How enforcement works under The Accessibility for Manitobans Act

Questions about enforcement often come with some anxiety. It helps to know how the process actually works. Under The Accessibility for Manitobans Act, C.C.S.M. c. A1.7, enforcement is a sequence of steps. A fine is not the first thing that happens. This article sets out each step, then explains what to do if you receive a compliance order.

Inspections (ss. 23 (opens in a new tab)-26 (opens in a new tab))

The Act allows the minister to appoint inspectors (s. 23 (opens in a new tab)). Inspectors can carry out inspections reasonably required to check compliance with the Act and its standards (s. 24 (opens in a new tab)).

During an inspection, an inspector can ask for records and other information. The person in charge must produce the records required, give reasonable assistance and answer questions in writing on request (s. 24(5) (opens in a new tab)). Inspectors can ask for electronic records in a readable form and make copies. Certified copies can be used as evidence (s. 25 (opens in a new tab)).

A dwelling used as a residence cannot be entered without consent or a warrant. Section 26 (opens in a new tab) allows a justice to issue a warrant where entry has been refused or refusal is expected.

For a website, the relevant records are likely to be things like audit results, notes on repairs, your accessible formats notice, your feedback records and, for large employers, documented policies. This is one reason keeping records matters.

Compliance orders (s. 27 (opens in a new tab))

If an inspector finds a contravention of the Act or a regulation, they may issue a written order requiring it to be remedied (s. 27(1) (opens in a new tab)). Under s. 27(2) (opens in a new tab), the order must:

• name the person or organization it is directed to,
• describe the contravention,
• explain what must be done to comply,
• set the time period for compliance,
• warn that an administrative penalty may be required if the order is not complied with,
• state that a written review by the director may be requested, and
• give the address for filing that request.

The Act does not set a fixed compliance period. The order itself states it.

Administrative penalties (s. 29 (opens in a new tab))

An administrative penalty can follow only if an order is not complied with within the time it specifies (s. 29(1) (opens in a new tab)). The amount is set by regulation rather than in the Act. A penalty notice may be issued only after the appeal period has passed or, if an appeal is filed, after it is decided (s. 29(2) (opens in a new tab)).

Public reporting (s. 32 (opens in a new tab))

The director may publish reports with detailed information about orders and administrative penalties (s. 32 (opens in a new tab)). Those reports may include personal information. For many organizations, the reputational effect of being named may matter as much as any penalty.

Offences and fines (s. 34 (opens in a new tab))

Section 34(1) (opens in a new tab) sets out offences, including failing to comply with a standard, failing to keep or produce records, knowingly making false or misleading statements and obstructing an inspector or the director.

On summary conviction, a fine can be up to $250,000 (s. 34(3) (opens in a new tab)). That is a maximum. It is not the amount that applies in every case.

Where a corporation commits an offence, its directors, officers, employees or agents who authorized, permitted or acquiesced in it can also be guilty of an offence. This applies whether or not the corporation itself is prosecuted or convicted (s. 34(2) (opens in a new tab)). Responsibility for compliance therefore sits with the people who run an organization, not only with the organization itself.

If you receive a compliance order

An order is a serious document, but it is also a clear one. It tells you what the problem is, what must be done and by when. A calm, organized response is the best approach.

1. Read it carefully and note the dates. Write down the compliance deadline. Under s. 28 (opens in a new tab), a written request for review by the director must be received within 14 days after the order is served, or the order becomes final.
2. Get legal advice early. A lawyer can tell you whether a review request makes sense and what your options are. Do this before the review period passes.
3. Understand exactly what is required. If the order refers to web content, identify which pages, documents or features are involved and which requirement they relate to.
4. Get a proper assessment. An audit against WCAG 2.1 Level AA, using manual keyboard and screen reader testing as well as automated scans, will show the full extent of the work. Our services page explains what that involves.
5. Plan the work against the deadline. Fix the issues named in the order first, then other barriers that block key tasks.
6. Keep records. Note what was tested, what was fixed and when. These records help you show that you have complied.
7. Do not rely on quick fixes. Overlay widgets do not meet the standard on their own. Repairs to the underlying site are what count.

The practical picture

An organization that understands its obligations, has assessed its website and is working through the fixes in good faith is in a very different position from one that has done nothing, or one that ignores an order. Our guide to the Manitoba standard explains what is required, and the FAQ covers common questions. If you have received an order, or want to make sure you never do, contact us.

Last reviewed October 2026. General information, not legal advice.