Pre-Budget Consultations in Advance of the Upcoming Federal Budget

​Submission to the Minister of Finance 


Fiscal Year 2027-28


September 2026

In September 2026, March of Dimes Canada responded to an open consultation launched by the Department of Finance on Budget 2026.

Introduction​

March of Dimes Canada (MODC) is pleased to submit our federal Pre-Budget Submission for fiscal year 2026–27. As a national service provider, advocate, and policy influencer dedicated to the rights and inclusion of people with disabilities, we work closely with our community to identify priorities that can transform public systems and ensure equity.

People with disabilities in Canada continue to face unacceptable rates of poverty, unemployment, social exclusion, and housing insecurity. Federal leadership is urgently needed to address these systemic challenges with concrete investments in accessibility, income security, and inclusive public systems.

Our recommendations are rooted in our ongoing programs and recent stakeholder consultations, and align with federal commitments outlined in the Disability Inclusion Action Plan and Canada’s obligations under the UN Convention on the Rights of Persons with Disabilities (UNCRPD).


Summary of Recommendations

Recommendation 1:
That the federal government remove benefit takeup barriers through Disability Tax Credit (DTC) reform by:
  • Replacing the restrictive DTC disability definition with a new broader definition to align with the Accessible Canada Act and granting automatic DTC eligibility to people receiving disability benefits through income support.
  • Overhauling DTC application processes and supports to remove barriers.
Recommendation 2:
That the federal government fund an exploration of the feasibility of a national disability status program to further remove barriers to disability benefit access for people with disabilities in Canada. 

​Recommendation 3:
That the federal government expand accessible and affordable housing by: 

Working with Build Canada Homes, provinces and territories, and municipalities to require inclusive and accessible design in all new housing developments. 

  • Updating the National Building Code, and supporting the standardization of accessibility requirements across jurisdictions. 
  • Establishing targeted rent supports and homeownership incentives for low- and modest-income people with disabilities. 
  • Meaningfully engage disability community organizations in the development of all related policies and programs and in decision-making processes.​

Recommendation 1:
Remove benefit takeup barriers through Disability Tax Credit reform

People with disabilities in Canada are fifty per cent more likely to experience poverty and twice as likely to experience food insecurity, yet hundreds of thousands of them are not accessing government supports for which they are entitled, and that would improve their lives. Disability related costs vary widely depending on individual needs, and can range from hundreds to thousands of dollars annually. As a result, many people with disabilities must forgo essential aids and devices, medications, and other supports. In 2022, 56 per cent—more than 3.2 million—of people with disabilities in Canada reported unmet needs due to cost1, more than doubling from 26 per cent in 2017.


Qualifying for the federal Disability Tax Credit (DTC) opens the door to receiving the Canada Disability Benefit (CDB) and 16 other federal disability programs, as well as a growing number of provincial and territorial programs. But the DTC was never designed to be the de facto eligibility test for all other disability supports, and far too few eligible people can access it. 

According to Statistics Canada, just 14.6 per cent of people with disabilities and only 34.8 per cent of those with very severe disabilities claim the DTC.2  There are many reasons people do not or cannot claim the credit, including an overly restrictive definition of disability and persistent administrative barriers. This has serious and far-reaching consequences, excluding people with disabilities from the very programs intended to support their right to an adequate standard of living. 

MODC welcomes the first steps taken to reform the DTC in Spring Economic Update 2026. We applaud the federal government for making several recent administrative changes that improve access to the DTC. These are expected to unlock an estimated $345 million in support over six years for people facing access barriers.3  This is a solid foundation on which to build. Finally, federal investments in navigation services and support for MODC’s “Enhancing Benefit Takeup for People with Disabilities through Multi Sector Stakeholder Engagement” project are essential in promoting benefit takeup for people with disabilities across Canada.

But there is much more to be done, and it will require fundamental reform.

We join the other members of the National Disability Network to call on the federal government to commit to a collaborative process to design a new eligibility system that:
  • Uses the Accessible Canada Act’s definition of disability as the starting point for access to federal disability programs.
  • Creates a centralized disability status determination process outside the tax system that is dignified, accessible and rights-based.
  • Automatically extends federal disability certification to people already receiving disability benefits through provincial or territorial social assistance programs.

While a new eligibility system is created, we also call for further action to remove administrative barriers to the existing DTC process for people with disabilities and medical practitioners, including:
  • A new plain-language DTC application form, designed in collaboration with medical practitioners, that enables applicants to complete the functional assessment themselves and asks medical practitioners to certify accuracy.
  • Continued expansion of the list of medical practitioners authorized to fully certify disability for the DTC.
  • Direct reimbursement of medical practitioners who certify DTC applications, as already occurs with Canada Pension Plan disability benefit applications.4
  • A plan to reduce the unnecessary use of temporary DTC certificates, along with a commitment to establish simplified renewal processes nationwide, building on the recent Manitoba pilot.5
  • More flexibility in the interpretation of the phrase "all or substantially all of the time" when evaluating restrictions on daily living.6 
  • Allowing supported decision-making for DTC applications and administration. 
  • Increased funding for the Disability Benefit Navigation program, which supports community-based organizations in helping people access the DTC, the CDB, and provincial and territorial disability benefits.
  • Amending Section 118.3(1)(a.2) of the Income Tax Act to include occupational therapists (OTs) as eligible certifiers for the Mental Functions for Everyday Life section of the Disability Tax Credit (DTC). This would expand community-based access for people with disabilities, reduce certification burden, and align the DTC with the functional expertise that already exists within our healthcare system.

All reforms must be designed in partnership with people with disabilities, in accordance with Canada’s human rights commitments under the UNCRPD. Central to the UNCRPD is the principle of “nothing about us without us,” which affirms that people with disabilities must be meaningfully involved in decisions that affect them.

Canada should be a country where disability supports are available to all people with disabilities who need them, and no eligible recipient is denied access to a program because of administrative barriers. These reforms would bring that goal within reach.

Recommendation 2: 

Fund exploration of a National Disability Status Program

One of the most significant barriers people with disabilities face in accessing programs, benefits, and other supports is the repeated need to ‘prove’ their disability. As demonstrated in Prosper Canada’s and MODC’s A Benefit Without Barriers Report, the current system involves onerous and redundant processes that require people with disabilities to provide the same documentation to multiple government departments to access benefits, requiring them to demonstrate their disability multiple times. This structure can make people feel a lack of respect and dignity, cause psychological and physical stress, and foster a lack of trust in government agencies, discouraging people from applying for the benefits to which they are entitled.7 

A federal disability status program could:
  • Provide a consistent way for a person to demonstrate that they have a recognized disability. The status could be accepted across participating federal programs and potentially recognized by provinces, territories, municipalities and private-sector organizations. 
  • Support more automatic enrolment into government programs and allow people to reuse previously approved documentation.
  • Be represented by a physical or digital credential, but the larger concept is not simply a disability identification card. It is a coordinated approach to recognizing disability that reduces the need for repeated assessments and creates a reliable foundation for accessing programs and services.

The purpose of a federal disability status would be to make systems across all sectors easier to navigate and reduce the administrative burden placed on people with disabilities. It has the potential to reduce or eliminate the extent to which the DTC is used as a default gateway to programs for which it was not originally designed. 

The federal Disability Advisory Committee has repeatedly called for greater coordination across departments. The Disability Advisory Committee to the House of Commons has also recommended streamlining disability-related reporting requirements.8 

Disability status programs are used in other jurisdictions (including Japan, Germany, the Philippines, and several EU member states through the European Disability Card pilot project9), and a Canadian solution offers the potential to significantly remove barriers to inclusion and lift more people with disabilities out of poverty. This potential solution should be explored through deep engagement and co-creation with people with lived and living experience of disability.
MODC urges the Minister of Jobs and Families to commission a study into the potential benefits, risks, and structure of a federal disability status program, with full engagement of people with disabilities in all stages of the study. 

Recommendation 3:
Expand accessible and affordable housing

In 2019, the Government of Canada enshrined housing as a human right in the National Housing Strategy Act (2019).  As a signatory to the UN Convention on the Rights of Persons with Disabilities, Canada is obligated to uphold the equal right of persons with disabilities to live independently and within the community, with the freedom to choose their place of residence on an equal basis with others. Unfortunately, due to the lack of affordable, accessible housing in Canada, many people with disabilities are unable to access housing that meets their needs and enables them to remain independent in their own homes and communities. Further, it is critical that disability community organizations and people with disabilities in Canada are meaningfully engaged in policy and program development processes related to housing meant for them. 

We welcome the progress the federal government has been made by creating the National Housing Design Catalogue using inclusive design principles, and by developing Accessible Standards Canada guidance for accessible ready housing for federally regulated entities. 

We ask that the federal government: 
  • Work with Build Canada Homes, provinces, territories, and municipalities to ensure new housing is designed to be inclusive, accessible, and adaptable. 
  • Fund updates to the National Building Code to reflect inclusive design principles and that you standardize accessibility requirements across provincial and territorial building codes. 
  • Establish targeted rent supports and home ownership incentives for low- and modest-income people with disabilities, for example, the Canada Housing Benefit System proposed by Maytree​.
  • Engage disability community organizations and people with disabilities in Canada in meaningful, substantive ways as housing policy, programs, and investment decisions are developed and implemented. 
 

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About MODC

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 75 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.​




1 Hébert, B., et al. (2024). A demographic, employment and income profile of persons with disabilities aged 15 years and over in Canada,​ 2022. Canadian Survey on Disability Reports. Released May 28, 2024.

2 McDairmid, C., & Choi, R. (2026). Technical Report on Disability Measurement in Canada. Statistics Canada. Statistics Canada: Technical Report on Disability Measurement in Canada

3 Government of Canada. (2026). Canada Strong for All: Spring Economic Update 2026. Government of Canada: CPP Disability Benefit Information for Health Care Professionals

4 Government of Canada. (2026). “Information for health care professionals.” https://www.canada.ca/en/services/benefits/publicpensions/cpp-disability-benefit/medical-professionals.htm​

5 Doctors Manitoba. (2025). Manitoba Pilots Shorter Disability Tax Credit Renewal Form. Doctors Manitoba: Manitoba Pilots Shorter DTC Renewal Form

6 Disability Advisory Committee. (2024). 2024 Fifth Annual Report of the Disability Advisory Committee. Disability Advisory Committee 2024 Annual Report

7 March of Dimes Canada & Prosper Canada. (2023). A Benefit Without Barriers: Co-Creating Principles and Recommendations for Canada Disability Benefit Administration. A Benefit Without Barriers Report (PDF)

8 May, Bryan (Chair), Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities. (2019). Taking Action: Improving the Lives of Canadians Living with Episodic Disabilities. ​ Taking Action: Improving the Lives of Canadians Living with Episodic Disabilities (PDF)

9 European Commission. (Accessed August 31, 2026). European Disability Card and European Parking Card for Persons with Disabilities. European Commission: European Disability Card and Parking Card Information


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