March of Dimes Canada's Response to the Build Canada consultation

​In August 2025, March of Dimes Canada responded to an open consultation launched by the Department of Housing, Infrastructure and Communities to refine the approach to Build Canada Homes. We shared the following insights and recommendations expressing the need for accessible, adaptable, affordable housing, based on our expertise in providing accessibility services to people with disabilities across Canada, deeply informed by the lived experience of our service users.



The Honourable Gregor Robertson
Minister of Housing and Infrastructure, Government of Canada

August 29, 2025

Re: Embedding Accessibility as a Core Priority in the Build Canada Homes Mandate

Dear Minister Robertson, 

On behalf of March of Dimes Canada (MODC), we welcome the federal government’s initiative to address housing affordability through the creation of a new federal housing agency, as outlined in the "Build Canada Homes Market Sounding Guide". We write to urge that accessibility be embedded as a foundational priority in this plan, accompanied by targeted investment, design requirements, and measurable accountability mechanisms.

MODC is a leading national charity committed to championing equity, empowering ability, and creating real change that will help people with disabilities across the country unlock the richness of their lives. We’re paving the way for people with disabilities to experience full and meaningful lives in an inclusive world.

For over 20 years, MODC has delivered the Home and Vehicle Modification Program in Ontario—first for the Ministry of Children, Community and Social Services, and now for the Ministry of Seniors and Accessibility. Our staff and service users know how critical adaptable home design is for people with disabilities and seniors as their needs evolve. Too often, individuals lose the ability to choose the best modifications due to the cost of additional renovations. By prioritizing accessible, adaptable housing, we can help more people stay independent and avoid unnecessary transitions to long-term care or hospital settings. 
 
With this experience in mind, we commend your government for including investment selection criteria that:
  • Prioritizes future projects led by co-ops, non-profits, and Indigenous housing providers, many of which already emphasize accessibility and inclusive design.
  • Advances innovation in homebuilding through modern construction methods (e.g., prefabricated, modular, 3D-printed homes), which can be designed with universal design principles from the outset.

In 2019, Canada recognized housing as a human right through the National Housing Strategy Act. As a signatory to the UN Convention on the Rights of Persons with Disabilities, Canada is also obligated to ensure people with disabilities can live independently and choose where they live. Yet, the lack of affordable, accessible housing prevents many from doing so. For millions, accessibility is not a luxury — it is essential to safety, independence, and dignity. A failure to address this systematically will only deepen existing inequities, especially given significant ongoing demographic changes in Canada: 
  • As of mid-2022, about 19.3 per cent of Canadians (over 7.8 million people) were aged 65 and older. Canada is projected to reach 25 per cent older adult population by 2052.1
  • The oldest of the population are those 85 and older and made up about 861,000 in 2021 (2.3 per cent of the population). This cohort is one of the fastest-growing; projections suggest it may triple to nearly 2.5 million by the mid-2040s.2
  • Nearly 8 million Canadians (27 per cent) have a disability3, yet many of their homes lack essential accessibility features. In 2022, 16 per cent of people with physical disabilities reported that their housing did not accommodate their needs. People with disabilities are four times more likely than those without disability to experience homelessness.4,5
  • Approximately 430,000 seniors currently live below the Official Poverty Line in Canada.6 Furthermore, the Material Deprivation Index (MDI), which assesses access to basic goods and services, also estimates 14 per cent of older adults experience material hardship, including housing and food insecurity.7
  • Seniors living alone (especially women), those with disabilities, racialized and immigrant older adults, and seniors in high-cost urban areas are particularly marginalized.6,7 

Strategic Areas for Investment and Focus
We strongly recommend that accessibility be prioritized and addressed across the following pillars of the new housing agency’s work:
  1. Design Standards & Regulations
    1. Mandate that a strong minimum target be set for federally funded affordable housing units directed at meeting the CSA/ASC B652:23 Accessible Dwellings Standard8 and/or the Rick Hansen Accessibility Gold Standard9 (RHF Gold) for multi-unit residential buildings.
    2. Implement CAN/ASC 2.8, Accessible-Ready Housing Standard10 across the remainder of all new housing units/developments. The CAN/ASC 2.8, Accessible-Ready Housing Standard should apply to any units not meeting the CSA/ASC B652:23 level of accessibility to improve the longevity and sustainability of homes.  

Mandating these standards will improve the structural and utility design of homes, making them more broadly useable, adaptable and livable by people in Canada. Current provincial and national building code minimum standards for residential construction do not meet basic accessibility needs.11

There are measures beyond the building code that make a home more adaptable and accessible that do not cost more, provided design decisions are made up front. There are also measures that do cost more in terms of labour or materials. Meeting the above-mentioned higher accessibility standards can add between 1 to13 per cent to the overall project costs of a building, depending on the type of structure. Single detached homes have a greater cost compared to large multi-unit buildings.12–14 

Investments in accessibility delivers strong returns: lower healthcare costs, reduced reliance on institutional care, and better quality of life for people with disabilities of all ages15–20. For example, Toronto Community Housing’s capital renewal strategy anticipates 2.1 million fewer healthcare visits and $13.6 billion in neighborhood value gains from improved living conditions.21 Investing in accessibility is not only equitable, it is economically and socially smart.

Research funded by Accessibility Standards Canada (ASC) and conducted by Sunnybrook Research Institute in partnership with ULI (Urban Land Institute) Toronto, the Accelerating Accessibility Coalition, StopGap Foundation and other partners suggests that clear regulations and targeted funding will create greater incentives for the housing market to provide the accessible homes that so many people need. Without these, the government is missing a cost-effective way to improve equity and reduce long-term costs.22
  1. Accountability & Monitoring
    1. Mandate data collection and public reporting on accessibility outcomes (wait times, unmet adaptation needs, affordability metrics, number of accessible units built that meet the above-mentioned standards). This should be done in partnership with Statistics Canada and CMCH. Strong metric on accessible homes is a critical missing component of the current Canadian systems.4
    2. Ensure sustained and meaningful consultation with people with disabilities and older adults within Build Canada Homes agency planning, funding criteria, and evaluations.22

We suggest this be done in partnership with ASC and the Canadian Human Rights Commission.

  1. Managing Affordability, Accessibility, and Density Objectives

To best manage the multiple objectives of accessibility, affordability, and high-density housing, we offer these strategies. Strategies include:
  • Prioritizing mixed-density models, where higher overall unit counts enable accessibility without reducing affordability.
  • Incentivizing universal design through layered tools like capital grants or density bonuses, preventing cost burdens from being borne by non-profit developers or tenants.
  • Incorporating accessibility at the planning stage, where spatial efficiency can be optimized and costs reduced.
  • Building adaptable “accessible-ready” units, while also ensuring a proportion of fully accessible homes/units in every development, as per the standards above.
  • Provide funding top-ups, tax incentives, or capital grants specifically for accessible and adaptable units meeting the standards mentioned above.
  • Offset modest cost increases in accessible construction with developer supports and by procurement preferences.
  • Support municipalities in creating accelerated zoning and permitting processes for applications that meet pre-construction accessibility standards (RHF Gold Pre-construction Certification).

It requires intentional, inclusive planning and the right policy frameworks to achieve these multiple objectives, which Build Canada Homes has great potential to implement.

Conclusion

With Canada’s population aging rapidly and a significant number of older adults and people with disabilities living in poverty, it is imperative that accessibility be integrated as a core priority in the Build Canada Homes mandate.

We urge the federal government to reflect the already-established voluntary national standards in its Build Canada Homes design, where inclusive, accessible, and affordable housing is not a goal we aspire to but a baseline we meet.

We stand ready to support Housing, Infrastructure and Communities Canada in this process and offer our experience, research, and community insight to ensure that Build Canada Homes becomes a vehicle for meaningful and lasting impact.

Sincerely,

Amanda MacKenzie
National Director, External Affairs
March of Dimes Canada


References

  1. Canada E and SD. "Final Report of the Expert Panel: Supporting Canadians Aging at Home: Ensuring Quality of Life as We Age." National Seniors Council; 2024. Accessed July 10, 2025. https://www.canada.ca/en/national-seniors-council/programs/publications-reports/aging-home.html
  2. Government of Canada SC. A portrait of Canada’s growing population aged 85 and older from the 2021 Census. April 27, 2022. Accessed August 14, 2025. https://www12.statcan.gc.ca/census-recensement/2021/as-sa/98-200-X/2021004/98-200-X2021004-eng.cfm
  3. Statistics Canada. "Canadian Survey on Disability, 2017 to 2022." Government of Canada; 2023. Accessed May 10, 2024. https://www150.statcan.gc.ca/n1/daily-quotidien/231201/dq231201b-eng.htm
  4. Monitoring the right to housing for people with disabilities. Accessed June 5, 2024. https://www.chrc-ccdp.gc.ca/en/resources/monitoring-the-right-housing-people-disabilities
  5. Joint news release – New project confirms people with disabilities are overrepresented in all aspects of inadequate housing and homelessness. Accessed November 7, 2024. https://www.housingchrc.ca/en/joint-news-release-new-project-confirms-people-with-disabilities-are-overrepresented-in-all-aspects-of-inadequate-housing-and-homelessness
  6. White A, Gill Y. "Seniors’ Poverty in Canada: Why It Exists and Why It Doesn’t Have to." Maytree; 2025. Accessed August 14, 2025. https://maytree.com/wp-content/uploads/Seniors-Poverty-in-Canada.pdf
  7. Iciaszczyk N, Stapleton J. The case for using several ways to measure the economic reality of older adults. "Policy Options Politiques." Published online June 9, 2025. Accessed August 14, 2025. https://policyoptions.irpp.org/magazines/june-2025/older-adult-poverty/
  8. Canadian Standards Association. National Standard of Canada CSA/ASC B652:23 Accessible dwellings. Published online January 2023. Accessed February 29, 2024. https://www.csagroup.org/wp-content/uploads/2430606.pdf
  9. Get RHF Accessibility Certified | Rick Hansen Foundation. Accessed August 14, 2025. https://www.rickhansen.com/become-accessible/rating-certification
  10. Accessibility Standards Canada. CAN/ASC-2.8:2025 – Accessible-Ready Housing. Published online May 2025. Accessed July 8, 2025. https://accessible.canada.ca/creating-accessibility-standards/can-asc-282025-accessible-ready-housing
  11. Houle MJ. Open letter – accessible housing and the National Building Code. Published online May 22, 2024. Accessed August 1, 2024. https://www.housingchrc.ca/en/open-letter-accessible-housing-and-the-national-building-code
  12. Engineers in Motion. "Costing of Accessibility Features in the New Construction of Residential Dwellings." Accessibility Standards Canada; 2023.
  13. Wall J, Robertson M, Harmsworth A. "BCBC 2024 Adaptable and Earthquake Design Space and Cost Study Analysis Report." Prepared by GHL Consultants Ltd. for the Government of British Columbia, Ministry of Housing and Municipal Affairs; 2024. Accessed June 23, 2025. Vancouver, BC
 Canada
  14. HCMA Architecture + Design. "Rick Hansen Foundation Accessibility CertificationTM Cost Comparison Feasibility Study." Rick Hansen Foundation; 2020. https://www.rickhansen.com/sites/default/files/downloads/20200115-rhfac-final-report-full-v3.pdf
  15. Heywood F, Turner L. "Better Outcomes, Lower Costs: Implications for Health and Social Care Budgets of Investment in Housing Adaptations, Improvements and Equipment – a Review of the Evidence." Office for Disability Issues, Department of Work and Pensions; 2007. https://www.wohnenimalter.ch/img/pdf/better_outcomes_report.pdf
  16. Schmidt SM, Chiatti C, Ekstam L, et al. Enabling Long-term Predictions and Cost-benefit Analysis Related to Housing Adaptation Needs for a Population Aging in Place: Protocol for a Simulation Study. "JMIR Research Protocols." 2022;11(8):e39032. doi:10.2196/39032
  17. Tsuchiya-Ito R, Hamada S, Slaug B, Ninomiya A, Uda K, Ishibashi T. Implementation and costs of housing adaptations among older adults with different functional limitations in Japan. "BMC Geriatrics." 2022;22(1):444. doi:10.1186/s12877-022-03100-9
  18. Canada Mortgage and Housing Corporation. "Study of the Cost of Including Accessibility Features in Newly Constructed Modest Houses." Government of Canada; 2015. Accessed June 23, 2025. https://publications.gc.ca/collections/collection_2016/schl-cmhc/NH18-23-2015-6-eng.pdf
  19. Hallinan D, O’Reilly R, Craddock G. Universal Designed Homes: Social Value and Economic Benefits. "Studies in health technology and informatics." 2024;320. doi:10.3233/shti241004
  20. "Living Not Existing: The Economic & Social Value of Wheelchair User Homes." Habinteg Housing Association; 2023:20. Accessed January 9, 2024. https://www.habinteg.org.uk/download.cfm?doc=docm93jijm4n3935
  21. 10-year capital plan | Toronto Community Housing. Accessed August 14, 2025. https://torontohousing.ca/building-construction-and-revitalization/capital-repairs/10-year-capital-plan
  22. Hitzig SL, Yuzwa KE, Weichel L, et al. Identifying priorities and developing collaborative action plans to improve accessible housing practice, policy, and research in Canada. "PLOS ONE." 2025;20(2):e0318458. doi:10.1371/journal.pone.0318458


​

​