Staff training under Manitoba's accessibility standard

A website that meets WCAG 2.1 Level AA can still let customers down if the people behind it do not know how to keep it that way, or how to respond when someone asks for information in another format. That is why the Accessible Information and Communication Standard Regulation, Man. Reg. 47/2022, includes a training duty in s. 4 (opens in a new tab). This article explains who needs training, what it should cover, when it is due and what large employers must put in writing.

Who needs training

Section 4(1) (opens in a new tab) requires an organization to ensure training is provided to five groups of people.

1. People who communicate on the organization's behalf with the public or with other organizations in Manitoba. The regulation names employees, agents and volunteers (s. 4(1)(a) (opens in a new tab)).
2. Educators, if the organization is an educational institution (s. 4(1)(b) (opens in a new tab)).
3. People who build or maintain web content (s. 4(1)(c) (opens in a new tab)).
4. People who buy or procure information and communication technology (s. 4(1)(d) (opens in a new tab)).
5. People who develop or carry out the organization's accessible communication measures, policies and practices (s. 4(1)(e) (opens in a new tab)).

In a small business, these roles often belong to the same few people. The owner may answer customer emails, update the website, choose the booking software and write the accessibility policy. Volunteers are named explicitly, which matters for non-profits and community groups.

The duty applies to people doing the work for the organization. If an outside agency maintains your website, it is worth considering how training for those people is handled. Asking a provider what accessibility training its staff have is a reasonable question.

What training should cover

Section 4(2) (opens in a new tab) sets out three topics.

• Identifying, preventing and removing barriers to communication.
• Providing information using communication supports or in accessible formats.
• A review of The Human Rights Code, The Accessibility for Manitobans Act and the regulation itself.

The regulation does not prescribe a length, format or provider. Training can be tailored to what each person does. Someone who answers the phone needs to know how to handle a request for large print or a plain language explanation. Someone who edits the website needs more practical detail.

Practical topics for people who maintain web content

• Writing meaningful alternative text for images, and knowing when an image is decorative.
• Using real headings in order rather than bold text styled to look like headings.
• Writing link text that makes sense on its own, rather than "click here".
• Checking colour contrast: 4.5:1 for normal text, and 3:1 for large text and for interface components and graphics.
• Captioning videos and providing transcripts for audio.
• Checking that a PDF is accessible before posting it, or providing the information as a web page instead.
• Testing a new page with a keyboard alone.

Practical topics for people who buy technology

• Asking vendors whether their product meets WCAG 2.1 Level AA, and asking for evidence.
• Testing a demo with a keyboard before committing.
• Understanding that a new or significantly updated web application, such as a booking tool or customer portal, falls under s. 8(1) (opens in a new tab).

Timing

Under s. 4(3)(a) (opens in a new tab), training must be provided as soon as reasonably practicable after a person takes on the relevant duties. The regulation does not set a fixed number of days, so "reasonably practicable" will depend on the circumstances. Building it into onboarding is a straightforward way to meet it.

Training is not a one-time event. Section 4(3)(b) (opens in a new tab) requires ongoing training when the organization changes its accessible communication measures, policies or practices. If you introduce a new feedback process or change how you handle requests for accessible formats, the people affected should be told how it works.

Records for large employers

Large employers, meaning employers with at least 50 employees, have an extra duty under s. 4(4) (opens in a new tab). Organizations in s. 2(a) (opens in a new tab) and (b), the public sector bodies covered earlier, share it. They must create and document a training policy that:

• states when training is provided, and
• includes a summary of the training content.

Smaller organizations are not required by s. 4(4) (opens in a new tab) to document a training policy. Keeping a simple record is still useful: who was trained, when and on what. If questions are ever asked, for example during an inspection under the Act, a short record is far easier to rely on than memory. Our article on enforcement explains how inspections work.

Next steps

Start by listing who in your organization falls into each of the five groups. Then decide what each person needs to know and when they will receive it. Our article on feedback and accessible formats covers two practices front-line staff should understand, and our guide to the Manitoba standard covers the rest. If you would like a clear picture of where your website stands before training your team, see our services or contact us.

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