Written Submission for 2026 Pre-Budget Consultations

Recommendations

Recommendation 1: That the government guarantee income adequacy by increasing the Canada Disability Benefit to a level that ends disability poverty.

Recommendation 2: That the government replace the restrictive DTC disability definition with a new broader definition and grant automatic DTC eligibility to individuals receiving disability benefits through provincial/territorial social assistance programs.

Recommendation 3: That the government commit to direct reimbursement of medical practitioners for completing DTC applications.

Recommendation 4: That the government replace the DTC application with a streamlined, plain-language form.

Recommendation 5: That the government reduce the use of unnecessary temporary DTC certificates and establish a simplified renewal process nationwide.

Introduction

As the point of access to 17 federal disability programs and a growing number at the provincial and territorial level, the Disability Tax Credit (DTC) has become Canada's primary gateway to disability supports.

Unfortunately, this gateway is too narrow for some and too difficult to navigate for others. Statistics Canada estimates the DTC is claimed by 14.6 per cent of persons with disabilities, and this number increases to only 19.5 per cent of persons with severe disabilities and 34.8 per cent of those with very severe disabilities.[1]

Disability supports should be available to all people with disabilities who need them, and no eligible recipient should be denied access because of administrative or financial barriers.

Since we made this case to the House of Commons Standing Committee on Finance in April 2026, the federal government has taken encouraging steps. The Spring Economic Update 2026 announced measures expected to unlock an estimated $345 million in support over six years for people facing access barriers, and the draft legislative proposals released on July 23, 2026 would expand the list of practitioners who can certify DTC eligibility and streamline certification for people with certain long-lasting conditions.[2][3]
 
We welcome these reforms – they are a solid foundation on which to build. But they do not change the benefit amounts people receive, nor the restrictive definition that keeps hundreds of thousands of people with disabilities outside the system altogether.

Canada's Disability Inclusion Action Plan promises a modern approach to defining disability across the federal government and solutions to the challenges that people with disabilities face in accessing federal programs and benefits.[4]

Budget 2026 should advance this commitment through the following priority actions:

1. Guarantee income adequacy by increasing the Canada Disability Benefit to a level that ends disability poverty.

The Canada Disability Benefit Act commits the federal government to reducing poverty and supporting the financial security of working-age persons with disabilities. The current benefit amount falls dramatically short of that legislative objective. At a maximum of $200 per month ($2,400 per year), the Canada Disability Benefit will not lift recipients out of poverty in any province or territory.[5]

People with disabilities are twice as likely to live in poverty as Canadians without disabilities, and the costs of living with a disability – including medications, devices, therapies, accessible housing, and transportation – are substantially higher than for the general population.[6] A benefit of this size cannot meaningfully close that gap.

Budget 2026 should commit to a clear, time-bound plan to raise the Canada Disability Benefit to a level that achieves the legislative objectives of the Act: one that meets basic needs, improves the financial security of people with disabilities, and, together with provincial and territorial supports, ends disability poverty in Canada. The federal government should also ensure that the benefit is not clawed back by other income supports, insurance providers, or tax measures, and that income thresholds and eligibility rules do not exclude people living in deepest poverty.

2. Replace the restrictive DTC disability definition with a new broader definition and grant automatic DTC eligibility to individuals receiving disability benefits through provincial/territorial social assistance programs.

The Disability Tax Credit uses a particularly complex definition of disability considered to be among the most restrictive of all disability support programs in Canada.[7] As a result, it shuts out hundreds of thousands of people with disabilities who qualify for a disability-related social assistance program.

The July 2026 draft legislation takes a first step in this direction: it would recognize provincial incapacity determinations for people under public guardianship or trusteeship, and create a streamlined certification pathway for an enumerated list of conditions.[8] But these provisions reach only a fraction of the people the DTC currently excludes. The same logic – trusting determinations that a public authority has already made – should be extended to everyone receiving disability benefits through provincial and territorial social assistance programs.

Budget 2026 should commit to a process for broadening the definition of disability so it is inclusive of all provincial and territorial disability definitions, ensuring that a person receiving disability support through social assistance in any province or territory will also qualify for federal benefits. Once a broader definition is in place, the federal government should work with provinces and territories to create a seamless data sharing process to facilitate automatic qualification for federal disability benefits.

3. Commit to direct federal reimbursement of medical practitioners for completing DTC applications, similar to CPP Disability applications.

Another critical barrier is the fees that medical practitioners charge for completing the DTC form. The federal government recently calculated an average fee of $125 based on a review of fee schedules; however, experience from frontline organizations across the country suggests fees are often much higher, especially for complex cases.

The one-time $150 supplemental payment to Canada Disability Benefit recipients announced for September 2026 is a welcome acknowledgment of this barrier, but it is not a solution: it arrives after the fact, reaches only those who have already succeeded in qualifying, and leaves out applicants who cannot afford the up-front cost in the first place.[9] Budget 2026 should commit to direct federal reimbursement of medical practitioners – something already in place for practitioners who complete CPP Disability applications.[10]

4. Replace the DTC application with a streamlined, plain-language form.

No government program should be so burdensome that it gives rise to a for-profit industry of “promoters” devoted solely to providing navigation support, yet this describes the DTC today. An overhaul is long overdue.

On average, it takes a physician more than 36 minutes to complete their portion of the initial DTC application.[11] In complex situations, it can take hours. Despite small improvements, the form remains overly long, complex, and poorly designed. It should be replaced with a new streamlined, plain-language application, tested with people with disabilities. Functional assessment questions should be consolidated to reduce duplication and confusion, and applicants should be empowered to complete the functional assessments themselves, with clinicians confirming accuracy rather than acting as form writers.

5. Reduce the use of unnecessary temporary DTC certificates and establish a simplified renewal process nationwide.

Too many DTC recipients are forced to repeat the application multiple times. About one-third of DTC certificates received in 2022 were temporary in nature, and there is evidence that some temporary certificates are awarded to people with lifelong disabilities whose circumstances are highly unlikely to change.[12] Requiring repeated applications causes unnecessary stress and expense for applicants and for our health system.

The streamlined certification pathway in the July 2026 draft legislation should reduce reassessment for people with the listed conditions – provided certifications under it are indefinite in duration. Budget 2026 should confirm this, commit to reducing the use of unnecessary temporary certificates more broadly, and establish a simplified renewal process nationwide, building on the Manitoba pilot.[13]

Conclusion

Budget 2026 is the government's opportunity to match the encouraging administrative reforms of the past year with the structural change that ends disability poverty: an adequate Canada Disability Benefit and a disability eligibility system that includes everyone it is meant to serve. Disability Without Poverty and our partners across the disability and health care communities stand ready to work with the government to get this done – nothing about us without us.

 


References

[1] McDairmid, C. & Choi, R. (2026). Technical report on disability measurement in Canada. Statistics Canada. https://www150.statcan.gc.ca/n1/pub/89-654-x/89-654-x2026001-eng.htm
[2] Government of Canada. (2026). Canada Strong for All: Spring Economic Update 2026. https://budget.canada.ca/update-miseajour/2026/report-rapport/tm-mf-en…
[3] Department of Finance Canada. (July 23, 2026). Legislative Proposals Relating to the Income Tax Act and the Income Tax Regulations (Budget 2025 and other proposals). https://www.canada.ca/en/department-finance/corporate/laws-regulations/…
[4] Government of Canada. (2022). Canada’s Disability Inclusion Action Plan. https://www.canada.ca/en/employment-social-development/programs/disabil…
[5] Maytree. (2026). Social Assistance Summaries, 2025. https://maytree.com/publications/social-assistance-summaries-2025-lates…;
[6] Statistics Canada. (2024). A demographic, employment and income profile of persons with disabilities aged 15 years and over in Canada, 2022. https://www150.statcan.gc.ca/n1/pub/89-654-x/89-654-x2024001-eng.htm
[7] Oliveira, T. & White, A. (March 2026). “Definitions of Disability” (within Social Assistance Summaries, 2025). Maytree. https://maytree.com/changing-systems/data-measuring/social-assistance-s…
[8] Department of Finance Canada, Legislative Proposals Relating to the Income Tax Act and the Income Tax Regulations (see note 3).
[9] Government of Canada, Canada Strong for All: Spring Economic Update 2026 (see note 2).
[10] Government of Canada. (2026). “Information for health care professionals” (CPP Disability). https://www.canada.ca/en/services/benefits/publicpensions/cpp-disabilit…
[11] Disability Without Poverty et al. (2026). Fix the Disability Tax Credit (DTC): Urgent Reform Needed to Support Canadians. https://www.disabilitywithoutpoverty.ca/en/dwp-media/fix-disability-tax…
[12] Disability Advisory Committee. (2024). Fifth Annual Report of the Disability Advisory Committee. https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-…
[13] Doctors Manitoba. (2025). Manitoba Pilots Shorter DTC Renewal Form. http://doctorsmanitoba.ca/news/mb-pilots-shorter-dtc-form