Who must comply with Manitoba's information and communication standard

Manitoba's Accessible Information and Communication Standard Regulation, Man. Reg. 47/2022, applies to far more organizations than many people expect. This article explains who is covered, when the obligations started, what extra duties fall on large employers, and how to think through some common situations.

The one-employee threshold

The regulation phases in its obligations by type of organization. For most private businesses and non-profits, the relevant clause is s. 2(c) (opens in a new tab): it covers any other organization under The Accessibility for Manitobans Act that has at least one employee in Manitoba, starting three years after the regulation came into force. The regulation came into force on May 1, 2022 (s. 15 (opens in a new tab)), so that date was May 1, 2025.

There is no revenue test and no exemption for being small. One employee is enough.

What "organization" means

The regulation does not define "organization" itself. The definition is in s. 1 (opens in a new tab) of the Act, and it is broad. It covers organizations in the public or private sector, including government and its agencies, entities created under an Act, unincorporated associations, partnerships, sole proprietorships and trade unions, along with any other type of entity prescribed by regulation.

In practice, that means the legal structure of your business is unlikely to take you outside the definition. A corporation, a partnership, a sole proprietorship and a community association can all be organizations. Whether the standard applies then turns mainly on the employee threshold in s. 2(c) (opens in a new tab).

Public sector and private sector timing

Section 2 (opens in a new tab) set out three start dates, based on the regulation's May 1, 2022 coming-into-force date.

All three dates have now passed.

Extra duties for large employers

The regulation defines a large employer as one with at least 50 employees. For a seasonal workplace, the count is 50 employees doing work expected to last at least 90 days. Large employers, along with the public sector organizations in s. 2(a) (opens in a new tab) and (b), carry two additional documentation duties.

• Documented measures, policies and practices (s. 3(2) (opens in a new tab)). Every covered organization must establish and carry out measures, policies and practices on accessible communication (s. 3(1) (opens in a new tab)). Large employers must also put them in writing and make the documented policies publicly available.
• A documented training policy (s. 4(4) (opens in a new tab)). Large employers must create and document a training policy that states when training is given and summarizes what it covers. Our article on staff training explains the training duty in more detail.

Smaller organizations still have to have measures, policies and practices, and still have to train staff. They are simply not required by s. 3(2) (opens in a new tab) and s. 4(4) (opens in a new tab) to document them.

Does this apply to us?

The regulation does not address every situation directly. The notes below reflect our reading of the text. Where the wording is not explicit, we say so. If your situation is close to the line, read the definitions in s. 1 (opens in a new tab) of the Act and s. 1 (opens in a new tab) of the regulation, and consider asking a lawyer.

• A sole proprietor with no employees. A sole proprietorship is an organization under the Act, but s. 2(c) (opens in a new tab) refers to organizations with at least one employee in Manitoba. On that wording, a sole proprietor with no employees does not appear to fall within s. 2(c) (opens in a new tab). That changes once you hire someone. Note that the regulation does not define "employee", so it is worth checking how your working arrangements would be viewed.
• A business based outside Manitoba with staff in Manitoba. Section 2(c) (opens in a new tab) turns on having an employee in Manitoba, not on where the head office is. An out-of-province business with Manitoba staff appears to meet that test. The Act does not contain a clear territorial application clause, so how far the obligations reach for such businesses is not spelled out. Treat it as likely in scope and get advice if it matters to you.
• A Manitoba business with only contractors. Whether contractors count as employees is not addressed in the regulation. Seek advice before relying on this.
• A non-profit with one paid coordinator and many volunteers. The paid coordinator likely meets the one-employee threshold. Volunteers who speak publicly for the organization are also named in the training duty in s. 4(1)(a) (opens in a new tab).
• A business with seasonal staff. Seasonal employees appear to count toward the one-employee threshold. They also matter for the large employer definition, which has a specific rule for seasonal workplaces.
• A franchise location. The organization that employs the Manitoba staff appears to be covered. Who controls the website matters for the s. 7(2)(d) (opens in a new tab) "no direct control" exception, which we discuss in our article on exceptions.

What being covered means

If you are covered, the core duties are web content that meets WCAG 2.1 Level AA (s. 7(1) (opens in a new tab)), accessible web applications where s. 8(1) (opens in a new tab) applies, a notice that information is available in accessible formats and with communication supports (s. 5 (opens in a new tab)), a feedback process (s. 9 (opens in a new tab)) and training (s. 4 (opens in a new tab)). Our page on the Manitoba standard walks through each one, and our article on feedback and accessible formats covers the two duties most often missed.

Next steps

If you have concluded that the standard applies, the next step is to find out where your website stands. Our services page explains what an audit covers, and the FAQ answers common questions about scope. If you are unsure whether you are covered, contact us and we will talk it through plainly. For a definite answer on your legal position, speak with a lawyer.

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