Section 1: institutional GBA Plus governance and capacity
Governance
The Canadian Human Rights Commission (the Commission) is pleased to have two executive level Gender-based analysis plus (GBA Plus) Co-champions, who are responsible for raisingawareness about GBA Plus and its importance in the work and organizational life of the Commission by acting as enablers, connectors, and advocates in support of organizational accountabilities.
The Commission also has a GBA Plus Focal Point, who is responsible for participating in the GBA Plus Focal Points Meetings and sharing relevant updates, resources, and events.
Capacity
The Commission is particularly sensitive to GBA Plus issues in general, enabling us to integrate this knowledge into our day-to-day operations and apply an intersectional lens to all areas of our work.
The nature of the Commission's work as Canada's national human rights institution puts us in a unique position. As the grounds of discrimination enumerated in the Canadian Human Rights Act (CHRA) include sex, sexual orientation, and gender identity or expression, as well as race, religion, age, disability and others, many employees have robust expertise in gender-based and intersectional analysis and assessment.
Additionally, the Pay Equity Commissioner (PEC) is entirely focused on addressing systemic gender-based discrimination in the compensation practices and systems of federally regulated employers.
The Commission is committed to ensuring that the differential impacts on diverse groups of people are considered when policies, programs and initiatives are developed. The Commission's GBA Plus Co-champions are responsible for the application and monitoring of this approach.
We have also established an Inclusion, Diversity, Equity, Accessibility and Anti-Racism (IDEA-AR) Unit within the Commission, successfully staffed with a director.
Lastly, in both the implementation of the Commission's Accessibility Plan and Anti-Racism Action Plan, an intersectional lens is applied, including race, sex, sexual orientation, and gender identity or expression.
Human resources (full-time equivalents) dedicated to GBA Plus
While the Commission has two GBA Plus Co-champions and Focal Point, we do not have a dedicated FTE for GBA Plus. Instead, this analytical lens is embedded across all our work because our mandates under the Canadian Human Rights Act (CHRA), Employment Equity Act (EEA), Pay Equity Act (PEA), Accessible Canada Act (ACA), and the National Housing Strategy Act (NHSA) require us to consider how systemic barriers impact individuals based on intersecting identities.
Section 2: Gender and diversity impacts, by program
Core responsibility: Engagement and Advocacy
Program name: Promotion program
Program goals:
The Promotion Program contributes to a more inclusive Canada by raising awareness about Canadian human rights and responsibilities through its public advocacy and engagement efforts. The program engages civil society, governments, employers and other stakeholders to work together in identifying approaches to eliminate barriers to social inclusion that people in vulnerable circumstances face in today's society. The program advances human rights by developing statements, positions, approaches and tools to influence public debate on emerging, immediate and long-term human rights issues and represents the public interest in courts and tribunals to support the advancement of human rights, pay equity and accessibility. The program uses GBA Plus in all its activities as the Commission is committed to ensuring that the differential impacts on diverse groups of people are considered when policies, programs and initiatives are developed.
Target population:
All Canadians
Key program impacts on gender and diversity
GBA Plus data collection plan
This program collects sufficient data to enable it to monitor or report program impacts by gender and diversity.
The Office of the Federal Housing Advocate (OFHA) integrates GBA Plus to ensure inclusive outcomes by prioritizing those disproportionately affected by inadequate housing, such as women, Indigenous peoples, 2SLGBTQI+ individuals, and people with disabilities. This approach aims to achieve systemic reforms in housing laws, policies, and programs to address inequities and improve access to adequate housing.
In 2025, the NehaFootnote 1 review panel examined the right to safe, adequate, affordable housing for women, Two-Spirit, trans, and gender-diverse people. It also examined the government's duty to uphold these rights. The Federal Housing Advocate's (FHA) written representation [PDF] to the review panel was submitted in February 2025, and the Advocate participated in Neha's oral hearings in June 2025. The Neha reports and recommendations concluded that Canada is not fulfilling all the conditions to realize the right to housing in Canada in an inclusive, gender-responsive, and human rights-based manner.
In October 2025, the Commission,together with the OFHA, released a report entitled “Monitoring the right to adequate housing for people with disabilities: Summary of outcome indicator results” [PDF]. This report used an intersectional approach and disaggregated data to the greatest extent possible to identify whether certain groups of people with disabilities face additional barriers. This report also provided recommendations to help advance the right to adequate housing for people with disabilities in Canada, including recommendations to address data gaps. The data collected confirmed that people with disabilities face numerous barriers in exercising their right to adequate housing, resulting in disparate housing outcomes.
Other key program impacts
The Commission applies an intersectional approach in all its work including legal and policy advice and development, ensuring that the differential impacts on diverse groups of people are considered.
As a centre of human rights knowledge and policy development, the Commission regularly provides expertise on federal laws, initiatives, and policies. This expertise is informed by consultations with stakeholders, people with lived experiences, complaints and case law, and thorough research and analysis.
Furthermore, under the PEA, information is collected from employers on compensation adjustments made to female‑predominant job classes as part of pay equity plan implementation. This data enables the PEC to assess the PEA's impact on the gender wage gap by examining the number of employees affected, the value and distribution of compensation increases, how these increases are implemented, and how outcomes evolve over time. While the PEA's reporting requirements focus on comparisons between male and female‑predominant job classes, this information supports ongoing monitoring of systemic gender‑based wage disparities and the effectiveness of pay equity measures in promoting more equitable compensation practices.
Core responsibility: Complaints
Program name: Protection program
Program goals:
The Protection Program contributes to a diverse society that promotes social inclusion by providing people in Canada with a human rights complaint resolution system, so that people in vulnerable circumstances can bring forward the human rights issues or challenges they face.
Target population:
All Canadians
Key program impacts on gender and diversity
The Commission applies an intersectional approach in all its work including legal and policy advice and development, ensuring that the differential impacts on diverse groups of people are considered.
As a centre of human rights knowledge and policy development, the Commission regularly provides expertise on federal laws, initiatives, and policies. This expertise is informed by consultations with stakeholders, people with lived experiences, complaints and case law, and thorough research and analysis.
GBA Plus data collection plan
This program collects sufficient data to enable it to monitor or report program impacts by gender and diversity.
Human Rights
Collecting disaggregated data from rights holders who file human rights complaints is a key means of identifying barriers and enhancing the human rights complaints process.
As part of the integrated data collection strategy, the Commission continued collecting demographic data from people who made complaints under the CHRA. Integrating a demographic data survey into the Commission's online human rights complaint form helped the Commission learn more about who is using its complaint process and how it can better serve them. The Commission keeps the data from these surveys separate from the human rights complaint files. Data from the survey allows the Commission to know who is using its human rights complaints process, identify trends, and identify emerging and systemic issues that merit a coordinated organizational response. This data is used to assess any gaps using a GBA Plus lens.
Pay Equity
To support ongoing improvements in data collection, analysis, and compliance oversight, upgrades to the existing information management technology will enhance the ability to track activities, identify trends, and support timely enforcement actions as the number of regulated entities coming into compliance continues to grow. These enhancements will strengthen the quality and availability of compliance data, helping to address current information gaps while improving reporting and decision-making.
Accessibility
Although the Accessibility Commissioner (AC) has received relatively few complaints under the ACA to date, the current complaints process does not include a digital solution that supports the systematic collection and analysis of demographic information. As a result, the AC's ability to analyze, and report on GBA Plus data is currently limited.
As the accessibility complaints program continues to mature, work is underway to identify future system and information management requirements that will enable the secure and appropriate collection, analysis, and reporting of demographic data while protecting complainant privacy. This work will inform the development of future digital solutions and case management capabilities.
The implementation of the Information and Communication Technologies (ICT) Accessibility Regulations, beginning in December 2027, is expected to increase regulatory activity and may contribute to higher accessibility complaint volumes. Modern digital infrastructure and data capabilities will be increasingly important to support effective complaint handling, operational planning, trend and intersectional analysis, and GBA Plus reporting as the program evolves.
Core responsibility: Proactive Compliance
Program name: Audit program
Program goals:
The Audit Program contributes to the establishment of a diverse society that promotes social inclusion and a fair labour market by ensuring that federally regulated workplaces are free of barriers for women, Indigenous Peoples, people with disabilities and racialized people. In conducting audits of federally regulated organizations for compliance with the requirements of the EEA, the PEA, and the ACA, the program helps them achieve reasonable progress toward the creation of environments that foster equality of opportunity and respect for human rights.
Target population:
All Canadians
Key program impacts on gender and diversity
GBA Plus data collection plan
Employment Equity
Under the Employment Equity Act (EEA), the Commission is responsible for enforcing federally regulated employers' compliance with the legislative requirements set out in the EEA. Through its employment equity compliance audit program, the Commission assesses whether federally regulated employers are meeting their obligations under the EEA, including identifying and eliminating employment barriers and implementing measures to achieve equitable representation of the four designated groups: women, Indigenous people, people with disabilities, and racialized people. These audits enable the Commission to evaluate employer progress and identify areas where additional efforts may be required to achieve the objectives of the EEA.
The data collected through employment equity compliance audits provides evidence to assess how employers are implementing the EEA and advancing equitable representation in federally regulated workplaces. By examining representation trends, employer policies and practices, the Commission can identify systemic barriers and support compliance and enforcement activities. While the current reporting framework focuses on the four designated groups established under the EEA, findings from compliance audits may also inform broader GBA Plus considerations by highlighting employment barriers that can intersect across multiple identity factors, contributing to evidence-based efforts to advance workplace equity and inclusion.
Pay Equity
Employers must submit an annual statement to the Pay Equity Commissioner with details of their pay equity plans. This includes information on any female-predominant job classes in the workplace that were entitled to compensation through the pay equity process, including the number of women affected, the amount of the increase, and how the increase is being paid. The annual statement portal collects this data in accordance with legislative requirements.
Under the PEA, information is collected from employers on compensation adjustments made to female-predominant job classes as part of pay equity plan implementation. This data enables the PEC to assess the PEA's impact on the gender wage gap by examining the number of employees affected, the value and distribution of compensation increases, how these increases are implemented, and how outcomes evolve over time. While the PEA's reporting requirements focus on comparisons between male- and female-predominant job classes, the information collected provides a strong foundation for ongoing monitoring of systemic gender-based wage disparities and supports continued analysis of the effectiveness of pay equity measures in advancing equitable compensation practices.
Accessibility
The ACA identifies intersectionality as a guiding principle; however, it does not prescribe mechanisms for collecting or reporting GBA Plus data. Responsibility rests with regulated entities to integrate intersectionality into their accessibility planning, feedback processes, and progress reporting. A key gap is that many regulated entities lack the tools, data, and expertise to apply an intersectional approach, which can result in limited consultation and Accessibility Plans that fail to capture the full range of barriers.
At this stage, there is limited evidence to demonstrate differential impacts on specific sociodemographic groups, as the AC has received relatively few accessibility complaints and the regulatory program is still maturing. Despite these limitations, ongoing compliance promotion, stakeholder engagement, and operational guidance continue to support the ACA's guiding principle of intersectionality while laying the foundation for enhanced GBA Plus analysis as additional data become available.
Other key program impacts
Employment Equity
The implementation of the EEA is essential for promoting fair representation and inclusion within federally regulated workplaces. Through a GBA Plus lens, the EEA addresses systemic barriers faced by women, Indigenous Peoples, people with disabilities, and members of visible minorities, recognizing that individuals experience discrimination differently based on gender, race, age, culture, sexual orientation, and other intersecting factors. Effective implementation of the EEA helps reduce inequities, fosters diverse and inclusive work environments, and enhances economic participation for underrepresented groups. This supports Canada's broader commitments to equity, human rights, and workforce diversity.
Pay Equity
The PEA has a direct impact on the economic participation and prosperity of diverse groups of women by reducing the portion of the gender wage gap that is due to the historic undervaluing of “women's work” in federally regulated workplaces. To amplify this impact, the Commission continues to work with workplace parties on tools, resources and training to ensure enforcement and compliance with the PEA.
By utilizing educational materials, awareness, outreach and engagement activities, the goal is to promote equal pay for work of equal value while also highlighting the detrimental effects of occupational segregation and gender stereotypes in the workplace. These efforts seek to promote education and skill development by creating diverse educational opportunities and expanding career choices. Through these efforts, the Commission aims to shift public perceptions and social dialogue surrounding traditional gender-based roles and promote gender equality in leadership roles. By challenging the notion of “women's work” and “men's work,” the Commission strives to make women's contributions more visible and duly recognized.
Accessibility
The implementation of the ACA and its Regulations is critical to ensuring equitable access and removing systemic barriers for people with disabilities across federally regulated sectors. Using a GBA Plus lens, accessibility challenges are understood to affect individuals differently based on gender, age, race, culture, language, income, and other intersecting factors. Women, Indigenous Peoples, racialized groups, and 2SLGBTQI+ individuals with disabilities often face compounded barriers to employment, services, and participation.
Effective implementation of the ACA promotes inclusion, economic participation, and social well-being for diverse groups, supporting Canada's commitment to human rights, equity, and accessibility for all. People with disabilities are not a homogeneous group, and compliance monitoring and promotion planning must reflect diverse needs shaped by intersecting identities such as gender, race, indigeneity, age, and socioeconomic status. Lived experience shows that a “one-size-fits-all” approach often masks the voices of those most marginalized within the disability community.