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CARP National Policy Paper for Members
Hearing Health Should Not Stop at Provincial Borders: Why Canada Needs Responsible Access to Over-the-Counter Hearing-Aid Technology
May 2026
Executive summary
CARP supports responsible provincial policy changes to allow adults in Canada to access safe, regulated, over-the-counter hearing-aid technologies. This includes new software-enabled devices such as Apple’s Hearing Test and Hearing Aid features, as well as other Health Canada-licensed over-the-counter hearing technologies that may emerge.
CARP recommends that Ontario modernize its hearing-health framework by permitting responsible access to regulated over-the-counter hearing-aid technologies for adults with perceived mild-to-moderate hearing loss, while maintaining strong professional, diagnostic, prescription, and public-support pathways for those who need them.
Hearing loss is common, gradual, and often under-recognized. Statistics Canada reports that hearing loss becomes more common with age, with audiometrically measured hearing loss affecting 77% of Canadians aged 60 to 69 and 94% of Canadians aged 70 to 79. Statistics Canada also found that many Canadians are unaware they have hearing loss; an estimated 54% of Canadians aged 40-79 – about 8.2 million people- had at least mild high-frequency hearing loss, yet 77% of them did not perceive any hearing loss.
CARP members understand how policy change happens. Often, people become most aware of a problem when they begin experiencing it themselves. But the policies they fight for do not benefit only them. That has been true for pensions, income supports, drug benefits, accessibility, and age-discrimination protections. It is true again here. Even Canadians with excellent hearing today should support responsible access now, because hearing needs change over time, and the system we build today will serve current and future generations.
The issue
Canada is at an important hearing-health policy moment.
Health Canada has already issued Class II medical device licences for Apple’s Hearing Test Feature and Hearing Aid Feature. Health Canada’s active licence listing for Apple shows a Hearing Test Feature licence issued December 11, 2024, and a Hearing Aid Feature licence issued the same date, with listed components including AirPods Pro firmware, iOS app, macOS, and watchOS elements.
Yet Apple’s Canadian feature-availability page states that, because of regulatory restrictions, Apple is unable to release the Hearing Test and Hearing Aid features in Canada at this time. Apple also states that the Hearing Aid feature is intended for people with perceived mild to moderate hearing loss and that the Hearing Test and Hearing Aid features are intended for people 18 years or older.
That gap is the problem. Federal licensing is necessary, but it is not sufficient. Provincial rules still determine whether a person can access a hearing aid without a professional prescription or dispensing process. CASLPO’s Ontario task force explains this clearly: Health Canada licenses medical devices federally, while provinces regulate whether health-care practitioners must be involved in public access to those devices.
For a mobile app-based health feature, this creates a practical national problem. Software does not respect provincial borders. If a supplier cannot confidently release a feature across Canada, the result may be that Canadians in every province lose access, even where the local rules are less restrictive.
That is why CARP is calling for a coordinated national provincial effort. Canada should not allow a patchwork of provincial rules to block access to safe, regulated hearing technology that has already been reviewed through federal medical-device processes.
Ontario is now consulting
Ontario has launched a 30-day consultation, beginning April 28, 2026, on whether to allow the sale and use of certain devices that function as hearing aids without a prescription. Under current Ontario regulations, hearing aids are dispensed only with a prescription from a regulated health professional, and devices such as earbuds with built-in hearing-aid functionality cannot activate those capabilities in Ontario.
Ontario has also stated that this change would not replace the current prescription system or affect access to prescribed hearing aids through the Assistive Devices Program. CityNews reported that Ontario’s Assistive Devices Program (ADP) covers up to 75% of the cost of hearing aids for eligible residents, to a maximum of $500 per aid, and that over-the-counter (OTC) devices would not be eligible for ADP coverage.
CARP supports Ontario moving forward, while protecting the existing professional and ADP pathways.
However, OTC access should not become an excuse to weaken public coverage, reduce professional care, or shift costs onto seniors. Instead, it should create another entry point for adults with perceived mild-to-moderate hearing loss.
The national picture
Canada needs more than one province to move. It needs a country-wide provincial effort.
Alberta appears to already be compatible with OTC access. The Alberta College of Speech-Language Pathologists and Audiologists says Alberta’s Health Professions Act does not specifically regulate the sale of devices, that providing OTC hearing aids is not a restricted activity under the HPA, and that non-regulated individuals are not prevented by that Act from providing OTC hearing aids, while protected titles and certain ear-canal activities remain regulated.
Nova Scotia needs clarification or change. Nova Scotia’s public permit pages state that a Hearing Aid Dealer Permit is required for a company that tests, fits, and sells hearing aids and accessories through retail or direct sales, and that a Hearing Aid Salesperson Permit is required to test, fit, or sell hearing aids and accessories on behalf of a licensed dealer.
Ontario is consulting. British Columbia has also had a consultation process on non-prescribed hearing aids, and CASLPO’s national comparison identifies Ontario, British Columbia, and Quebec as jurisdictions with legislative barriers to OTC hearing-aid access.
The result is a patchwork. Patchwork rules may work for some products, but they are a poor fit for app-enabled hearing technology. A person can cross provincial borders, update a phone, or use the same device in multiple jurisdictions. Consumers should not be left confused about whether a federally licensed hearing-health feature can be used, depending on where they live.
CARP’s position is that each province should create a clear exception allowing adults to access Health Canada-licensed OTC hearing-aid technologies without a prescription, within defined limits and with strong consumer protections.
What over-the-counter (OTC) hearing-aid technology is for
CARP supports OTC hearing-aid access for a defined adult population:
Adults 18 and older with perceived mild-to-moderate hearing loss.
People who notice early signs of difficulty: trouble following conversation in groups, difficulty hearing speech in noisy places, listening fatigue, turning up the television, or missing parts of phone conversations.
People who need a lower-barrier first step into hearing support.
People who are comfortable using app-based setup, or who can be supported by a family member, caregiver, retailer, audiologist, or other professional.
People who understand that if the device does not help, or if symptoms are unusual or concerning, they should seek professional care.
This is consistent with the FDA’s OTC hearing-aid framework, which is limited to adults 18 and older with perceived mild-to-moderate hearing loss. The FDA also explains that OTC hearing aids can include self-fitting tools, tests, software, and wireless technology, and can be bought without a medical exam, prescription, or audiologist fitting.
Apple’s own support materials are similarly clear: the Hearing Aid feature is intended for people 18 years or older with perceived mild-to-moderate hearing loss, and it can use either Apple Hearing Test results or audiogram results from a hearing-health professional.
What OTC hearing-aid technology is not for
CARP is equally clear about what OTC hearing-aid technology is not.
It is not for children.
It is not for severe or profound hearing loss.
It is not for sudden hearing loss, one-sided hearing loss, ear pain, drainage, dizziness, unusual ear shape, suspected earwax blockage, or other red flags.
It is not a replacement for a diagnostic hearing assessment.
It is not a replacement for prescribed hearing aids.
It is not a replacement for audiologists, physicians, ENT specialists, or professional hearing care.
The FDA warns that OTC hearing aids are not intended for severe or profound hearing loss, that people under 18 should receive prescription hearing aids and medical care, and that red-flag symptoms should prompt medical attention.
That should be the Canadian framework too: clear eligibility, clear warnings, clear referral pathways, and no confusion about the role of professional care.
Why access matters
Unaddressed hearing loss is not a minor inconvenience. The World Health Organization (WHO) identifies unaddressed hearing loss as affecting communication, cognition, social isolation, loneliness, stigma, work and education access, falls, higher medical costs, and dementia risk when hearing loss remains unaddressed.
The policy goal should be to move more people from doing nothing to doing something.
For many Canadians, the current pathway feels too expensive, too complicated, too medicalized, or too stigmatized. Some people delay care for years. Some never seek help. Some may not realize their hearing is changing. OTC hearing-aid technology can provide a lower-barrier first step. It may also normalize hearing support in the same way that reading glasses normalized low-barrier vision support.
This does not weaken professional care. It can strengthen it. A person who takes a hearing test, sees a hearing profile, tries a regulated device, and learns that their hearing needs are more complex may be more likely to seek an audiologist or physician than someone who never engages with hearing health at all.
CASLPO’s Ontario task force reached a similar public-health conclusion. It recommended allowing OTC hearing aids for a defined adult population and stated that access may help overcome barriers by offering a more affordable, convenient, and socially comfortable option; it also stated that the broader public-health risk of unaddressed hearing loss in mid-to-later life is greater than the risk posed by allowing some adults to access OTC devices without a prescription.
Hearing health is healthy-aging policy
Hearing health should be understood as part of healthy aging, not as a narrow consumer-device issue.
When hearing loss goes unaddressed, people may begin to withdraw from conversations or from group settings, relying more on family or missing important information in medical, financial, or social settings. Over time, hearing loss can not only affect what someone is able to hear, but also how confidently they can participate in their daily life.
Hearing loss is also a safety issue. New research has linked hearing loss with increased fall risk among older adults due to its effect on environmental awareness, balance, and cognitive load. For seniors, preventing or addressing hearing loss is therefore not about hearing conversations; it is also about maintaining independence, confidence, and safety.
Hearing access is not just about devices. It is about aging in place, staying socially connected, reducing avoidable risks, supporting caregivers, and helping older Canadians remain active in their families and communities.
Responding to professional-care concerns
CARP respects audiologists and professional hearing-care providers. OAPAC describes audiologists as autonomous hearing-health professionals who identify, assess, and manage hearing loss, tinnitus, balance disorders, and other auditory disorders, and notes that OAPAC clinics are audiologist-owned and regulated by CASLPO.
CARP agrees that professional care is essential. The answer is not “OTC instead of audiologists.” The answer is “OTC plus audiologists.”
Professional concerns should shape the safeguards, not block the technology. Those safeguards should include age limits, plain-language warnings, red-flag screening, return policies, user education, retailer obligations, and clear referral routes to audiologists and physicians.
The FDA’s authorization of Apple’s Hearing Aid Feature shows that this can be done responsibly. The FDA authorized Apple’s software as the first OTC hearing-aid software device for compatible AirPods Pro, intended for adults 18 or older with perceived mild-to-moderate hearing impairment. The FDA also reported that a clinical study of 118 subjects found similar perceived benefit between self-fitting and professional fitting of the same device, with comparable measures of ear-canal amplification and speech understanding in noise, and no device-related adverse events observed in the study.
That does not mean every person should use such a device. It means regulated access for the right population is reasonable.
Why this matters even if your hearing is fine today
This consultation is not only for people who currently have hearing loss.
Many Canadians hear well today but may experience hearing decline in the future. Hearing loss often arrives gradually. People may notice it first in noisy restaurants, on the phone, in family gatherings, or when conversation becomes more tiring than it used to be. By then, policy barriers may already be standing between them and early support.
Seniors’ advocacy has always worked this way. People who experience the problem first push for reforms that benefit many others later. That is how policy change becomes generational. CARP members have fought for retirement security, income support, drug benefits, accessibility, and protection against age discrimination. Those changes did not help only the people who advocated for them. They helped the people who came after.
Hearing health is another opportunity to do that.
You may hear perfectly well today. But good policy is not built only for today. It is built for the person you may become, the family members you may support, and the next generation that should not have to fight the same fight again.
CARP’s national recommendations
CARP calls on every province and territory to:
- Create a clear legal exception allowing adults 18 and older to access Health Canada-licensed OTC hearing-aid technologies without a prescription when those technologies are intended for perceived mild-to-moderate hearing loss.
- Maintain existing prescription and professional-care pathways for children, severe hearing loss, complex cases, medical red flags, and people who need diagnostic testing or professionally fitted hearing aids.
- Protect provincial funding programs, including Ontario’s ADP, so OTC access does not become an excuse to weaken public support for prescribed hearing aids.
- Require clear consumer information before purchase and during setup: who the device is for, who it is not for, when to seek professional care, what the device can and cannot do, and how to return or escalate care if it does not help.
- Require red-flag warnings for sudden hearing changes, one-sided hearing loss, ear pain, drainage, dizziness, significant wax or blockage concerns, tinnitus concerns, and other symptoms requiring professional assessment.
- Permit audiologists and other regulated hearing professionals to advise on, recommend, support, or provide OTC hearing-aid technologies when appropriate, without turning OTC access into a mandatory prescription process.
- Work with Health Canada and other provinces to create consistent definitions of “hearing aid,” “prescription hearing aid,” and “over-the-counter hearing aid.”
- Ensure national implementation is practical for mobile and app-enabled technologies that cannot realistically be released province by province without consumer confusion.
Member call to action
CARP members across Canada should support responsible OTC hearing-aid access.
If you already live with hearing loss, this may help you or someone you know.
If your hearing is good today, your voice still matters. You are helping build a better system for the future.
Ontario’s consultation is a first step. Alberta appears to be further ahead. Nova Scotia and other provinces need clarity. Canada needs a coordinated provincial response so that federally licensed, regulated hearing-health technology can be made available to Canadians who can benefit.
CARP is calling our members to submit their comments to Ontario’s proposal. The regulatory registry posting can be accessed here with the last day to comment being May 28, 2026
That is the power of advocacy: people who see the problem first help build the solution for everyone.
Sources
1 https://www150.statcan.gc.ca/n1/daily-quotidien/190821/dq190821c-eng.htm
2 https://www.apple.com/ca/airpods-pro/feature-availability/
