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CNIB’s feedback on the Canada Disability Benefit Regulations

The federal government recently launched a public consultation to gather feedback on the proposed Canada Disability Benefit Regulations (hereafter “the Regulations”) which, once approved by the Government of Canada, will set out technical details for the design and implementation of the Canada Disability Benefit (CDB). The new benefit, scheduled to launch in July 2025, aims to reduce disability poverty and strengthen the financial security and independence of Canadians with disabilities across every province and territory.

CNIB submitted feedback to the consultation, informed by an engagement survey distributed to our community members asking for their perspectives on key aspects of the Regulations. Our final submission brief made 14 recommendations to the Government and touched on topics including eligibility criteria, payment amounts, program administration, employment supports, and more.

Read our complete submission brief, including a full list of our recommendations.

The submission brief describes the technical and design elements that must be included in the Regulations to ensure the CDB works effectively to support Canadians with sight loss while upholding their independence and dignity. 

Here is a summary of CNIB’s recommendations:

  • Prevent clawbacks – The federal government must work with provincial and territorial counterparts to ensure each province and territory has an established agreement to ensure existing benefits for persons with disabilities will not be clawed back or negatively impacted by income received through the CDB. 
  • Expand eligibility – The Disability Tax Credit (DTC) cannot be the only pathway to eligibility for the CDB, as there are many barriers that prevent Canadians with disabilities from accessing it. The Government must create additional pathways to eligibility for Canadians with disabilities who would otherwise be eligible for the CDB, but do not hold a DTC Certificate. Automatic eligibility should also be expanded to include current beneficiaries of any federal, provincial, or territorial disability benefit.
  • Increase payment amounts – The proposed maximum payment amount of $200 monthly is inadequate to lift Canadians with disabilities out of poverty. The Regulations should establish a mandatory minimum amount to be paid for all persons with disabilities deemed eligible to receive payment amounts from the CDB. This amount must be sufficient to provide a basic livable income and account for the additional costs of living with a disability. 
  • Individualize payment amount calculations – Calculating CDB payment amounts based on the collective income of an individual beneficiary and their spouse or common-law partner serves to undermine the independence and dignity of the person with a disability. Payment amounts for CDB beneficiaries should be calculated according to their individual income alone.
  • Increase income thresholds – The annual income thresholds to receive the maximum CDB payment amount are too low to capture a significant number of Canadians with disabilities currently experiencing poverty or acute financial insecurity. The thresholds must be increased to reflect, at minimum, the Official Poverty Line as defined by the Market Basket Measure, to ensure all Canadians with disabilities living on or below the Official Poverty Line will be eligible to receive the maximum benefit amount. 
  • Incentivize and support employment – The $10,000 exemption for working income must be increased to incentivize and enable persons with disabilities who can and want to work to access gainful employment, without the risking the safety net provided by their existing benefits. As Service Canada will be administering the CDB, it should also provide attached navigation and referral services to connect interested CDB applicants and beneficiaries with government- and community-based employment programs for persons with disabilities. 
  • Design accessible administrative processes and assets – The Government must ensure that all administrative processes and assets are designed with accessibility at the forefront. This includes making documents and information available in accessible alternate formats (i.e., braille, large print, or audio) and ensuring that all digital assets are compliant with the latest WCAG guidelines, and usable on mobile devices and with screen reading or magnification software. All assets must be user tested by persons with varying types and levels of sight loss. A centralized location, such as an online portal, should be created to house all information and required forms and documents necessary to complete an application or appeal, as well as contact information to access assistance. 
  • Provide assistance from dedicated Service Canada staff – Assistance must be available online, by phone, or in-person from live Service Canada agents to answer questions and assist individuals with completing applications or filing an appeal. These agents must be provided enhanced training to mitigate attitudinal barriers. 

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