Who counts as disabled depends on where you’re standing at the bus stop. A new comparative study of public transit rules in Canada and the United States finds that the definition of disability changes from one jurisdiction to the next. That means a rider who qualifies for accessible service in one city or province may not qualify in the next one.
The study, published in the Journal of Disability Policy Studies, was carried out by researchers at the University of British Columbia, the University of Illinois Chicago and the Vancouver-based disability advocacy group Live Educate Transform Society (LET’S). The team examined transportation policies at three levels of government in both countries: municipal, provincial or state, and federal.
A patchwork of definitions
The researchers looked at three things in each policy: what it set out to achieve, how it defined disability, and what it actually required of transit providers.
The definitions turned out to be inconsistent. Because eligibility for accessible transportation depends on those definitions, the authors say the inconsistency splits people into two groups: those who are covered and those who are not. Two people with similar needs can get different treatment depending on which set of rules applies to them.
The two countries’ top-level laws were written decades apart. The Americans with Disabilities Act dates from 1990. Canada’s federal equivalent, the Accessible Canada Act, did not pass until 2019. Below the federal level, transit is shaped by a mix of provincial, state and local rules, which leaves plenty of room for those rules to differ.
Ramps and lifts, but not people
In both countries, the policies concentrated on physical infrastructure: the built environment around transit, modifications to vehicles, and the provision of services such as specialized transit.
Far fewer policies addressed what the authors call social accessibility, meaning how riders with disabilities are treated by transit staff. The researchers describe this as a significant policy gap. A wheelchair lift is of limited use if the operator doesn’t know how to deploy it, or if riders with less visible disabilities are met with suspicion or impatience. The authors argue that policies should include more training requirements for transit workers.
Canada’s funding gap
The comparison also found that dedicated funding for transit agencies to serve people with disabilities was largely missing, particularly in Canada. Rules that require accessibility without paying for it leave agencies to absorb the cost, and implementation tends to suffer.
The authors call on policymakers to create funding mechanisms so that accessibility requirements actually show up in services and infrastructure, not just on paper.
Why it matters
The researchers point out that public transportation is how many people with disabilities get to work, school, medical appointments and social life. Previous research has documented that people with disabilities face persistent barriers to using transit. This study suggests that some of those barriers are built into the policies meant to remove them.
Source: Labbé, D., Yao, D. P., Scales, T., McCain, H., Miller, W. C., & Mortenson, W. B. (2025). “Inclusion of People With Disabilities in Public Transportation: A Case-Study Analysis of Canada and U.S. Policies.” Journal of Disability Policy Studies, 37(1). https://doi.org/10.1177/10442073251370266
