National Bank – Three-Year Accessibility Plan (2026-2029)

Disability

The Accessible Canada Act (2019) defines disability as follows: “any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment — or a functional limitation — whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, hinders a person’s full and equal participation in society.” 

Barrier

The Accessible Canada Act (2019 defines a barrier as follows: “anything — including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice — that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation.” 

Employment

All an employee’s activities and experiences during the full cycle of their career path. 

Design and delivery of programs and services

All products and services provided by the Bank through its employees, including the client experience, whether it be digital, in person or remote. 

Built environment

All physical spaces intended for employees, clients and the public. 

Information and communication technologies (ICT)

All of the Bank’s technological solutions used by internal and external users, clients and employees to communicate and access information sources. 

Communications other than ICT

All activities intended to spread a message or promote the image of a product or service. 

Procurement of goods, services and facilities

All procurement activities including the identification of goods or services required, the method of selecting suppliers, the implementation of that method and the awarding of agreements. 

WCAG (Web Content Accessibility Guidelines)

The Accessible Canada Regulations (2021) define the term “WCAG” as “the most recent version available in both English and French of the Web Content Accessibility Guidelines, published by the World Wide Web Consortium.” 

In order to develop its accessibility plan, the Bank used several data collection methods to evaluate the accessibility of the products and services offered to its clients, employees and partners. The combination of all these data collection methods helped guide the drafting of the plan and the actions taken to eliminate or reduce barriers.

I. Inventory: The Bank started by drawing up an inventory of the initiatives, tools, products and services available for each of the applicable areas. This exercise enabled us to carry out a self-assessment of existing accessibility practices and prioritize various action plans. 

II. Consultation with clients: Every year, National Bank surveys its clients to better understand their experience, expectations and irritants encountered during their journey. This expanded listening strategy makes it possible to gather specific insights into our products, services and interactions across all our channels. During the 2026-2029 cycle, the Bank plans to organize focus groups or individual interviews with senior clients, clients with disabilities and/or vulnerable clients to gain deeper insights and involve the people concerned in the decision-making process.

The results of these surveys and interviews will be key in guiding our priorities, measuring the evolution of the client experience and identifying opportunities for continuous improvement. By giving our clients a voice, we strengthen our ability to design solutions that are simpler, more accessible and better adapted to the diversity of needs.

III. Consultation with employees: Employees are consulted through an annual survey that covers topics such as work organization, the use of technology, services offered, working conditions, etc. Individual and group interviews are also conducted on a periodic basis with a sample of employees with disabilities who have expressed an interest in taking part in the consultations. In addition, the Bank works closely with the employee resource group R.I.S.E. (Respect, Inclusion, Support, Equity) whose mission is to promote the wellbeing of every person at the Bank, particularly in the areas of mental health, accessibility and disability.

IV. Document review: Different sources of information have been reviewed to evaluate accessibility and monitor market trends, including: 

• Accessibility audit reports 
• Internal standards, policies and guides 
• Action plans 
• Complaint reports 
• Results of internal surveys and feedback from clients and employees
• Statistics on employee experience

The Bank is a learning organization that leverages its expertise in inclusivity and diversity to keep improving its accessibility. We are committed to reinforcing accessibility measures so we can offer a better experience to our clients, our teams and our stakeholders. To this end, the Bank plans to: 

• Promote its culture of inclusion, diversity and equity 
• Adopt a zero-tolerance policy on discrimination 
• Promote learning and raise awareness of accessibility issues among its employees
• Use surveys to obtain feedback from employees and clients so it can identify and correct irritants 
• Include accessibility standards in its new initiatives, on an ongoing basis

To ensure continuity, we recognize the need to put in place preventive measures to avoid barriers in the future and have a positive impact on the experience of our clients and employees, whether or not they have a disability. To do this, we have focused on three areas: 

I. Corporate culture: Encourage buy-in and promote an inclusive, non-discriminatory culture by fostering awareness of accessibility issues, knowledge of the barriers encountered and understanding of the impacts. To this end, we integrate our intrinsic values and organizational priorities into our internal standards and policies to give them maximum visibility. Various forums are also in place and will continue to be used to promote our values of inclusion and accessibility.

II. Training: Increase knowledge of accessibility across the organization and develop the skills in that area to improve our employees’ responsiveness and reflexes while raising awareness about prejudice and negative bias. To do this, training will be offered, reference tools provided and discussion forums and information platforms publicized.

III. Governance: To facilitate the early detection of possible barriers, monitor the evolution of our practices, identify the needs of our clients and employees and ensure the visibility of our accessibility initiatives, various governance mechanisms for inclusion and accessibility are in place and will be maintained. Our goal is to monitor industry best practices, progress made in accessibility and the new tools and trends available.

1. Background and statement of commitment

The Bank is committed to offering an inclusive, simple client experience that puts people first and focuses on supporting key moments in its clients’ lives. It aims to offer accessible and equitable advice, products and services, regardless of the communication channel chosen.

Our branches, digital platforms and contact centres are designed so that all people can use them, including those with disabilities or who may need special support, such as seniors. The experience offered is based on constant respect for dignity, autonomy and equity. To meet clients’ preferences and needs, services can be offered based on the desired communication method: Telephone, email, in person or video call. Accessible technological tools make it easier to access to information, products and services, while supporting certain transactions.

To this end, the Bank is continuously improving the accessibility of its digital programs, services and platforms to reduce barriers and promote clear, simple and autonomous navigation. A digital accessibility best practices guide helps standardize these practices in accordance with the Web Content Accessibility Guidelines (WCAG), contributing to a more inclusive, barrier‑free client experience.

2. 2023-2026 plan achievements

During the 2023–2026 plan, the Bank made significant progress in accessibility with respect to the design and delivery of its programs and services. Three objectives were set:

• Learn more about the barriers faced by people with disabilities so we can adapt our programs and services
• Ensure accessibility when designing, reviewing or delivering programs and services
• Provide an ecosystem that meets accessibility standards

One of the main achievements is the implementation of a Bank-wide design system to apply the WCAG standard to digital content. Manual independent audits are carried out periodically to document gaps and identify areas for improvement. This work confirms the importance of furthering our understanding of the barriers faced by people with disabilities and reinforcing the integration of accessibility throughout the cycle, from design to service delivery.

Digital accessibility training courses have been developed to meet the specific needs of the various functions involved in the value chain, including developers, designers, analysts, content creators, project managers, etc. The Bank is continuing to make progress and is preparing for the future in terms of accessibility.

3. Barriers identified during consultations

Despite the progress made, findings from assessments and client surveys reveal several persistent irritants in service delivery. For example: 

• Some clients may have difficulty completing the verification and authentication processes.
• Low contrast screens and navigation can sometimes be complex for the visually impaired.
• Some procedures still require clients to be physically present, which poses a problem for clients with reduced mobility or sensory limitations.
• Vulnerable individuals, such as clients with visual or cognitive disabilities, may be more exposed to manipulation and financial abuse.
• When rules are applied too strictly without regard for people with disabilities, a perception of discrimination or inadequate support persists.
• The use of telephone lines by some people with disabilities may be a challenge. For example, people with a hearing impairment using relay transcription services.
• The accessibility of the products and services offered by some of the Bank’s partners varies, which may be reflected in our service offering.

These irritants stem in part from a lack of expertise in accessibility, which limits the Bank’s capacity to effectively implement WCAG standards and integrate and operationalize the approach from the design phase. Furthermore, accessibility remains insufficiently integrated in processes and the execution cycle, leading to delays in corrections and an elevated risk of technical debt as compliance gaps continue to emerge. The uneven prioritization of accessibility by design in digital initiatives is also a major barrier, especially when it needs to be integrated retroactively. Certain paths and services remain less accessible, which has a direct impact on the experience of clients with limitations or disabilities. 

4. Priorities to eliminate barriers

In response to these findings, the Bank has established four priorities for 2026-2029. 

The first priority is to develop capacity and expertise in digital accessibility, in particular by implementing a structured and ongoing skills development program, which includes training for developers, design teams and key stakeholders, as well as adopting accessible writing principles.

The second priority is to integrate accessibility by design by implementing formal mechanisms and aligning accessibility requirements with processes, tools and key steps in the execution cycle, particularly by using the design system as a structuring driver. To ensure consistency from end to end, accessibility requirements will have to be integrated into sourcing processes, allowing for the selection of third parties that comply with the Bank’s accessibility standards and principles.

The third priority involves structuring governance and practices through dedicated resources and strengthening expertise to ensure the consistency of interventions, follow-up on required adjustments and compliance with regulatory requirements.

The fourth priority is to better equip and raise awareness among the teams that support clients in assisted channels to ensure consistent interventions, quickly identify adjustments needed and support the Bank's commitment to offering services that are accessible to all.

Lastly, the Bank will continue to optimize its information sites to improve the client experience in concrete terms, including through targeted audits of web pages and improving the structure, readability and compatibility of content. These orientations will help us consolidate what we've learned, reduce barriers to accessibility in the long term and offer programs and services that are more inclusive, consistent and comply with applicable standards for all clients.

1. Background and statement of commitment

In 1992, the Bank made a commitment to the Canadian Human Rights Commission to ensure its branches and other buildings comply with universal accessibility standards. National Bank therefore continues to make significant investments in its branches and points of service to offer clients an environment that lives up to their expectations. For example, in 2025 we: 

• Opened, renovated or relocated 40 branches to offer modern, more accessible spaces. 
• Gradually updated our branches to meet new diversity, inclusion and universal accessibility standards for people with cognitive and physical limitations, with the help of the guidelines in the Code of Conduct for the Delivery of Banking Services to Seniors.

The Bank recognizes that accessibility to the built environment is an essential driver to promote the inclusion of people with disabilities and to meet the diversity of needs of its clients and employees. This commitment applies to corporate buildings and 382 branches located in Canada. Our Real Estate Business Strategy is the main pillar for supporting the development of the built environment and ensuring the progressive integration of IDEA (Inclusion, Diversity, Equity and Accessibility) principles into projects with a view to continuous improvement.

2. 2023-2026 plan achievements

Over the period covered by the 2023–2026 plan, the Bank took several important steps to ensure the inclusive accessibility of the built environment. The inauguration of the new head office located at 800 Saint-Jacques Street West is one of the major achievements. It was designed in accordance with standards, codes and legislation in effect, including universal accessibility requirements. Improvements were also made based on feedback collected through surveys and audits carried out with an external accessibility firm. Signage was modified to better support people with disabilities, notably by adding braille to furnishings to make orientation easier. Implementing photometric studies when designing projects also helped optimize visual comfort and meet different user profiles. 

We also developed a support offer to help employees with specific needs move around more easily and become familiar with their work environment, so they can adapt their workspace, in coordination with Human Resources. Incorporating accessibility requirements into the project design process has become a driver of both efficiency and effectiveness. 

The Bank has also strengthened its internal knowledge through awareness-raising and training activities, particularly for the teams responsible for its buildings. Accessibility audits were carried out in some buildings by a specialized firm, with particular attention to the sensory, cognitive, and communication accessibility of the premises. 

These initiatives are significant achievements in documenting the current state of existing environments and supporting a progressive and sustainable approach to improvements.

In addition to being accessible in six languages (English, French, Spanish, traditional Chinese, Punjabi, Arabic), all our automated banking machines (ABMs) are equipped with an audio guide to assist people with visual disabilities.

3. Barriers identified during consultations

Consultations and work conducted as part of the 2023–2026 plan identified challenges in some buildings, notably related to ease of access (ramps, automatic doors, etc.), reserved parking near entrances, sometimes poorly adapted furniture, complex vertical circulation, accessible washroom facilities, ambient noise management and workstation ergonomics. Barriers involving ABMs mainly concern people with visual impairments (e.g., text size, contrasts). 

These findings reflect the diversity and complexity of existing facilities, some of which were designed or renovated to meet the standards in place at the time. While recent projects meet the applicable regulatory requirements, the systematic integration of IDEA principles and other more advanced criteria vary from site to site. The various standards published since 2023, as well as those to come, will allow us to continue identifying, eliminating and preventing barriers in the built environment. 

4. Priorities to eliminate barriers

The Bank plans to consolidate its achievements and further structure its accessible built environment practices in its projects over the 2026-2029 period. Several initiatives are underway in the built environment area, such as the development of a standards guide that integrates IDEA principles, including space acoustics, signage, ergonomics, lighting and emergency measures in buildings. Over time, these tools will help harmonize the layout design for major projects and ensure property management teams commit to offering more accessible and inclusive spaces.

Future projects will follow the guidelines of our real estate strategy in order to find a balance between the need for collaboration, concentration and confidentiality in work areas. A detailed inventory of real estate and rental facilities and their components will allow us to prioritize corrective measures to reduce gaps with current and future provincial and federal standards.

The standard on emergency evacuations is a reminder that people with disabilities want the same level of security as their colleagues when a building needs to be evacuated. The following objective has therefore been developed:

1. Background and statement of commitment

As part of its 2023–2026 accessibility plan, the Bank continued its efforts to boost the accessibility of its digital and technological ecosystem. The ICT area has helped to progressively improve the experience of people with disabilities, for both clients and employees, by relying on recognized standards, the evolution of its design and development practices, and the rollout of monitoring tools. With this in mind, the Bank will continue working to make accessibility a shared mindset in IT teams and to keep improving digital systems and services so they are accessible to the widest possible audience.

2. 2023-2026 plan achievements

The last three-year plan helped establish solid foundations for digital accessibility and showed a tangible commitment. The main advances include:

• Structured rollout of digital accessibility training: Training programs tailored to the different roles have been implemented to reinforce teams’ knowledge of accessibility, including specialized training, and practical resources to help them apply best practices. 
• Strengthening awareness in IT teams: Ongoing awareness-raising initiatives were implemented to support ownership of accessibility issues and encourage more inclusive digital practices on a daily basis.
• Tangible and measurable improvements to digital platforms: Continuous improvements were rolled out across selected technology systems, notably in navigation, key components and forms, leading to solid progress in accessibility over time.
• Changes to development practices: The ICT area has started transforming its practices to better integrate digital accessibility. The development, which is already well-established in some teams, is continuing so that it becomes a shared mindset across the organization.
• Accessibility monitoring and control tools implemented: Automated audit and monitoring tools have been rolled out to regularly assess the accessibility of information websites. These assessments allow us to identify gaps, track progress and support continuous improvement based on objective data.
• Structuring the IT support offered to employees: A dedicated section of the Intranet helps employees and managers identify IT adaptation needs for persons with disabilities. It provides a framework for the processes used to make requests for non-standard devices and equipment, while documenting the use of accessibility features integrated into digital tools, including Microsoft Teams. This approach helps clarify IT processes and makes it easier to implement suitable technology solutions.

3. Barriers identified during consultations

The consultations helped identify structural challenges associated with integrating digital accessibility in a complex organizational and technological environment. These include challenges related to cross‑sector alignment of priorities and resources, varying approaches to integrating digital accessibility depending on contexts and initiatives, and limits to the standardization of processes and tools supporting these practices. 

The evolving regulatory framework, particularly the coming into force of Phase 1 of the Digital Technologies Accessibility Regulation, further underscores the importance of these challenges by introducing new progressive requirements that apply across the entire digital technology lifecycle. These findings helped guide discussions on the priorities of the next three-year plan.

Lack of cross-sector alignment of priorities, responsibilities and resources

Implementing digital accessibility requires a clear alignment of objectives and responsibilities among teams. Without fully coordinated prioritization across the organization, there may be gaps in the pace, scope and consistency of the rollout of accessibility practices.

Varying maturity in integrating digital accessibility

In line with the alignment challenges identified, the integration of accessibility into digital practices is still uneven across teams and projects. While some teams have already developed strong maturity and well-established reflexes, others are still in the buy-in phase, which limits systematic application across the organization.

Incomplete standardization of processes and tools

The lack of standardized processes and shared automated tools, combined with alignment and maturity challenges, limits the consistent integration of accessibility across the entire lifecycle of digital solutions. The coming into force of Phase 1 of the Digital Technologies Accessibility Regulation reinforces these findings and introduces new progressive requirements, particularly with respect to the design, updating, assessment, and acquisition of digital technologies, as well as the training of the teams involved. These findings have made it possible to better target the priorities in the next three-year plan, particularly in terms of standardization, reinforcing capacity, training and governance, in order to continue progressing towards a fully accessible digital ecosystem.

4. Priorities to eliminate barriers

These governance and monitoring mechanisms are the foundations needed to systematically integrate accessibility into IT projects.

1. Background and statement of commitment

The Bank implements measures to ensure that everyone has access to information, presented in clear and understandable language and delivered through the communication channel best suited to their needs—digital platforms, telephone, email, in‑person meetings, or videoconferencing. To this end, guidelines have been developed to encourage the use of plain and simple language in all documents and communications. These guidelines are intended to align practices related to inclusive and accessible communications, both internally and externally.

Communications published on the Bank’s digital platforms also help, in part, to adequately support people with disabilities. The Bank also acknowledges the importance of showcasing its values and inclusive culture within the organization to support the sustainable evolution of accessibility practices. These messages are conveyed through various internal channels, such as discussion forums, information tools and corporate communications.

Finally, the Bank regularly collects feedback from its employees and clients, using tools such as surveys, discussion forums and data analytics, in order to quickly identify potential accessibility barriers in communication and respond proactively to them.

The 2023-2026 three-year plan helped us understand the universal scope of the practices and processes used to produce accessible communications. The progress made in the areas of Employment and Communications (internal) will be used in the next three-year plan to improve the accessibility of communications with clients. 

2. 2023-2026 plan achievements

Our achievements in 2023-2026 include several major advances:

Improved communications and content

Several tools have been rolled out to help content creators to communicate in plain language: 

• Guide to inclusive writing
• Plain language writing guide
• Guide on best practices for producing accessible videos 
• Training program for content creators

Improvements to the different communication channels

The following initiatives have made information more accessible on our various communication channels: 

• Transcriptions can be activated for corporate conferences.
• Quarterly follow-up of major achievements in video format as well as in writing.

Improved awareness of accessible communications 

Several initiatives were carried out to address accessibility in our communications to employees.

3. Barriers identified during consultations

Internal communications (employees)

• Overuse of acronyms across the organization does not promote understanding.
• Financial information can be complex or difficult to understand depending on the level of knowledge or expertise. 
• The large number of content creators with varying proficiency in the guidelines leads to information overload.
• Web accessibility standards and criteria are not known/followed by everyone.
• Quality of content is not always tested before publication.
• Sign language is not provided in our videos. LSQ/ASL interpreters are rare and in high demand.
• The resources and tools available to meet employees’ accessibility needs are not well understood. 
• The needs associated with several invisible disabilities are not well understood, making it more difficult to identify appropriate accommodation measures.

External communications (clients)

• No comprehensive centralized inventory of client requests regarding accessibility of communications. 
• No exhaustive inventory of initiatives and services implemented by the business lines to accommodate clients’ accessibility needs in communications. 
• Information on clients’ communication accessibility preferences (braille, large print, etc.) is not centrally collected or stored for future reference. 
• In many cases, templates for sending communications to clients based on their accessibility needs (i.e., accessible or alternative formats) are not readily available.
• Employees in charge of communications with clients must be trained to select the right channel and/or make sure that the documents sent meet the accessibility criteria requested, while reflecting the brand. 
• Some web pages require a higher than average level of proficiency in French or English, which is a barrier for many clients. 

¹ The communications covered here encompass all communications issued by the Bank, whether internal communications to employees or external communications to clients.

4. Priorities to eliminate barriers

1. Background and statement of commitment

The Bank is committed to fostering inclusion and accessibility in all aspects of its operations, including procurement and sourcing activities. We recognize that meaningful progress in these areas requires the active participation of all stakeholders, including our business partners, suppliers, and employees. To this end, we regularly review and update our standard contract templates for the acquisition of goods and services. This process ensures that our contractual clauses remain aligned with evolving legal and regulatory requirements, industry best practices, and emerging accessibility standards. By prioritizing these reviews, the Bank demonstrates its dedication to creating an equitable and accessible environment for everyone involved in our procurement processes.

2. 2023-2026 plan achievements

As part of our ongoing commitment, the Bank has implemented a standard clause in all contract templates requiring suppliers to comply with Canadian federal and provincial legislation. Our business lines actively ensure that suppliers uphold these legal requirements. In addition, the Supplier Code of Conduct outlines expectations regarding inclusion and diversity, reinforcing our commitment to accessible procurement. 

3. Barriers identified during consultations

Accessibility procurement is a challenging area considering vendors are in different jurisdictions and sometimes lack the understanding of the requirements under the Accessible Canada Act. Several challenges have been identified:

• Insufficient contractual clauses and monitoring mechanisms: Some contracts lack specific provisions that mandate suppliers to comply with accessibility legislation, and do not require suppliers to demonstrate their ability to deliver accessible goods and services. 
• Lack of awareness and training: Employees involved in procurement processes may not receive adequate training on accessibility requirements and best practices, leading to gaps in implementation and oversight. Products and services acquired through procurement do not consistently incorporate accessibility principles and requirements from the outset.
• Accessibility of the procurement system: The SAP Ariba platform, processes, and documents used in procurement could pose barriers for certain users, employees, or vendors, hindering their ability to fully participate in procurement activities.
• Accessibility of payment terminals: An increased number of touchscreen payment terminals with touch screen are inaccessible to blind or visually impaired people as they lack tactile markers.
• Food services: From time to time, at the Montreal head office, employees with disabilities encounter barriers in the cafeteria, especially during busy periods. Issues are related to acute noise levels and/or lighting, stairs restricting certain areas, carrying food trays and other physical barriers.

4. Priorities to eliminate barriers

Through these initiatives, the Bank seeks to eliminate barriers in the procurement of goods and services.