Accessible Phone Menus: ADA, AODA and ACA Explained

The short answer

As of October 2026:

• United States (ADA Title III). If your business serves the public and uses an automated attendant or IVR, that system "must provide effective real-time communication" with people using TTYs and FCC-approved relay services, including Internet-based relay ^[1]. You do not need your own TTY.
• FCC Section 255 applies to providers of phone, VoIP, voicemail and interactive menu services and to equipment makers ^[2]. It is aimed at your phone provider, not at you.
• Ontario (AODA). Any organization with employees in Ontario must provide accessible customer service. Paperwork and reporting duties increase at 20 and 50 employees ^[3].
• Federal Canada (Accessible Canada Act). The Act covers federal bodies and businesses within Parliament's legislative authority. Most small businesses are outside it ^[4].

None of these rules sets a timeout in seconds, a maximum number of options or a required "repeat" key. Those are design choices, and the checklist below covers them. This article is educational, not legal advice.

Why menu design is an accessibility question

A phone menu asks the caller to listen, remember, decide and press a key, often against a clock. Each of those steps can block someone:

• Relay users (deaf, hard-of-hearing or speech-disabled callers) have an operator in the middle who relays each prompt and enters each choice. Every step takes longer.
• Callers with hearing aids or in noisy places miss options and need them repeated.
• Blind and low-vision callers using a smartphone may have to take the phone away from their ear to find the keypad. A Missouri state IVR guideline asks for "an appropriate pause between menu items and between different menus" because cell phone users have to do this ^[5].
• Callers with memory or cognitive disabilities struggle with long lists. The same guideline sets a maximum of five items, "because people cannot actually see the menu items."

The FCC's definition of an "accessible" interactive menu names these needs directly. It includes "operable without time-dependent controls," meaning at least one mode "that does not require a response time or allows a response to be by-passed or adjusted by the user over a wide range" ^[6]. That definition binds providers, not you. It is still a useful design target.

What the ADA expects from a US small business on the phone

Title III covers "businesses and nonprofit organizations that serve the public" ^[7]. For phones, four points matter:

1. Effective communication. Businesses must provide auxiliary aids and services (such as TTYs) unless that would be an "undue burden," meaning "significant difficulty or expense" ^[7].
2. Relay calls. "Covered entities are also required to accept telephone calls placed through TRS and VRS." The free nationwide relay service is reached by dialing 7-1-1 ^[7]. Relay calls must be answered "in the same manner" as other calls ^[1].
3. Automated attendants. If you use "an automated-attendant system, including, but not limited to, voicemail and messaging, or an interactive voice response system, for receiving and directing incoming telephone calls," it must provide effective real-time communication with TTY and relay users ^[1].
4. No TTY required. You may use relay services instead of direct communication, and you are not required "to use a TTY" ^[1].

The regulation does not say how to meet point 3: it sets no timeout, no option count and no key layout. The practical test is whether a relay user can get through your menu to the right person or voicemail box. A menu that hangs up after one silent pass is the kind of design that can fail.

FCC Section 255: who it actually binds

On February 25, 2026, the FCC issued Public Notice DA 26-190. It reminds covered entities that Section 255 applies to "any provider of telecommunications service, interconnected VoIP, voicemail, or interactive menu service," to equipment manufacturers, and to carriers ^[2].

A clinic or trades business that buys a number with a menu is the provider's customer. The notice is addressed to "service providers and equipment manufacturers," and nothing in it asks a business that only answers its own calls with a menu to file anything. Your duties as a business come from the ADA and from state or provincial law. Section 255 does give you a good question for a vendor: what accessibility features does your menu service have?

Ontario AODA: customer service rules for small employers

Under the Accessibility for Ontarians with Disabilities Act, 2005, you are exempt only "if you do not have employees in Ontario." Full-time, part-time, seasonal and contract workers count toward the thresholds. Volunteers and independent contractors do not ^[3].

Every covered organization must provide customer service that lets people with disabilities access its goods and services. That includes "communicating in a manner that takes a person's disability into account," "providing notice of temporary disruptions," and accessible ways to give feedback ^[3]. The page does not mention telephones, but your main line is where much of that communication happens.

Source: ^[3], updated June 16, 2026. The current filing deadline for organizations with 20 or more employees is December 31, 2026.

What this means for your phone line:

• Use your closure prompt for "temporary disruption" notices: what is unavailable, and when it returns.
• Accept feedback by phone, and make voicemail easy to reach from the menu.
• Include relay calls in staff training.

We could not load the regulation itself (O. Reg. 191/11), so this section relies on the province's guidance.

Federal Canada: the Accessible Canada Act

The Act applies to federal government entities, certain Crown corporations, the Canadian Forces, and any organization that "carries on an undertaking or business that is within the legislative authority of Parliament" ^[4]. Most retail, trades, clinic and professional-services businesses are provincially regulated and fall outside it.

Even for federally regulated businesses, the Accessible Canada Regulations exempt an entity with "an average of fewer than 10 employees" from the duties to publish accessibility plans, feedback processes and progress reports (sections 47-49, 56-58, 65-67 and 69-71 of the Act). The exemption ends in any year the average reaches 10 or more ^[8]. CRTC telecom accessibility rules and provincial human rights codes are outside this article's scope.

Design checklist: timeouts, repeats and fallbacks

About timeouts. None of these sources gives a required number, and your platform may not let you set one. The safe pattern does not depend on it: on silence, replay the menu; if there is still no choice, route the call to a person or a shared voicemail box instead of ending it.

Sample menu:

"Thanks for calling Northside Dental. For appointments, press 1. For billing, press 2. To leave a message, press 3. To hear these options again, press 9."

(No key:) replay the options once.

(Still no key:) send the call to the general voicemail box.

More wording is in our phone menu scripts for small business, and the research behind it is in phone menu design evidence.

Handling relay and TTY callers on a menu system

United States. Relay users reach you through 7-1-1 or Internet-based and video relay ^[7]. Your menu plays to the operator, who relays it and enters the caller's choice.

Canada. Each carrier runs its own relay service. For example, Bell tells TTY users to dial 711, gives voice callers 1 800 855-0511, and says operators are available 24 hours a day. It also advises people calling organizations to give the operator the department, contact name and extension ^[9]. Other carriers publish their own numbers.

Staff checklist:

1. Do not hang up on the relay introduction.
2. Speak to the caller, not the operator.
3. Pause after each question; relay adds delay.
4. Make voicemail and closed-hours messages say plainly what to do next.
5. Every few months, place a relay test call through the full path: menu, transfer, no answer, voicemail.

Our relay call test for small-business phone menus walks through the test.

FAQ

Am I legally required to have a TTY line? Under the ADA Title III regulation, no. You may use relay instead, but you must accept relay calls ^[1].

Does my menu itself need to be accessible? In the US, a Title III business's automated attendant must communicate effectively with TTY and relay users ^[1]. In Ontario, the duty to communicate in a way that takes disability into account covers customer service generally.

What is a reasonable timeout? No source we reviewed sets one. Design the menu so a slow response costs nothing: replay, then fall back to a person or voicemail.

Do I file anything with the FCC? The Section 255 certification falls on providers and manufacturers, not on businesses that only use a menu.

Auto Attendant menus use text-to-speech prompts, up to seven options, and voicemail by email with a transcript, which is enough for a short menu with a voicemail fallback.

Sources

1. 28 CFR 36.303, eCFR (DOJ ADA Title III rule): automated attendants and relay, no TTY required.
2. ADA Requirements: Effective Communication, ADA.gov: Title III coverage, undue burden, relay calls, 7-1-1.
3. Public Notice DA 26-190, FCC, February 25, 2026: who Section 255 covers; recordkeeping and certification.
4. 47 CFR part 7, eCFR: definition of "accessible"; provider and manufacturer duties.
5. 47 CFR 14.31, eCFR: records and annual April 1 certification.
6. Accessibility rules for businesses and non-profits, Government of Ontario: AODA duties by size; December 31, 2026 deadline.
7. Accessible Canada Act, s. 7, Justice Laws Website: who the Act applies to.
8. Accessible Canada Regulations, SOR/2021-241, Justice Laws Website: fewer-than-10-employee exemption.
9. The UX of Phone-Tree Systems: 16 Usability Guidelines, Nielsen Norman Group, 2022: menu usability patterns.
10. Press or Say 1, USAGov, 2020: repeat and back options.
11. IVR Guidelines, Missouri Office of Administration, 2006: pauses, five-item limit, key after description.
12. Bell TTY relay service, Bell Canada: 711, voice access number, hours.