Entity classification under the CRTC Accessibility Reporting Regulations
Entities regulated by the CRTC have obligations under the Accessible Canada Act (ACA) and the CRTC Accessibility Reporting Regulations (the Regulations).
Classes
Subsections 2(1) and 18(1) of the Regulations establish classes of entities.
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Class B1 and Class T1
Consist of federal governmental/Crown entities
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Class B2 and Class T2
Consist of CRTC-regulated entities that have 100+ employees
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Class B3 and Class T3
Consist of CRTC-regulated entities that have 10 to 99 employees
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Class B4 and Class T4
Consist of CRTC-regulated entities that have fewer than 10 employees
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Class T5
Class T5 captures the entities that are exempt from the CRTC’s reseller registration requirement.
Consists of TSPs whose telecommunications service is limited to:
- a service offered without an explicit charge;
- a service offered on a temporary basis only to individuals located on the entity’s premises; or
- a service that does not allow individuals to engage autonomously in two-way voice telecommunications or to access the Internet autonomously.
The classes have different obligations under the Regulations.
Class B4 and T4 entities are exempt from obligations under the Regulations upon attestation to the CRTC (see below).
Class T5 entities are exempt from obligations under the Regulations and do not need to make an attestation to that effect.
Counting employees
In the Regulations, “employee” is defined as follows:
a person employed by a regulated entity referred to in paragraph 7(1)(e) or (f) of the Act and includes a dependent contractor, as defined in subsection 3(1) of the Canada Labour Code, but does not include:
- (a) a person employed under a program designated by the employer as a student employment program; and
- (b) a student employed solely during their vacation periods.
This definition excludes volunteers and some types of student employees, but does not exclude part-time employees, employees working remotely or employees located outside Canada. Entities should count the total number of employees, regardless of whether they are based in Canada or elsewhere.
Form 860: Attestation under the CRTC Accessibility Reporting Regulations
A regulated entity that could qualify as a member of classes B3/T3 or B4/T4 (i.e., that has a number of employees within the relevant range) must submit an attestation to the CRTC in order to be treated as a member of that class under the Regulations. A regulated entity that could qualify as a member of classes B3/T3 or B4/T4 but does not submit an attestation will be treated, by default, as a member of either class B1/T1 or B2/T2, as appropriate.
Unless the entity began operations after 2022, the Attestation under the CRTC Accessibility Reporting Regulations (Form 860) generally appears under the 2022 period in the entity’s My CRTC Account. The form needs to be submitted only once; this is not a form that must be completed on an annual basis.
Entities can revise their attestations should their circumstances change (i.e., should their employment levels fluctuate such that they would qualify for membership in another class). Filing a revised attestation voids any previous attestations filed by that regulated entity. To have the attestation form reissued, contact us at engagement@crtc.gc.ca.
Consult the list of providers that submitted the attestation form.
Technical issues
If you encounter issues accessing or using the data collection system (“My CRTC Account”) please see Support for My CRTC Account.
Please note that new users may require an activation code. To obtain an activation code, see the “New Users” section of Forms and My CRTC Account.
Still have questions
For more information about the requirements under the ACA and the Regulations, contact us at engagement@crtc.gc.ca.
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