Review Panel on the Lack of Accessible Housing in Canada
Introduction
Disability Without Poverty (DWP) welcomes the opportunity to contribute to the National Housing Council’s Review Panel on the Lack of Accessible Housing in Canada. We commend the Council for establishing this review under the National Housing Strategy Act (NHSA) and for centering the voices of people with disabilities and older adults who are disproportionately affected by Canada’s accessible housing crisis.
This submission responds to the four questions posed by the Review Panel, including the detailed sub-questions. It draws on publicly available research, federal data, international comparisons, and the lived experiences of communities we serve. We use terms like “accessible housing,” “adaptable housing,” and “disability” broadly and inclusively, consistent with the working definitions provided by the Panel.
Question 1: What is your vision for accessible housing in Canada and why?
DWP’s vision is a Canada where every person with a disability or age-related accessibility need can find safe, affordable, and suitable housing in their community of choice – housing that is not only physically accessible but located near the services, transportation, employment, and social connections that make independent community living possible. This means no more years-long waitlists, prohibitive costs, or impossible trade-offs between affordability, accessibility, and location.
At the core of this vision is the principle that new housing should be designed for accessibility from the start, rather than requiring costly retrofits after the fact. The publication of CAN/ASC-2.8:2025 (Accessible-Ready Housing) by Accessibility Standards Canada provides a clear technical benchmark. Our vision is that this standard becomes the baseline for all new residential construction across the country, not an optional aspiration.
But accessible design is only part of the equation. Truly accessible housing must also be in the right location: close to grocery stores offering affordable food options, near town and city centre hubs for access to services, and connected to public transportation so that people can reach medical appointments, visit family and friends, and participate in leisure and community life. An accessible unit in an isolated location without services or transit is not, in any meaningful sense, accessible housing.
This vision is grounded in rights. The National Housing Strategy Act recognizes the right to adequate housing. The Accessible Canada Act (ACA) envisions a barrier-free Canada by 2040. The UN Convention on the Rights of Persons with Disabilities (CRPD), which Canada has ratified, affirms the right to live independently and be included in the community. Accessible housing is not a special accommodation; it is a precondition for the exercise of these rights.
We also envision a system that works across the full spectrum of disability - including mobility, sensory, cognitive, and psychosocial - one that accounts for the intersecting barriers faced by Indigenous peoples, women, racialized communities, and those in rural and northern regions. Accessible housing must be understood not as a niche category but as good housing for everyone: families with young children, people recovering from injury, and the growing population of older Canadians who wish to age in place.
Question 2: How does the lack of accessible housing affect people living in Canada?
The lack of accessible housing affects people with disabilities in profound and compounding ways. It is not simply an inconvenience - it undermines health, dignity, independence, and participation in community life.
How has the lack of accessible housing affected you, your family, your community, your organization or someone you know?
Housing insecurity and impossible trade-offs
Statistics Canada data shows that persons with disabilities are more likely than the general population to live in core housing need. Persons with disabilities face especially acute pressures due to limited supply, affordability challenges, discrimination, and long waitlists for accessible or adapted units.
Across the country, people with disabilities report spending years on social housing waitlists, only to be offered units that do not meet their accessibility needs. Many are forced to choose between housing they can afford and housing they can physically use, accepting inaccessible units simply because nothing suitable is available, or paying far beyond their means for an adapted unit. Location adds yet another dimension to this trade-off: an affordable, physically accessible unit may be situated far from grocery stores, medical services, or public transit, effectively isolating the person from the community it is supposed to connect them to. The well-documented income gap experienced by Canadians with disabilities makes this trade-off especially punishing.
Are some groups of people affected differently than others, and how does it affect them?
Differential impacts on specific groups
The accessible housing crisis does not affect all groups equally. Indigenous persons with disabilities face compounding barriers: housing in First Nations, Inuit, and Métis communities is often in poor condition, overcrowded, and rarely built to accessibility standards. Women with disabilities - particularly those fleeing violence - face acute shortages of accessible emergency shelters and transitional housing. Racialized Canadians with disabilities encounter both disability-related and race-based discrimination in the rental market. People in rural and northern communities often find that accessible housing simply does not exist in their region, forcing relocation to urban centres and separation from family, cultural ties, and support networks. Older adults with emerging accessibility needs face a housing stock that was not designed to support aging in place, and the growing senior population means this gap will widen rapidly in the coming years.
What is the broader impact on other aspects of society or daily life?
Broader societal impacts
The lack of accessible housing has ripple effects well beyond housing itself. It strains the healthcare system: people living in inaccessible housing are at higher risk of falls, injuries, and preventable hospital admissions. It limits workforce participation, as people who cannot find accessible housing near employment centres, services, or transit routes are excluded from the labour market and from the daily rhythms of community life – shopping for affordable groceries, attending appointments, seeing friends and family, and accessing leisure and recreation. It increases reliance on institutional care - long-term care facilities and hospitals - when community-based living would be both more dignified and less costly. It undermines the social inclusion goals of the Accessible Canada Act and burdens families and informal caregivers who fill the gaps that housing systems leave. In short, the accessible housing deficit is not only a housing problem - it is a health, economic, and social participation problem.
Question 3: What system-wide gaps, and what government actions and inactions, are getting in the way of progress?
What is causing the shortage of accessible housing in Canada?
Causes of the shortage
The shortage has multiple root causes. Canada’s existing housing stock was overwhelmingly built before accessibility standards were meaningfully incorporated into building codes, leaving a legacy of inaccessible homes. The National Building Code has historically treated accessibility as a minimum-compliance exercise focused on common areas of multi-unit buildings rather than individual dwelling units, meaning even brand-new apartments may have an accessible lobby but inaccessible bathrooms. Retrofitting existing homes is expensive and there is no dedicated, adequately funded federal program to support it. Meanwhile, private developers have little incentive to exceed minimum code requirements, and accessible design is still treated as a cost rather than a standard feature. There is also a planning gap: even where accessible units are built, zoning and land-use decisions often place them in peripheral locations, disconnected from the grocery stores, service hubs, and transit systems that people with disabilities depend on to live independently.
How do governments make it easier or harder for people to find accessible housing?
Fragmented jurisdiction and weak federal leverage
Housing policy in Canada is divided across federal, provincial, and municipal jurisdictions. The Accessible Canada Act (2019) set the goal of a barrier-free Canada by 2040, but it does not directly govern provincial building codes or municipal zoning. The CAN/ASC-2.8:2025 standard is an important reference point, but without a mechanism to incentivize or require provincial adoption, uptake will remain inconsistent. The federal government has significant leverage through funding programs under the National Housing Strategy, yet the accessibility requirements attached to these funds have been modest and inconsistently enforced.
Program design choices can also create barriers. Access criteria, application processes, and documentation requirements are often complex and inconsistent across jurisdictions, making it harder for people with disabilities to secure timely support.
Do people face barriers or discrimination when trying to access accessible housing?
Discrimination and attitudinal barriers
People with disabilities face significant discrimination in the housing market. The Canadian Human Rights Commission reports that disability remains the most common ground for human rights complaints in Canada. In housing specifically, discrimination may take the form of landlords refusing to rent to people with disabilities, failing to fulfill the duty to accommodate (for example, refusing reasonable modification requests), harassing tenants with mental health conditions, or permitting substandard living conditions. The Ontario Human Rights Commission has documented patterns of both overt and systemic discrimination against tenants with disabilities. These barriers are compounded for people who face intersecting forms of discrimination based on race, gender, Indigenous identity, or income level. The result is that even when accessible units exist, discriminatory practices and attitudes can block people from accessing them.
Are there gaps in housing policies or standards that make this worse for those who need it most?
Gaps in data, targets, and accountability
Canada lacks a national registry or inventory of accessible housing units. There is no systematic way for a person with a disability to find available, suitable housing in their community. While CMHC began collecting data on barrier-free housing through the Social and Affordable Housing Survey in 2022, this data is limited in scope and does not cover the private market. Without comprehensive data, governments cannot set meaningful targets, allocate resources effectively, or measure progress.
The National Housing Strategy (NHS) has allocated significant funding since 2017, yet accessibility has not been a central pillar. CMHC reporting suggests that accessibility-focused housing commitments remain modest relative to the scale of need. The National Housing Strategy still lacks clear, binding accessibility targets, dedicated streams focused specifically on accessible housing, and strong enforcement mechanisms tied to accessibility outcomes.
Question 4: What actions and solutions should governments and communities lead?
DWP offers the following recommendations. Consistent with the Panel’s guidance, these are designed to be practical, scalable, and applicable across all regions of Canada. We organize them into immediate actions and longer-term systemic changes.
What would help increase the amount of accessible housing in Canada?
Increasing supply
- Mandate accessible-ready design in the National Building Code.
The federal government should work with the Canadian Board for Harmonized Construction Codes to incorporate the CAN/ASC-2.8:2025 standard into the next edition of the National Building Code, making accessible-ready design the default for all new residential construction. This is the single most impactful long-term action to prevent the accessible housing deficit from growing. - Tie National Housing Strategy (NHS) funding to accessibility outcomes.
A meaningful and increasing percentage of all units funded through National Housing Strategy programs should be required to meet or exceed the CAN/ASC-2.8:2025 standard. This percentage should be set in consultation with the disability community and escalate over time. Accessibility should be a core funding criterion, not an optional checklist item. Funding criteria should also account for location, prioritizing projects that are well-connected to public transit, essential services, grocery stores, and community hubs – recognizing that accessible housing must enable people to live in the community, not merely to be housed. - Create a dedicated accessibility retrofit fund.
A standalone federal fund should support home modifications for people with disabilities and older adults. Unlike the current patchwork of programs, this fund should be needs-based, easy to access, cover a broad range of modifications, from grab bars to full-unit renovations, and minimize burdensome documentation requirements.
What should governments do now and over the long-term to improve accessible housing?
Systemic and institutional reforms
- Establish a national accessible housing registry.
CMHC, in partnership with provinces, territories, and municipalities, should develop and maintain a publicly searchable national database of accessible housing units - covering social, non-profit, and private-market rentals. This would help people with disabilities find suitable housing and enable governments to track supply against demand and set evidence-based targets. - Invest in data collection and public accountability.
The federal government should fund a comprehensive national survey of accessible housing supply and establish annual public reporting requirements tied to clear, measurable targets. Without data, there is no accountability. - Strengthen anti-discrimination enforcement in housing.
Governments should invest in proactive enforcement of the duty to accommodate in housing, provide accessible complaint mechanisms for tenants with disabilities, and fund education and outreach to landlords and property managers about their legal obligations. Human rights commissions should be resourced to address housing-related disability complaints in a timely manner. - Apply an intersectional lens to all housing programs.
All federal housing programs should apply GBA Plus analysis with specific attention to disability, ensuring that program design addresses the compounding barriers faced by Indigenous persons with disabilities, women with disabilities, and those in rural and northern communities. Solutions must work for those at the intersection of multiple forms of marginalization.
Are there good examples of initiatives here or outside Canada that are increasing accessible housing?
Examples from Canada and internationally
Several jurisdictions offer instructive models that Canada can learn from:
• United Kingdom – Part M of the Building Regulations: The UK mandates that all new homes meet a baseline “visitable” accessibility standard (Category M4(1)), with local authorities able to require higher standards accessible and adaptable dwellings (M4(2)) or full wheelchair-user dwellings (M4(3))-based on local needs assessments. This tiered, mandatory approach provides a clear model for how Canada could implement the CAN/ASC-2.8:2025 standard through the National Building Code.
• Australia – National Construction Code: After years of relying on voluntary guidelines that failed to produce sufficient progress, Australia moved to incorporate minimum accessibility provisions for new housing into the National Construction Code. The Australian experience shows the limits of voluntary approaches and the value of embedding accessibility requirements in mainstream building rules.
• British Columbia – Adaptable Housing Requirements: Several BC municipalities, including the City of Vancouver, have adopted adaptable housing requirements for new multi-unit developments, requiring features like blocking for future grab bars, wider doorways, and accessible bathroom layouts. These requirements show that sub-national jurisdictions can lead when federal or provincial codes lag.
• Ontario – Accessibility for Ontarians with Disabilities Act (AODA): While the AODA has been criticized for slow implementation, its framework of phased, enforceable accessibility standards across sectors offers lessons on how governments can build accountability mechanisms for accessibility commitments.
These examples demonstrate that progress is possible when governments move from voluntary guidelines to mandatory, enforceable standards, and when accessibility is treated as a default feature of good housing rather than a specialized add-on.
Conclusion
The lack of accessible housing in Canada is not merely a supply problem - it is a human rights issue that touches every dimension of life for people with disabilities. It affects health, employment, social participation, safety, and dignity. It falls hardest on those who already face the greatest barriers: Indigenous peoples, women, racialized communities, and those in rural and northern regions.
The legislative framework exists: the National Housing Strategy Act, the Accessible Canada Act, and Canada’s international commitments all affirm the right to adequate, accessible housing. What is needed now is the political will and institutional commitment to implement these principles at the scale the crisis demands – through mandatory building standards, dedicated funding, better data, stronger enforcement, and programs designed to reach the people who need them most.
Accessible housing is not simply a matter of building an affordable unit with a ramp. It means housing that allows people with disabilities to live in their communities: near services, near transit, near the people and places that make life worth living.
Disability Without Poverty urges the Review Panel to deliver bold, actionable recommendations to the Minister. We thank Panel members Simon April, Teresa Goldstein, and Sam Watts for their service, and we look forward to continuing this dialogue through the oral hearing process.
References and Resources
• Accessibility Standards Canada, CAN/ASC-2.8:2025 – Accessible-Ready Housing (2025). https://accessible.canada.ca/creating-accessibility-standards/can-asc-282025-accessible-ready-housing
• Canadian Human Rights Commission, Monitoring the Right to Housing for People with Disabilities – Discrimination and Dignity. https://www.chrc-ccdp.gc.ca/resources/publications/monitoring-the-right-housing-people-disabilities/discrimination-and-dignity-monitoring-the-right-to-housing-for-people-with-disabilities
• Canadian Human Rights Commission, Monitoring the Right to Housing for People with Disabilities – Accessibility. https://www.chrc-ccdp.gc.ca/resources/publications/monitoring-the-right-housing-people-disabilities/accessibility-monitoring-the-right-to-housing-for-people-with-disabilities
• CMHC, 2026–2028 Accessibility Plan. https://www.cmhc-schl.gc.ca/about-us/corporate-reporting/transparency/accessibility-at-cmhc/2026-2028-accessibility-plan
• CMHC, Core Housing Need Data – By the Numbers. https://www.cmhc-schl.gc.ca/professionals/housing-markets-data-and-research/housing-research/core-housing-need/core-housing-need-data-by-the-numbers
• CRESA (New Zealand), International Trends in Accessible Housing for People with Disabilities. https://cresa.co.nz/wp-content/uploads/2020/12/working-paper-2.pdf
• Housing, Infrastructure and Communities Canada, Accessibility Plan 2026–28. https://housing-infrastructure.canada.ca/accessibility-accessibilite/plans/2026-2028-plan-eng.html
• Ontario Human Rights Commission, Discrimination Based on Disability and the Duty to Accommodate: Information for Housing Providers. https://www3.ohrc.on.ca/en/discrimination-based-disability-and-duty-accommodate-information-for-housing-providers
• Statistics Canada, Housing Experiences in Canada: Persons with Disabilities (2021). https://www150.statcan.gc.ca/n1/pub/46-28-0001/2021001/article/00011-eng.htm
• UK Government, Raising Accessibility Standards for New Homes: Consultation Response. https://www.gov.uk/government/consultations/raising-accessibility-standards-for-new-homes/outcome/raising-accessibility-standards-for-new-homes-summary-of-consultation-responses-and-government-response
• University of British Columbia (CIIC), Disability Housing in Canada: A Jurisdictional Scan (January 2025). https://ciic.ok.ubc.ca/wp-content/uploads/sites/212/2025/06/Disability-Housing-in-Canada-A-Jurisdictional-Scan-January-2025-F.pdf