can't enforce what you don't measure.
- This intersects with other policies. The Treasury Board Policy on the Planning and Management of Investments requires accessibility to be considered in project planning and procurement, so CFA obligations often begin upstream of the contracting phase itself.
Related Terms
Accessible Canada Act, Supply Manual, Statement of Work, Evaluation Criteria, Technical Specifications
Sources
- Supply Manual – Section 3.135: Accessibility considerations
- Supply Manual – Section 4.70.15: Accessible procurement
- Accessible Canada Act, S.C. 2019, c. 10
Bottom line: if you're contracting on behalf of the federal government, accessibility isn't optional. Build it into your requirements, reflect it in evaluation, and make sure your file shows you thought it through.