Canada Accessibility Plan

Canada Accessibility Progress Report 2024-25
Canada Accessibility Progress Report 2023-24

Overview

Bank of America Canada (BofA) is committed to treating all people in a way that allows them to maintain their dignity and independence. We continue to uphold the principles of dignity, independence, integration and equal opportunity, as outlined in the Accessible Canada Act (ACA) and the Accessible Canada Regulations (ACR). We are committed to meeting the needs of people with disabilities and meeting accessibility requirements under the ACA.

The Accessible Canada Act is a Federal Act with the purpose of identifying, removing, and preventing accessibility barriers in built environments, employment, information and communication technologies, procurement of goods and services, delivering programs and services and transportation. Pursuant to this legislation and the Accessible Canada Regulations, SOR/2021-241 (the “Regulations”), federally regulated entities have a duty to put into place accessibility plans, feedback tools and progress reports. This plan continues our 3-year planning cycle and builds on our 2023 plan and progress reported annually since.

A. Consultations

BofA continued to consult with individuals with disabilities to assist with determining barriers in the workplace and with our updated accessibility plan.

As part of this process, we expanded our consultations to external disability organizations with subject-matter expertise and lived experience.

Steps Taken to Identify, Remove, and Prevent Barriers to Accessibility

The following is an outline of steps taken by BofA to identify, remove, and prevent barriers to accessibility.

Internal Consultations

BofA consulted with employees by asking questions about accessibility via in-person meetings. We asked our employees with disabilities whether they had experienced barriers, and if so, what those barriers were. We also asked our employees how we could improve accessibility for our employees and in general at BofA.

Key themes that stood out included physical barriers specifically related to accommodations such as larger monitors and specialized equipment, as well as the value of increasing representation and proactive recruitment of people with disabilities.

We have responded by working with our Technology partners on the continuous roll-out of 32”monitors for all employees. As well, we have reminded staff we provide ergonomic assessments upon request.

External Consultations

In addition to internal consultations, BofA consulted with two external organizations that specialize in workplace barriers:

1. Neurodiversity in the Workplace

BofA engaged with an organization to provide live virtual training and support, including specialized ‘success coaching’ to managers with neurodivergent employees in their teams. Their training included:

  • Effective task-tracking methods
  • Understanding neurodivergent workstyles
  • Sensory-friendly support strategies
  • Accessible communication techniques
  • Tailored approaches based on specific issues

This consultation helped strengthen our ability and approach to supporting neurodivergent teammates and informed updates to our Employment and Training sections. We will continue and expand this important training to our employees and managers going forward.

2. Optimal Performance

BofA engaged with an external accessibility-focused firm to conduct an assessment of our built environment. After a detailed review of our environment, they confirmed our offices meet current accessibility requirements. However, minimal improvement suggestions were identified, demonstrating strong alignment with accessibility standards. These suggestions included:

  • Tactile and high‑contrast wayfinding signage
  • Accessibility of washrooms in public‑facing areas
  • Lighting consistency for people with low vision
  • Communication supports, including hearing assistance technologies in meeting spaces

BofA recognizes that there are continuous opportunities to improve accessibility in our organization. We will continue to solicit feedback and listen to people with disabilities with the goal to become barrier free, including providing organization-wide disability sensitivity and accessibility training at BofA

This accessibility plan will continue to guide BofA and hold us accountable as we continue to work towards becoming a barrier-free organization.

B. Addressing the areas identified in the Accessible Canada Act

1. Employment

BofA accommodates people with disabilities during the recruitment and assessment processes and when people are hired as follows:

  • Recruitment, Assessment and Selection Process

BofA fosters an environment of respect and inclusivity in our recruitment process. Language is incorporated in each job posting to make applicants aware that accommodation is available upon request to assist with the recruitment and selection process. Workday, our Applicant Tracking systems, immediately asks candidates to identify if a candidate needs an accommodation. Talent Acquisition partners are educated on inclusive selection strategies and on how to implement and request support for accommodation-related requests. When making offers of employment, BofA will notify the successful applicant of our policies for accommodating employees with disabilities. If support is requested through the recruitment process, Human Resources Canada will be notified.

  • Informing Employees of Supports

BofA will inform its employees of its policies, and any changes to its policies used to support employees with disabilities on an annual basis, taking into account various employee accessibility needs due to a disability. This information is be provided to new employees as soon as practicable after commencing employment.

  • Accessible Formats and Communication Supports for Employees

Upon request of an employee with a disability, BofA will consult with the employee to provide or arrange for the provision of accessible formats and communications supports for information that is needed to perform his/her job and information that is available to other employees.

  • Workplace Emergency Response Information

BofA is committed to providing employees with emergency information in an accessible way upon request. We will also provide employees with disabilities with individualized emergency response information when necessary. Where an employee requires assistance, BofA will, with consent of the employee, provide the individualized emergency response information to the person designated to provide assistance to the employee.

  • Documented Individual Accommodation Plans

BofA has a process in place for developing individual accommodation for employees that have identified themselves as needing accommodation due to a disability.

BofA will develop individualized accommodation plans for employees with disabilities, as the Bank is made aware.

BofA is committed to ensuring that such accommodation is made available to the point of undue hardship.

We review all our accommodation policies and plans to ensure they are compliant with all applicable laws, including the Accessible Canada Act.

BofA will implement and maintain effective measures to maintain the privacy of its employees with disabilities.

If an employee requires an accommodation due to a disability, please contact Human Resources Canada at human_resources_canada@bofa.com

  • Return to Work Process

BofA has a documented process that details the process to request an accommodation as well as responsibilities of each party (employee, manager, and third-party benefits partner).

BofA partners with a third-party benefits provider to deliver a proactive, high communication disability management program that facilitates individualized return-to-work plans.

  • Performance Management, Career Development & Redeployment

BofA takes into account the accessibility needs of employees with disabilities and employees with individual accommodation plans when conducting performance reviews, providing career development and when redeploying employees.

2. Training

BofA provides annual online mandatory training to all employees and contract staff on Canada’s accessibility laws and on the human rights legislation as it relates to people with disabilities. This training is provided to new employees as soon as practicable after the employee is assigned the applicable duties. Training is provided on an ongoing basis in connection with any changes to the policies, practices and procedures governing the provision of goods or services to persons with disabilities.

Training includes the following:

  • A review of the purposes of the Accessible Canada Act.
  • How to interact and communicate with people with various types of disabilities.
  • How to interact with people with disabilities who use assistive devices, service animals, or support persons.
  • How to use equipment or devices available on the premises or provided by the business that may help with the provision of goods or services to people with disabilities.
  • What to do if a person with a disability is having difficulty accessing a particular good or service offered by the business.
  • The processes that businesses in Canada must follow to create, provide, and receive information and communications in a manner that is accessible to people with disabilities.

Additionally, BofA’s Enterprise Technology Accessibility Centre of Excellence team provides general and role-specific training to help technologists design, develop, and test applications that create accessible experiences for all. Through BofA’s internal learning team, The Academy, BofA provides an ‘Accessibility for Developers’ education pathway outlining the importance of digital accessibility, how to develop for digital accessibility, and how to adhere to the WCAG requirements.

BofA also offers online training resources to all employees through The Academy helping foster inclusivity and better support for neurodivergent-identifying people in various environments. These include a ‘Learning Spotlight’ video education series, a ‘Neurodiversity’ education pathway, and an ‘Understanding & Supporting Neurodiversity’ online course. As well, through our Disability Action Network, employees and managers can access a Neurodiversity resource information hub.

3. The Built Environment

BofA has offices in Toronto, Vancouver, Calgary and Montreal. Our offices are in spaces that we rent and have many accessibility features. These features include:

  • Universal washrooms with automatic doors and grab bars.
  • Automatic doors throughout the buildings.
  • Many different places to sit and work or take a break.
  • Color-coded touchscreen scheduling panels outside of meeting rooms to indicate availability.
  • Department and floor-level signage and employee nameplates with increased font size and braille characters.
  • Emergency exit signage colored green.
  • Accessible kitchens and common rooms.
  • Inclusive LED 400 PC lighting with dimming functionality.
  • Stairs with visual cues and high-contrast markings on leading edges.
  • AED machines at AODA/ACA standards height.

As the environment continues to be built, we will work with Property Management and Facilities to ensure a barrier free and accessible workplace.

4. Information and Communication Technologies (ICT)

BofA is committed to meeting the communication needs of people with disabilities. We will continue to consult with individuals with disabilities to determine their specific information and communication needs.

Feedback

  • BofA will ensure that its processes for receiving and responding to feedback are accessible to people with disabilities via providing multiple feedback processes including online, phone and printable formats upon request. Accommodation Services are available to respond to any inquiries related to accessible formats.
  • Current feedback processes allow for multiple communication channels such as email, telephone, or regular mail.
  • To submit feedback on the Canada Accessibility Plan, please email human_resources_canada@bofa.com.

Accessible Formats & Communication Supports

  • Accommodation Services are available to respond to any inquiries related to accessible formats. BofA will notify the public about the availability of accessible formats and communications supports for persons with disabilities.
  • BofA’s Enterprise Technology Accessibility Team coordinates efforts across the company to make sure universal design and access are embedded into every part of BofA’s business. By making technology accessible, we lower the ‘invisible barriers’ that often prevent individuals with disabilities from navigating technologies and doing their jobs at the Bank every day.
  • BofA recently introduced the AI tool Microsoft Copilot to employees. Copilot provides many Accessibility features and functions, including:

    • Screen reader compatibility
    Full keyboard navigation support
    Voice access and dictation features
    Alternative text generation for uploaded images
    Simplification and translation of complex or technical content
    Built-in Accessibility Checker for Word and PowerPoint items
    Enablement of hands-free device control for users with mobility impairments

Note, Microsoft Copilot was leveraged to review this document for clear, plain language and easier reading, including identifying ways to reduce barriers for people using assistive technologies.

Accessible Websites and Web Content

  • BofA has raised its level of adherence to WCAG requirements from WCAG 2.1 AA to WCAG 2.2 AA providing accessibility to individuals with low vision, cognitive and learning disabilities, and motor disabilities. Both our internal intranet and external websites (careers.bankofamerica.com) and applications comply with the WCAG 2.2 Guidelines at Level AA requirements.
  • BofA ensures all publicly available information is made accessible upon request.

5. Communication, other than ICT

Web conferencing continues to be popular with employees and clients for connecting virtually, and we look for ways to help ensure our tools for virtual meetings provide an inclusive environment for team collaboration. In 2025, BofA transitioned from Zoom and Webex to Microsoft Teams for meetings and internal direct messaging. Teams has many built-in accessibility features including live captions available for all BofA hosted meetings, non-verbal methods of communication such as virtual hand raising, and chat, and screen reader support. The Bank will continue to look for ways to ensure communications are accessible for employees and clients.

6. Procurement of Goods, Services and Facilities

BofA purchases goods and services from suppliers. Purchasing of goods and services occurs through the Bank’s internal online systems, complying with WCAG 2.2 Guidelines at Level AA requirements.

7. Design and Delivery of Programs and Services

This section is not applicable to Bank of America in Canada.

8. Transportation

This section is not applicable to Bank of America in Canada.

C. General

If clients of BofA or members of the public have any questions or comments regarding this plan or the Bank’s compliance with the Accessible Canada Act, or their respective regulations, they can contact Canada Human Resources through the following: