Nothing Without Us in Action: Harmonizing Accessibility Standards for Real World Impact

Accessibility standards are one of the most practical tools available to governments to implement Article 9 of the UN Convention on the Rights of Persons with Disabilities (CRPD). Article 9 obligates States Parties to ensure access to the physical environment, transportation, information and communications technologies, and public services on an equal basis with others. Standards provide the technical specifications and operational guidance needed to translate these commitments into practice, serving as a bridge between policy intent and measurable, enforceable outcomes.

One organization that stands out for its approach to standards development is Accessibility Standards Canada (ASC), a federal standards development organization established under Canada's Accessible Canada Act with a mandate to help achieve a barrier-free Canada by 2040. ASC develops and recommends accessibility standards across 7 priority areas including the built environment, information and communication technology, employment, transportation, communication, procurement, and the design of programs and services.

What distinguishes ASC is not only the scope of its work, but how it works. ASC has embedded the principle of “nothing without us” into its governance and technical processes. People with disabilities lead and are meaningfully involved throughout the standards development lifecycle as researchers, technical committee members, subject matter experts, and decision-makers. This model ensures that standards reflect lived experience and meet real-world needs. It also positions ASC as an internationally recognized model for disability-inclusive standards development.

To date, ASC has published eight standards with more than 30 currently under development. These includes standards on Accessibility requirements for ICT products and services; Employment; Accessible and Equitable Artificial Intelligence Systems and Plain Language

It is important to distinguish, however, between standards and regulation. Accessibility standards, such as those developed by Accessibility Standards Canada (ASC) are voluntary instruments. Organizations are encouraged to adopt them, but they are not legally binding on their own. When incorporated into regulation, they become mandatory within a defined scope. Legislation and regulations determine who must comply, in what contexts, and within what timelines, while standards provide the technical means to do so.

A concrete example of this standards-to-regulation pathway is the ICT accessibility standard, CAN/ASC–EN 301 549:2024. This standard sets out detailed accessibility requirements for ICT products and services and aligns with internationally recognized standards. While developed as a voluntary standard, it was adopted into regulation under the Accessible Canada framework in 2025. The regulation requires federally regulated organizations to conform to the requirements set out the standard for their web pages, (including web applications), mobile applications and digital documents. The ICT accessibility standard is also referenced in the Employment regulations, demonstrating alignment not only across global ICT standards, but also within related standards.

As accessibility standards and regulations continue to evolve across jurisdictions, the need for harmonization becomes increasingly important. Divergence between standards can create inefficiencies for governments, increase compliance complexity for industry, and ultimately impact accessibility for users. In this context, practical mechanisms for coordination become essential.

In Canada, one approach ASC is using to address this challenge has been the use of Memorandums of Understanding (MOUs) between ASC and provincial regulators. Provinces across Canada develop accessibility standards within their own legislative frameworks, which are then implemented through regulation. Without coordination, this can lead to duplication of effort and fragmentation in technical requirements.

To date, ASC has signed nine MoUs with seven provinces, including British Columbia, Ontario, Saskatchewan, Manitoba, New Brunswick, Nova Scotia, and Alberta. The MoU’s focus on coordinating standards development, sharing research, and identifying where standards can align or reinforce one another.

Through MOUs, ASC and provincial partners establish a framework for information sharing, collaboration, and alignment in standards development. This allows provinces to leverage existing standards work, rather than initiating separate development processes from the ground up. As ASC has noted in the context of these partnerships, “Together, through collaboration and alignment, we can make accessibility progress…” In practice, this approach supports greater consistency across jurisdictions while respecting provincial authority.

MOUs also send a clear signal to industry and civil society that governments are working together. For organizations operating across multiple provinces, this reduces regulatory uncertainty. For people with disabilities, it supports a more consistent experience of accessibility regardless of where they live.

It is, however, important to recognize that MOUs are not a comprehensive solution. As non-binding instruments, their effectiveness depends on sustained engagement, clear governance arrangements, and a shared commitment to implementation. Without these elements, there is a risk that collaboration remains at the level of intent rather than producing tangible alignment. For this reason, MOUs are best understood as one tactic within a broader harmonization toolkit.

The G3ict Digital Accessibility Standardization and Policy Harmonization (DASH) Advisory Council provides a global platform to advance this work. Bringing together stakeholders from standards bodies, regulatory authorities, industry, and civil society, DASH supports the implementation of Article 9 of the CRPD through practical collaboration and knowledge exchange.

A key objective of DASH is to promote standards and policy harmonization for emerging technologies, including artificial intelligence. As digital systems become more complex and interconnected, ensuring accessibility will require coordinated approaches that span both voluntary standards and regulatory frameworks. The experience of ASC and its use of MOUs with provincial regulators offers a valuable example of how such coordination can be achieved in practice.

Looking ahead, there is a clear need to strengthen the evidence base on harmonization practices. Different jurisdictions will continue to adopt different approaches, shaped by their governance structures, resources, and policy contexts. Capturing and sharing these experiences is essential to identifying what works, under what conditions, and why.

Call to action: G3ict, through the DASH Advisory Council, invites standards bodies, regulators, industry leaders, and organizations of persons with disabilities to share their experiences with harmonization mechanisms. What approaches have proven effective in your context? How have you balanced alignment with local requirements? By contributing to a global exchange of practical strategies, partnerships, and lessons learned, stakeholders can help accelerate progress toward the full realization of accessibility as envisioned in Article 9 of the CRPD.