Diabetes affects people in different ways. Diabetes has the potential to be disabling, but for many, it can be well managed with education and supports, diet, exercise, and often medication.
People with diabetes have the right to be assessed on an individual basis to determine their fitness for various activities, including employment, insurance, driving, aviation, and participation in school, sports, or other activities.
Position statement
A person with diabetes should be eligible for employment in any occupation for which they are individually qualified.
In being considered for employment or certification in safety-sensitive positions, including aviation, a person with diabetes has the right to be assessed for specific job duties on their own merits, based on reasonable, evidence-based standards applied consistently.
Employers, regulators, and certifying bodies have a duty to accommodate individuals with diabetes unless it can be demonstrated that accommodation would result in undue hardship or compromise public safety.
Aviation and Public Safety
The purpose of aviation medical certification programs is to ensure that aircrew are medically fit in order to reduce the risk of medically related human factors contributing to aircraft accidents.
Canada’s aviation medical standards are established under the Canadian Aviation Regulations (CARs) and aligned with standards developed by the International Civil Aviation Organization (ICAO) to support global aviation safety.
Transport Canada’s current approach recognizes that individuals with Insulin Treated Diabetes Mellitus (ITDM), including those living with type 1 diabetes, may be safely certified to fly when assessed using up-to-date medical criteria and supported by appropriate monitoring and risk mitigation measures. Current measures include:
- Eligibility for consideration for a Category 1 medical certificate;
- Restrictions for professional licences (ATPL, CPL) requiring operation with an accompanying pilot;
- Annual medical certification renewals for all ITDM pilots;
- Mandatory in-flight glucose monitoring protocols as a condition of flying while using insulin; and
- Ongoing modernization of clinical guidance for Civil Aviation Medical Examiners (CAMEs) and applicants.
This approach reflects the principle that individuals with diabetes should be assessed based on individualized medical evidence, functional ability, and appropriate safeguards, rather than excluded solely on the basis of diagnosis.
Definition: undue hardship
Undue hardship arises as part of the legislative requirement that employers and organizations must modify workplace policies, rules, practices, and operations that result in discrimination, and provide individual accommodation unless doing so would create unreasonable hardship.
What constitutes undue hardship varies by circumstance; however, courts have made it clear that employers must expect to incur some cost in eliminating barriers and providing accommodation. Under the Canadian Human Rights Act, undue hardship must be assessed in consideration of health, safety, and cost. The existence of some cost or inconvenience alone is insufficient to establish undue hardship.
Background and rationale
People with diabetes may face discrimination in employment and licensing decisions simply because they have diabetes. Most individuals with diabetes can perform their duties safely and effectively with minimal accommodation, such as nutrition breaks, time for glucose monitoring, access to supplies, or flexibility for medication administration.
Advances in diabetes management, including modern insulin therapies and continuous glucose monitoring technologies, have significantly improved the ability of people with diabetes to safely perform in safety-sensitive occupations, including transportation and aviation roles.
Employers and regulatory bodies have, at times, terminated, demoted, or denied opportunities to people with diabetes without adequate understanding of the condition or reasonable investigation into individual circumstances. Individualized assessment tools tailored to the specific role, developed collaboratively among the employer or regulator, the individual, and qualified health- care professionals, can help ensure decisions are fair, evidence-based, and consistent with both public safety and human rights obligations.
Updated May 2026