Introduction
Section 1: Institutional GBA Plus governance and capacity
Governance
The Canadian Human Rights Commission (the Commission) is pleased to have an executive Gender-based analysis plus (GBA Plus) Champion, who is responsible for the promotion of GBA Plus at the Commission, including disseminating relevant information to support GBA Plus awareness and implementation across the organization. The Commission also has a GBA Plus Focal Point, who is responsible for participating in the GBA Plus Focal Point meetings and sharing relevant updates, resources, and events.
Capacity
The Commission is particularly sensitive to GBA Plus issues in general, enabling it to integrate this knowledge into its day-to-day operations and apply an intersectional lens to all areas of its work.
The nature of the Commission's work as Canada's National Human Rights Institution puts it in a unique position. As the grounds of discrimination enumerated in the Canadian Human Rights Act include sex 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 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 Champion is responsible for the application and monitoring of this approach. It also has an internal Inclusion, Diversity, Equal Access, and Anti-Racism Unit, 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, and gender identity and expression.
Human resources (full-time equivalents) dedicated to GBA Plus
The Commission does 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), and Accessible Canada Act (ACA) require us to consider how systemic barriers impact individuals based on intersecting identities. This is further reinforced by the efforts of our GBA Plus Champion and Focal Point.
Section 2: Gender and diversity impacts, by program
Core responsibility: Engagement & 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
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.
In 2024–2025, the Commission, together with the Office Federal Housing Advocate, launched a framework for monitoring the right to adequate housing for people with disabilities. This was developed with the input of people with disabilities, their families, and caregivers, as well as people who have experienced inadequate housing and homelessness. This project uses publicly available data, including figures from Statistics Canada, to monitor human rights-based housing outcomes for people with disabilities. It tracks the housing experiences of people with disabilities in eleven key areas, such as homelessness, institutionalization, affordability, and accessibility. Information through this work will be disaggregated as much as possible, including by province or territory, disability type, age, race and gender. The findings illustrate that people with disabilities are overrepresented in all aspects of inadequate housing and homelessness.
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
The work of the Federal Housing Advocate (FHA) benefits the Canadian population overall. However, the FHA puts particular focus on those with the greatest housing need, these groups include people experiencing homelessness; Indigenous peoples; women, adults and children leaving situations of violence; seniors; people who identify as 2SLGBTQI+ people with disabilities; people with mental health or addiction issues; veterans; youth; racialized groups; newcomers to Canada; post-incarcerated individuals and other groups.
In 2024–2025, the FHA integrated GBA Plus into all aspects of data collection and reporting to ensure systemic housing issues were assessed through an intersectional lens. The FHA advanced distinctions-based data collection through the Métis Housing Conditions Report and, in partnership with the Commission, launched a Monitoring Framework for people with disabilities using outcome indicators and Statistics Canada data. Submissions received through the online tool were analyzed to capture systemic barriers affecting Indigenous peoples, women, gender-diverse people, racialized communities, veterans, and others, informing review panel referrals on issues such as gender and accessibility. Public-facing knowledge products, including jurisprudence briefs and fact sheets on encampments, emphasized governments' legal obligations while ensuring rights information was accessible to diverse communities. Finally, national and international engagements and sustained media outreach amplified marginalized voices, highlighted the barriers faced by intersecting groups, and reinforced that housing is a human right.
The FHA receives submissions from the public on systemic housing issues and unmet housing needs across Canada through a submission tool. This tool helps inform how identity factors such as socioeconomic status, age, ethnicity, disability, and geography, intersect with gender to contribute to housing outcomes. As women face numerous barriers to accessing safe, affordable housing, they are more vulnerable and experience higher rates of core housing need than the overall population and their male counterparts.
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
Supplementary information sources
Over the past year, the Commission applied the Complaint Accountability Framework (CAF) to its human rights work.
The CAF is designed to ensure that the necessary checks and balances are in place when looking at each human rights complaint. The idea is that highly trained employees — with a variety of lived experience — will review and assess these complaints collectively to determine the path that a human rights complaint will take within the system.
More specifically, the CAF and training delivered to staff recognize that many of the race-based discrimination complaints filed by people in Canada involve subtle acts of exclusion, also known as micro-aggressions. This form of discrimination can include implicit bias and other racist underpinnings that are often difficult to prove.
The CAF also allows the Commission to triage and prioritize cases where the alleged discrimination is ongoing and/or severe. Though all cases are dealt with as efficiently as possible, the details of a human rights complaint may result in faster processing times or more dedicated resources. Examples of human rights complaints that are prioritized include complainants who are in prison and allege multiple forms of discrimination based on several human rights grounds; Black and Indigenous public servants experiencing racial harassment in their workplaces; trans rights holders who are not afforded the same rights as cis-gendered people in Canada; and, group complaints involving many complainants experiencing similar, and hence systemic, forms of discrimination.
The CAF ensures that an intersectional lens is applied to the triaging and prioritization of human rights complaints, recognizing that multiple forms of discrimination are often happening concurrently, leading to layers of oppression for complainants.
GBA Plus data collection plan
As part of the integrated data collection strategy, the Commission continued collecting demographic data from people who made complaints under the Canadian Human Rights Act. Online Complainant Surveys were collected from participants who submitted their human rights complaint using the online complaint form and by email. Paper based surveys were also collected.
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. Work is underway to review the results, which will inform the Commission's broader data strategy, including investigating ways to link this complaint data to larger data sources, such as those of Statistics Canada, with the goal of enabling more in-depth demographic analysis.
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.
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 Employment Equity Act (EEA), the Pay Equity Act (PEA), and the Accessible Canada Act (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
Other key program impacts
The Proactive Compliance Branch supports the Pay Equity Commissioner and the Accessibility Commissioner in carrying out their mandates. This Branch also includes the Employment Equity Division.
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 implementation of 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 is working directly 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.
In addition, the Pay Equity Commissioner continues to actively cultivate relationships and participate as a speaker in international events, aiming to learn and share best practices.
Gender-based analysis is inherent in pay equity. Now that the deadline for the first Pay Equity Plans has passed, more data will become available to gain further insight about the gender wage gap.
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.
GBA Plus data collection plan
Pay Equity
Employers must submit an annual statement to the Pay Equity Commissioner that provides details about their Pay Equity Plans. In particular, they must provide information about any female predominant job class found in their workplace that was owed compensation because of the pay equity process. Information includes the number of women that are owed compensation, the amount of that increase, and how they are being paid that increase. The annual statement portal will collect that data in accordance with the legislative requirements.
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.
Within its compliance monitoring and promotion activities, the Commission is limited in the extent of GBA Plus data it can directly collect or analyze. The Accessibility Commissioner's role is primarily to ensure that regulated entities comply with the ACA and its regulations, including the principle of intersectionality, which remains difficult to measure in practice. Despite these limitations, steps are taken to strengthen the approach, including exploring ways to embed intersectionality into compliance monitoring and guidance. These efforts aim to ensure that accessibility plans and progress reports better reflect diverse lived realities and promote equity across groups.