Introduction
March of Dimes Canada responded to an open consultation launched by the House of Commons Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities for their study on Bill C-20, An Act respecting the establishment of Build Canada Homes.
We shared the following insights and recommendations based on our based on our expertise in providing accessibility services and attendant services to people with disabilities across Canada, deeply informed by the lived experience of our service users.
Submission
August 2026
On behalf of March of Dimes Canada (MODC), we welcome the federal government’s initiative to address housing affordability through the creation of Build Canada Homes.
We urge the federal government to embed accessibility and inclusion as a foundational priority in Bill C-20.
MODC has delivered the Home and Vehicle Modification Program in Ontario for over 20 years. We partnered with the Government of Manitoba in 2023 to deliver a similar program (Manitoba Safe and Healthy Home for Seniors). Our staff and service users know how critical inclusive, accessible, and adaptable home design is for people with disabilities and seniors as their needs evolve. Too often, people lose the ability to stay in their homes as they age, and their access needs change due to the cost of additional renovations. By prioritizing inclusive, accessible, and adaptable housing, we can help more people become and stay independent and avoid unnecessary transitions to long-term care or hospital settings.
Housing as a Human Right
Canada recognized housing as a human right through the National Housing Strategy Act in 2019. As a signatory to the UN Convention on the Rights of Persons with Disabilities, Canada is also obligated to make sure people with disabilities can live independently and choose where they live. Yet, the lack of inclusive, affordable, and 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 and exclusion, especially given these significant ongoing demographic changes in Canada:
As of mid-2022, about 19.3 per cent of people in Canada (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 people in Canada (27 per cent) have a disability3 and many of their homes lack essential accessibility features. People with disabilities are four times more likely than those without disability to experience homelessness.4
Approximately 430,000 seniors currently live below the Official Poverty Line in Canada.5 Furthermore, the Material Deprivation Index (MDI), which assesses access to basic goods and services, estimates 14 per cent of older adults experience material hardship, including housing and food insecurity.6
Seniors living alone (especially women), those with disabilities, racialized and immigrant older adults, and seniors in urban areas where the cost of living is highest are particularly marginalized.7
Recommendations
MODC makes the following recommendations to The House of Commons Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities for consideration for the study On Bill C-20.
1. MODC recommends that the purpose of Bill C-20 be modified from:
Purpose:
The purpose of the Corporation is to promote, support and develop the supply of affordable housing in Canada and to promote innovative and efficient building techniques in the housing construction sector in Canada.
To:
The purpose of the Corporation is to promote, support and develop the supply of
affordable and inclusive, accessible, and adaptable housing in Canada and to promote innovative and efficient building techniques in the housing construction sector in Canada.
This echoes our
previous recommendations we submitted to the Minister of Housing and Infrastructure in August 2025 in response to the release of the Build Canada Homes Market Sounding Guide.
We called for this new crown corporation to:
b.
Implement
CAN/ASC 2.8, Accessible-Ready Housing Standard 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.
Incorporating the concepts of accessible and adaptable housing (as defined in CAN/ASC 2.8) in the purpose of the bill would make inclusion and accessibility a core principle of the mandate of the Corporation and serve as a significant consideration in the corporation’s decision-making instead of an afterthought or being overlooked altogether.
2. The following language should be added to Article 7, “Establishment and composition”:
A minimum of 27 per cent of directors must have living experience of disability.
Build Canada Homes has a responsibility to reflect the population it serves and to make sure its governance is informed by diverse living experiences as a publicly funded corporation. At least 27 per cent of people in Canada have a disability on the Board of Directors aligns governance with the demographic reality and reinforces a commitment to inclusion, equity, and public accountability.
Living experience of disability brings essential insight into how decisions, policies, and services affect people in practice, strengthening oversight and reducing unintended barriers. Meaningful representation at this level is critical to applying an intersectional lens to decision making, recognizing how disability intersects with race, gender, Indigeneity, age, income, and other factors to compound inequities. A benchmark of 27 per cent moves beyond tokenism and makes sure disability perspectives are consistently embedded in governance and contributes to more informed, effective, and equitable outcomes.
3. Article 20 (c,d) should be modified as follows:
(c) invest in persons or entities carrying on activities in respect of the supply of affordable and inclusive, accessible and/or adaptable housing in Canada, including by acquiring their shares or securities or by making a loan or guarantee to the person or entity.
(d) invest in ventures or enterprises, including through the acquisition and development of property, that are likely to benefit the supply of affordable, inclusive, accessible and/or adaptable housing or the adoption of innovative and efficient building techniques in Canada.
Investments in inclusion and accessibility deliver strong returns: lower healthcare costs, reduced reliance on institutional care, and better quality of life for people with disabilities of all ages . 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 – and this is just in the City of Toronto. Investing in inclusion and accessibility is not only equitable, but also economically and socially smart.
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 inclusion and accessibility be integrated as a core priority in the Build Canada Homes mandate.
We urge the federal government to embed accessibility in Build Canada Homes corporation with a strong connection to already-established voluntary national standards, where inclusive, accessible, and affordable housing is not a goal we aspire to but a baseline we meet.
About March of Dimes Canada
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.
Together with our partners, we serve, connect, and empower people with disabilities to participate fully in life and in their communities on their own terms. Our work is grounded in the voices of the people we serve, built on a foundation of service, and backed by more than 70 years of success.
We’ve proven time and again our dedication to serving the needs of people with disabilities. Born in one of the 20th century’s greatest public health crises, we know that seemingly impossible goals can be achieved, and barriers can be broken. In the 1950s, MODC helped fund a vaccine for polio. Now, we are working on creating communities in which people with disabilities can live and thrive nationwide.
We’re proud to support people with disabilities across Canada, from the early years to seniors. Our services extend beyond the individual to families who feel the impact of disability in different ways. Their collective experiences play a critical role in shaping our work as a service provider, resource, and advocate, which is focused in four areas:
- The best start for children, youth, and families.
- Independence at home and in the community.
- Active, healthy, connected lives.
- Financial security.
These are the things people with disabilities told us they need, want, and expect out of life.
Our staff and volunteers are allies, supporters, and champions committed to making a difference for people with disabilities. With the guidance of our community, and working together with our donors and partners, we provide the tools and support our service users need to live independently, improve their health and wellness, and thrive in all they aspire to do.
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 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
9 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/
10 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
11 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
12 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
13 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
14 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
15 "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
16 10-year capital plan | Toronto Community Housing. Accessed August 14, 2025. https://torontohousing.ca/building-construction-and-revitalization/capital-repairs/10-year-capital-plan
