Direct Answer
Yes, if your employees are performing CDAP services on behalf of a client, you must cover them with workers' compensation insurance, just as you would for any other in‑house employee. The CDAP program does not exempt employers from standard insurance obligations.
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Why Workers' Compensation Is Required
CDAP (Canada Digital Adoption Program) funds services that improve a business's digital capabilities. The employees executing these services are still your staff, so Canadian labour laws apply. Workers' compensation protects employees against injury or illness related to their job duties, regardless of the client or project.
Determining Coverage Scope
Identify which staff are involved in CDAP projects. If they are hired directly by you and perform tasks under your direction, they are covered. Employees contracted through a third‑party vendor are typically covered by that vendor's insurance, unless a subcontractor agreement specifies otherwise.
Key Compliance Steps
- Verify employee status and job roles.
- Purchase or confirm existing workers' compensation coverage for those roles.
- Maintain proof of insurance and keep records for audits.
- Review any changes in project scope that might alter coverage requirements.
Common Misconceptions
Some firms think that because the work is funded by CDAP, it is exempt from insurance. That is incorrect; the funding source does not affect the legal requirement to insure employees. Ignoring this can lead to penalties, denied claims, and potential legal liability.