Accessibility Hub: Manitoba Human Rights Code

Manitoba Human Rights Code — what it requires, who it applies to, and what it can mean for your website and digital content

Ontario Human Rights Code at a glance

The Human Rights Code (Manitoba) is Manitoba’s provincial human rights law. It protects individuals and groups in Manitoba from unreasonable discrimination and is administered by the Manitoba Human Rights Commission.

In practice, the Code matters for more than employment: it also applies to services available to the public, housing/accommodation, contracts, and more—so it can affect public-facing digital experiences (websites, forms, online service journeys).

Discrimination under the Code can include differential treatment, failure to provide reasonable accommodation, and harassment.

Note: This content is provided for general information only and does not constitute legal advice. If you need a formal interpretation of requirements for your organization, consult qualified legal counsel and your compliance team.

When the Manitoba Human Rights Code applies

Public-facing digital experiences: If you provide services to people in Manitoba through a website, portal, app, or online forms, the Code can be relevant because it prohibits discrimination in services available to the public.

Employment: The Code applies to hiring and employment practices (often HR-led), including accessibility-related accommodation needs connected to protected characteristics.

Housing/accommodation and contracts: The Code also applies to rental units and other accommodation contexts, and to contracts—areas that may include digital touchpoints (applications, disclosures, forms).

Does the Manitoba Human Rights Code apply to me?

If you operate in Manitoba as an employer, a landlord/housing provider, or a service provider offering services to the public (or a section of the public), you should assume the Code is relevant.

If your organization publishes public-facing web content used by Manitobans (web pages, online applications, PDFs, videos), accessibility and accommodation considerations may be part of providing equal access to services.

If you rely on third-party tools (embedded forms, booking tools, chat widgets), barriers introduced by vendors can still create risk—plan for vendor due diligence and/or accessible alternatives.

If you’re unsure whether or how the Code applies to your organization, treat this page as a practical overview and confirm your specific obligations with qualified legal counsel.

Protected characteristics (grounds)

The Code protects people in Manitoba from discrimination based on specific characteristics. The Province of Manitoba summarizes these protected characteristics as:

Ancestry (including color and perceived race)
Nationality or national origin
Ethnic background or origin
Religion or creed (including religious belief, association, or activity)
Age
Sex (including sex-determined characteristics or circumstances, such as pregnancy and circumstances related to pregnancy)
Gender identity
Sexual orientation
Marital or family status
Source of income
Political belief, political association, or political activity
Physical or mental disability (or related characteristics/circumstances, including reliance on a service animal, wheelchair, or other remedial appliance/device)
Social disadvantage

What discrimination can include (practical view)

Differential treatment: When someone is treated differently based on assumptions or generalizations about a protected group, rather than on individual merit.
Failure to provide reasonable accommodation: When an employer, landlord, or service provider does not make reasonable changes that allow for equal opportunity and access—up to the point of undue hardship.
Harassment: Abusive and unwelcome behaviours or comments directed at someone because they belong (or are thought to belong) to a protected group.

For digital teams, these concepts show up when barriers in websites, online forms, PDFs, or support channels make it harder for some users to access the same service, information, or outcome as others. In addition to building accessible experiences, organizations often need a clear process to respond to requests for alternate formats or supports.

Examples in digital services

An online form that can’t be completed using only a keyboard (or where focus is not visible).

Required fields or errors that are only indicated by color, with no clear text message.

A PDF application package that is scanned/un-tagged and unreadable by screen readers.

Critical service information posted only as an image (no text alternative) or only in a video without captions.

No clear way to request an alternate format (or requests go to an unmonitored inbox).

A third-party booking/chat tool that introduces barriers with no accessible alternative path.

Common pitfalls to avoid

Don’t make the only option a phone call—offer at least one accessible digital contact path.

Don’t publish time-sensitive or required information only in scanned PDFs or images.

Don’t rely on “we’re compliant” statements from vendors—ask for evidence and test key flows.

Don’t treat accessibility as a one-time project—new content and releases can reintroduce barriers.

What you may need to do (digital and content implications)

Make your website usable for everyone: Reduce barriers on key pages, navigation, forms, and core user journeys. Many organizations use WCAG 2.0 Level AA as a common benchmark for reducing accessibility barriers, and aim for WCAG 2.1 or 2.2 as a best practice for better mobile accessibility and future-proofing. (WCAG references here are provided as practical guidance, not legal advice.)
Provide accessible documents and media: Prefer accessible web pages; make PDFs accessible when you must use them; add accurate captions to videos and provide transcripts when appropriate.
Offer a way to request alternate formats/support: Ensure people can request information in accessible formats or with communication supports—and that requests are routed to the right team.
Have a clear feedback/complaints path: Provide a way for users to report barriers and ensure you respond in a timely way.
Train the right people: Staff who publish content, design experiences, build features, or support users should understand accessibility basics and how to handle accommodation-related requests.
Manage third-party risk: Check accessibility of embedded tools (forms, booking, chat) and have a plan for remediation or an accessible alternative.
Keep it from slipping over time: Accessibility needs ongoing checks as content changes, new features launch, or vendors update components.

How this connects to “reasonable accommodation”

Accommodation is often described as adjusting a rule, policy, practice, or environment to remove barriers linked to a protected characteristic—so a person can access the same opportunity or service as others. In digital contexts, that can mean removing accessibility barriers in the experience itself and/or providing an alternate format or supported path where needed. Accommodation decisions are typically case-by-case, and organizations should confirm approach and obligations with legal counsel.

If someone requests accommodation (simple process)

Acknowledge the request promptly and confirm who owns next steps.
Clarify the barrier and the outcome the person is trying to achieve (not just the format they used).
Provide an option that works: fix the barrier where feasible and/or offer an alternate accessible format or supported path.
Confirm timelines and any interim workaround if a full fix will take time.
Document what was requested, what was provided, and why (especially where options are limited).
Feed the issue into your backlog so the same barrier doesn’t affect the next person.

How 4Point can help

If you’re unsure how Manitoba human rights obligations relate to your digital presence—or where to start—4Point can help you assess your current state, prioritize fixes, and build a practical plan to improve accessibility and reduce barriers over time.

Start with an accessibility audit. If you’re unsure where you stand in reducing accessibility barriers (and how your digital experiences align to common benchmarks like WCAG), 4Point can run a practical audit to establish a baseline, identify the highest-risk barriers, and give you a prioritized remediation roadmap.

Scoping session: confirm which forms are in scope, the number to be reviewed, and the accessibility standard(s) to assess against.
Forms accessibility audit: review an agreed number of forms and document accessibility gaps.
Conformance report and prioritization: provide conformance findings, severity ratings, and a recommended fix order.
Recommendations and remediation plan: share recommendations for addressing identified gaps and provide a statement of work for remediation of the audited forms (remediation is not included in the audit engagement).

Next step: request an audit by sharing your digital scope (properties, platforms, documents), your target standard (e.g., WCAG 2.1 AA), and any upcoming procurement or reporting deadlines. We’ll confirm the audit approach, sample size (templates/journeys), and deliver a prioritized findings summary with recommended fixes.

Contact 4Point: Request an accessibility audit

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