Background
In 2024, the Office of the Commissioner of Lobbying (OCL) requested to Share Services Canada’s Accessibility, Accommodation and Adaptative Computer Technology (AAACT) program to evaluate the Lobbyists Registration System (account creation and login processes) on its accessibility and usability for people with disabilities. The final report was completed in October 2024.
Objective
The objective of this document is to present the management response and action plan based on the comments, issues noted, or warnings made in the AAACT’s report on the accessibility evaluation of the Registry of Lobbyists.
1. Usability comments
| Comment #1 |
| Redundant tooltips |
|
| Action |
Responsible official |
Target completion date |
| Remove all tooltips that repeat the existing text. |
Manager, IT Operations and System Management |
2025-12-31 |
| Comment #2 |
| Redundant or repetitive text in elements with wb-inv class |
|
| Action |
Responsible official |
Target completion date |
| Aria-labels or the wb-inv WET4 class should not be used to repeat what is already available to screen reader users. |
Manager, IT Operations and System Management |
2025-12-31 |
| Comment #3 |
| On 200% resize, a menu that was not shown normally appears and it does not work with keyboard |
|
| Action |
Responsible official |
Target completion date |
| When a user starts the account creation process and uses the screen at 200% zoom, a menu not normally there appears. That menu is not keyboard operable. A solution could be to prevent it from appearing. |
Manager, IT Operations and System Management |
2025-12-31 |
| Comment #4 |
| HTML entities and HTML elements with delimiters are showing up in French error messages |
|
| Action |
Responsible official |
Target completion date |
| Modify French character entities and HTML entities to the appropriate Unicode equivalent for CSS or JavaScript files (as HTML entities do not work in those). |
Manager, IT Operations and System Management |
2025-12-31 |
| Comment #5 |
| CAPTCHAs are very difficult to pass |
|
| Action |
Responsible official |
Target completion date |
| Review the use of CAPTCHAs v2 (current) versus the use of reCAPTCHA v3 | Google for Developers. |
Manager, IT Operations and System Management |
2025-12-31 |
| Review and modify CAPTCHA visibility (pixels), if required. |
| Review and modify CAPTCHA definitions of images, if required. |
| Review audible versions, identify words that are read out and type them without misspelling, if required. |
2. Adaptable
2.1 Info and Relationships (Level A)
| Issue #1 |
| Use of <caption> elements on layout tables |
|
| Action |
Responsible official |
Target completion date |
| Review the use of tables for layout purposes, and the use of the caption element (only used for semantic meaning). Consider the use of tableless design in forms. |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #2 |
| Text styled as a heading is not marked up as such |
|
| Action |
Responsible official |
Target completion date |
| Review the HTML heading elements on the search results screen to ensure hierarchical relationship between sections and subsections of content. |
Manager, IT Operations and System Management |
2025-12-31 |
2.2 Meaningful Sequence (Level A)
| Warning #1 |
| Buttons precede explanations instead of being located after them |
|
| Action |
Responsible official |
Target completion date |
|
Review the positioning of the “Select” buttons in relation to the explanatory texts.
|
Manager, IT Operations and System Management |
2025-12-31 |
2.3 Sensory Characteristics (Level A)
| Issue #1 |
| Use of graphical symbols only to denote required fields |
|
| Action |
Responsible official |
Target completion date |
|
Review mandatory fields with asterisks and ensure they are clearly identified as required. A solution could be to identify fields or define asterisks using a legend.
|
Manager, IT Operations and System Management |
2025-12-31 |
2.4 Identify Input Purpose (WCAG 2.1 Level A)
| Issue #1 |
| Lack of autocomplete attributes |
|
| Action |
Responsible official |
Target completion date |
|
Review the possibility of adding the appropriate autocomplete attributes to the following fields on applicable forms:
- First name
- Last name
- Position title
- Preferred language
- English organization or corporation name
- Country
- Street address 1 and 2
- City
- Province
- Postal Code
- Telephone
- Extension
- Facsimile
- Email address
- Confirm email address
|
Manager, IT Operations and System Management |
2025-12-31 |
3. Distinguishable
3.1 Contrast (Minimum) (Level AA)
| Issue #1 |
| Text colour not satisfying the minimum required contrast ratio |
|
| Action |
Responsible official |
Target completion date |
| Change error message text to a darker tone for all large text to satisfy the 3:1 contrast ratio. |
Manager, IT Operations and System Management |
2025-12-31 |
3.2 Non-Text Contrast (WCAG 2.1 Level AA)
| Issue #1 |
| User interface component colour not satisfying the minimum required contrast ratio |
|
| Action |
Responsible official |
Target completion date |
|
Remove the opacity property/value pair from the mfp-close class to satisfy the 3:1 contrast ratio.
|
Manager, IT Operations and System Management |
2025-12-31 |
4. Keyboard accessible
4.1 Keyboard (Level A)
| Issue #1 |
| Sets of toggle buttons cannot be operated by keyboard |
|
| Action |
Responsible official |
Target completion date |
| Ensure the toggle buttons can be operated by keyboard (ex: toggle buttons that allow users to show and hide the password fields). |
Manager, IT Operations and System Management |
2025-12-31 |
5. Navigable
5.1 Focus Order (Level A)
| Warning #1 |
| Focus order not aligned with visual order |
|
| Action |
Responsible official |
Target completion date |
| Ensure across the LRS that primary buttons are placed before secondary buttons and that focus is respected (ex: Continue versus Cancel). |
Manager, IT Operations and System Management |
2025-12-31 |
5.2 Link Purpose (In Context) (Level A)
| Issue #1 |
| Pagination link text not descriptive |
|
| Action |
Responsible official |
Target completion date |
| Change pagination numbers to identify and provide context that they contain more results from a search. |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #2 |
| Links for applied filters fail to specify their purpose |
|
| Action |
Responsible official |
Target completion date |
| Adapt the search filter to satisfy adaptive technologies so their purpose may be fully communicated. |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #3 |
| “Select” and “Learn more” links are not descriptive of their purpose |
|
| Action |
Responsible official |
Target completion date |
| Ensure the “Select” and “Learn more” links provide contextual descriptions. |
Manager, IT Operations and System Management |
2025-12-31 |
5.3 Headings and Labels (Level AA)
| Issue #1 |
| Labels not descriptive enough |
|
| Action |
Responsible official |
Target completion date |
| Review and modify (when required) the labels of search combo boxes in a manner where they accurately describe their function. |
Manager, IT Operations and System Management |
2025-12-31 |
6. Readable
6.1 Language of Parts (Level AA)
| Issue #1 |
| Wrong values for the language attributes |
|
| Action |
Responsible official |
Target completion date |
| Fix the language attributes on entities to ensure they are in the appropriate language they are encapsulating (ex: language toggle text at the top of every screen). |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #2 |
| Forgotten English text in French screens |
|
| Action |
Responsible official |
Target completion date |
Unless text is in a language other than the page language, ensure that the LRS has completely unilingual pages, including these cases:
- Text in tooltips (title attributes)
- Text in elements that have “wb-inv” class
- Content that appears upon interaction only
- Image alt texts
- Error messages
- System notices
|
Manager, IT Operations and System Management |
2025-12-31 |
7. Input assistance
7.1 Labels or Instructions (Level A)
| Issue #1 |
| Requires fields not announced as required |
|
| Action |
Responsible official |
Target completion date |
| Ensure that all screens containing required fields are clearly marked as such. |
Manager, IT Operations and System Management |
2025-12-31 |
8. Compatible
8.1 Name, Role, Value (Level A)
| Issue #1 |
| Incorrect usage of parent for <a> element with the role = “menuitem” attribute |
|
| Action |
Responsible official |
Target completion date |
| Assign a presentation role to all list items that are parents of the <a> elements that have the role="menubar". To remediate, apply Canada.ca solution to all <li> elements in the main menu. |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #2 |
| ARIA attributes with invalid values |
|
| Action |
Responsible official |
Target completion date |
| Evaluate if the ARIA-control attributes and their values should be removed if they do nothing. |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #3 |
| Input fields with no associated labels |
|
| Action |
Responsible official |
Target completion date |
| Ensure all input fields have an associated label, and that they provide an appropriate contextual description. |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #4 |
| Applied filters state is not communicated programmatically |
|
| Action |
Responsible official |
Target completion date |
| Ensure the applied search filter statuses (active/inactive) aren’t solely communicated using background colour. |
Manager, IT Operations and System Management |
2025-12-31 |
| Issue #5 |
| Toggle buttons to hide or show password lack an accessible name |
|
| Action |
Responsible official |
Target completion date |
| Ensure the toggle buttons to hide or show password have accessible names to identify their purpose. |
Manager, IT Operations and System Management |
2025-12-31 |
Approval
The Management Response and Action Plan was approved by the members of the Executive Management Committee on November 28, 2024.
