Canadian Human Rights Commission's 2024 Report to Parliament

Chief Commissioner's message

I am pleased to deliver the Canadian Human Rights Commission's 2024 Annual Report to Parliament.

As I write this message, at the close of 2024, Canada is navigating a period of uncertainty. Economic tensions are rising, and hateful rhetoric and symbols are being minimized in the mainstream, leading many to fear rollbacks of hard-won human rights victories. Protecting and promoting human rights in Canada is essential. As Canada's national human rights institution, we recognize the profound importance of this responsibility, particularly in these challenging times.

This Annual Report details the work undertaken to advocate for human rights, and provide fair, equitable enforcement and dispute resolution processes that respect the inherent dignity of all. It focuses mainly on the Commission's work under the Canadian Human Rights Act and Employment Equity Act. The Accessibility Commissioner, Pay Equity Commissioner, and Housing Advocate will each present separate Annual Reports under their respective mandates.

Throughout 2024, we spoke out against the troubling rise in hate crimes, antisemitism, and Islamophobia. We advocated for the human rights of Two-Spirit, trans, non-binary, and gender-diverse youth. We called for stronger equity and inclusion measures, including an employment equity regime that effectively addresses persistent, systemic inequities and a robust Canada Disability Benefit that ensures an adequate standard of living and dignity for people with disabilities. We also advocated for stronger protections for people deprived of liberty in various settings, including prisons and institutional care facilities. And, through various submissions to the United Nations, we highlighted intersecting human rights issues for racialized people in Canada, people of African descent, Indigenous peoples, people with disabilities, and women, among others.

We continued to support the Federal Housing Advocate in her work to advance housing rights for people in Canada in the most vulnerable circumstances. Together with her office, in our role as Canada's National Monitoring Mechanism of the Convention on the Rights of Persons with Disabilities, we released a new framework that pulls together national data on the state of housing rights for people with disabilities, confirming that it is now one of Canada's most pressing human rights issues.

We also continued modernizing our approach to assessing, litigating, and helping to resolve complaints under the Canadian Human Rights Act. This includes engaging with stakeholders, bolstering our trauma-informed mediation services, reviewing our accommodation practices, and focusing our strategic litigation on cases that can help strengthen anti-racism jurisprudence in Canadian law.

This year, race-based complaints represented the largest proportion of accepted complaints for the first time in the Commission's history. Our ongoing work to transform how we handle these complaints has resulted in a higher referral rate to the Canadian Human Rights Tribunal and a lower dismissal rate for race-based complaints compared to all others. Disability, historically the most cited ground of discrimination, was cited almost as frequently as the grounds of race, colour and national or ethnic origin — with nearly half of the disability cases relating to mental health.

In 2024, we worked with federally regulated organizations in Canada to promote compliance with the Canadian Human Rights Act, the Employment Equity Act, the Pay Equity Act, and the Accessible Canada Act. This included publishing new human rights guidance for federally regulated employers on workplace accommodations and addressing and preventing workplace harassment and violence.

Also this year, the Global Alliance of National Human Rights Institutions (GANHRI) reviewed us against the international standards for independence and effectiveness and affirmed our A-status, which empowers us to advocate for human rights in Canada on the global stage.

What has been clear to us in all this work over the past year is that now more than ever, the values of equality, dignity, and respect for all must remain at the forefront of our collective consciousness, guiding us through these uncertain times. We will continue to embed inclusion, diversity, equity, accessibility, and anti-racism within the Commission and across all our work that touches the Canadian public and workforce.

I am inspired daily by the passion, expertise, and resilience of the people at the Canadian Human Rights Commission who work tirelessly toward a fairer, more inclusive Canada. As you read through this Annual Report, I hope you feel the impact of our work and share in our vision for a Canada where everyone is valued and respected and can live free from discrimination.

Sincerely,

Charlotte-Anne Malischewski

Interim Chief Commissioner

Canadian Human Rights Commission

About the Commission

Our vision

An inclusive society where everyone is valued, respected and has access to equal opportunities, free from discrimination.

Our mission

We protect and promote human rights in Canada.

Our mandate

We advocate for human rights, and provide enforcement and dispute resolution processes that are fair, equitable, and respect the inherent dignity of all.

We operate under the authority of the Canadian Human Rights Act, the Accessible Canada Act, the Employment Equity Act, the Pay Equity Act and the National Housing Strategy Act. We are internationally accredited as Canada's national human rights institution.

Who we are and what we do

The Canadian Human Rights Commission is Canada's national human rights institution, comprising approximately 337 diverse employees in 2024.

Together, we provide fair mechanisms for human rights resolution, enforcement and advocacy inside a single expert organization.

We provide free, confidential, and accessible pathways for people in Canada to understand their rights, resolve disputes, and seek redress, often without the need to proceed to complex, lengthy and costly public hearings.

We advance human rights in Canada by representing the public interest, identifying emerging issues and advocating for change that keeps pace with society so that Canada is inclusive, equitable and barrier-free.

And as Canada's national human rights institution, we hold Canada accountable to its domestic and international human rights commitments.

Advocating for human rights in Canada

We are Canada's national human rights institution. We speak out, raise awareness, and advocate for human rights in Canada by:

advising Parliament on new laws and emerging human rights issues
supporting and conducting human rights research
engaging with international bodies to raise concerns when Canada is not meeting its human rights obligations
monitoring Canada's implementation of the United Nations Convention on the Rights of Persons with Disabilities
publicizing key human rights settlements that have the potential to affect broader change across Canada
working with the Federal Housing Advocate to drive meaningful action and human-rights-based solutions to housing need and homelessness in Canada

Preventing discrimination

Through mediation and litigation, we resolve discrimination disputes, often reaching remedies that prompt changes to policies and programs that impact the lives of many people in Canada.

Informed by research, stakeholders and those with lived experience, we inform policy changes across Canadian institutions that will help prevent discrimination.

And we make sure that federally regulated employers:

work towards a barrier-free Canada by removing barriers for people with disabilities through the Accessible Canada Act (Office of the Accessibility Commissioner)
work towards a Canada where the right to equal pay for work of equal value is a reality for all through the Pay Equity Act (Office of the Pay Equity Commissioner)
take steps to increase representation across Canada's workplaces for women, Indigenous peoples, racialized people and people with disabilities through the Employment Equity Act

Resolving human rights complaints

In accordance with the Canadian Human Rights Act, we receive and assess complaints from people who believe they have experienced discrimination or harassment.

We help people resolve disputes through mediation
We refer complaints to the Canadian Human Rights Tribunal when the issues are systemic in nature
We represent the public interest in certain cases that go before the Tribunal and the courts

In accordance with the Accessible Canada Act and the Pay Equity Act, we support the Accessibility Commissioner and the Pay Equity Commissioner in resolving disputes that come before them.

We assess, litigate, resolve complaints

The Commission assesses, litigates, and helps resolve complaints under the Canadian Human Rights Act from people who believe they have been discriminated against by the federal government or a federally regulated organization.

A key part of this role is to help people determine if they have the basis for a human rights complaint under the Canadian Human Rights Act, or if they need to go through another process like a union grievance or a provincial or territorial human rights commission or tribunal.

In 2024, we helped thousands of people who came to us because they believed they had been discriminated against. For most of them, we were able to help without them having to file a formal discrimination complaint.

For others whose inquiry met the requirements for a complaint under the Canadian Human Rights Act, we supported them in navigating our process — recognizing that the majority of people who use our system to file a human rights complaint do not have legal representation.

We then helped people resolve their human rights disputes by bringing the parties together in mediation, or by referring complaints to the Canadian Human Rights Tribunal, which is entirely separate and independent from the Commission. The main difference between the Commission and the Tribunal is that we are the screening body, whereas the Tribunal is similar to a court. It reviews evidence, conducts hearings, and only the Tribunal can decide if discrimination has taken place.

When a human rights case goes before the Canadian Human Rights Tribunal or Canada's courts, the Commission often participates and represents the public interest. Our litigators are there to advocate for people in Canada and be the voices of those whose human rights might be impacted by the outcome of the case.

Improving complaints data, policies and process

Over the course of 2024, the Commission continued to improve and modernize its complaints process—from the way we collect data, to clearer policies for complainants and respondents, to ongoing training for our complaints staff.

Stakeholder engagement

We have improved the lines of communication between our advocacy and respondent communities of stakeholders to keep our audiences informed more regularly and efficiently, and to get direct input from them about how we can continue to improve our complaints process.

We have produced a video, "Mediation: A smart path to human rights justice," to help demystify the process for people in Canada. For many of the people who file complaints with the Commission, this is their first time interacting with a process like ours, or any legal process in general. Most of them are doing this without legal representation. Our new video is part of an ongoing initiative to keep providing useful guidance to people who are new to this entire process.

A more accessible complaints process

This past year, the Commission addressed various types of accommodation requests from rights holders at different stages of our complaint process.

We transcribed complaints that were delivered orally to us by the complainants.
We coordinated translation and interpretation services when complainants have requested services not in English or French, including requests for ASL and LSQ interpretation.
In line with our trauma-informed approach, we accommodated the diverse needs of rights holders with respect to the type, time, and duration of our communications and services. This is allowing rights holders to have their needs considered during the complaints process.
We continue to check in with parties about their accommodation needs at every step of the process, including during mediation or conciliation. For example, while virtual mediation is now our standard practice, we hold in-person mediations and conciliations as an accommodation. The Commission has also enlisted ASL and LSQ interpretation services as well as translation services when needed during mediations and conciliations.
We are broadening our Complaints Services Accommodation Policy into an accommodation policy for anyone participating in any Commission processes under the Canadian Human Rights Act, the Accessible Canada Act or the Pay Equity Act. This updated policy will be made available in 2025.

Transforming how we handle race-based complaints

The Commission is dedicated to improving the way we handle race-based complaints under the Canadian Human Rights Act. It is all making a meaningful difference. From the changes to our complaints process, to improving the way we use evidence to assess the cases we refer to the Canadian Human Rights Tribunal, to deepening employee understanding of how systemic racism manifests in society.

Over the past year, we have continued to apply our Complaints Accountability Framework. Developed in 2021, the Framework is designed to ensure that the necessary checks and balances are in place when looking at a race-based complaints. The idea is that highly trained employees — many with lived experience — will review and assess race-based complaints collectively, to determine the path that a complaint will take within the complaints system.

This work is in response to the recognition 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.

Our learning and training matrix is now in place. It ensures employees receive training about unconscious bias, inclusion, anti-Black racism, Islamophobia, anti-oppression, and how to take a trauma-informed approach.

And finally, our disaggregated data initiative has been expanded to include the development of a new case management system. The new system is being designed to collect disaggregated data from the outset, allowing us to better understand who is using the Commission's complaint process.

The results of this ongoing work continue to be encouraging. In 2024, we continued to see a consistent trend in the outcomes of the race-based complaints that come through our system.

The number of race-based complaints we refer to the Canadian Human Rights Tribunal continues to be higher than our rate of referrals in other complaints. And the number of race-based complaints we dismiss continues to be lower than our rate of dismissals of other complaints.

2024 decisions in complaints (243 total) - the text version follows — **2024 decisions in complaints citing race, colour, and/or national or ethnic origin (243 total)**

2024 decisions in all complaints (644 total) - the text version follows — **2024 decisions in all complaints (644 total)**

2024 cases referred to the Tribunal - the text version follows — **2024 cases referred to the Tribunal (95 total)**

2024 complaints and decisions

Complaints and decisions in 2024 - the text version follows — Complaints and decisions in 2024

Trends in new complaints

In 2024, the Commission accepted 540 new complaints under the Canadian Human Rights Act.

Which grounds were cited in 2024, compared to the past five years?

Proportion of accepted complaints by grounds - the text version follows — **Proportion of accepted complaints by grounds of discrimination cited**

Complaints by grounds	Accepted in 2024	Accepted from 2020 to 2024
Race-Colour-National/Ethic Origin^{note *}	46%	36%
Disability	45%	51%
Sex	26%	21%
Religion	18%	13%
Family status	16%	12%
Age	10%	11%
Sexual orientation	6%	4%
Gender identity	6%	3%
Marital status	2%	3%
Pardoned conviction	0%	0%
Genetic characteristics	0%	0%

Where are the 2024 complaints from - the text version follows — **Where are the 2024 complaints from?**

Incident Province	Percentage in 2024
1. Ontario	34%
2. Quebec	18%
3. British Columbia	16%
4. Alberta	15%
5. Manitoba	4%
6. Saskatchewan	3%
7. Nova Scotia	3%
8. New Brunswick	2%
9. Yukon Territory	0%
10. Newfoundland and Labrador	2%
11. Northwest Territories	0%
12. Nunavut	0%
13. Prince Edward Island	0%
14. Unspecified	2%

Who were the 2024 complaints about?

Federal Government: 53%
Transportation: 18%
Finance / banking: 11%
Communications: 4%
Reserves / band councils: 5%
Unions: 3%
Other / unknown: 6%

Complaints related to mental health

44% of disability complaints accepted by the Commission were related to mental health.
This represents 19% of complaints accepted by the Commission in 2024.

Complaints citing more than one ground

21% of complaints accepted in 2024 cited more than one ground of discrimination.

Complaints related to harassment

18% of complaints accepted in 2024 cited harassment.

What is an "accepted" complaint?

A complaint is considered accepted for processing if it meets the requirements of the Canadian Human Rights Act. The Commission can only accept a complaint that is linked to one or more grounds of discrimination listed in the Act, is within the federal jurisdiction, and is submitted in an acceptable format.

What does it mean to "dismiss" a complaint?

When a complaint is dismissed, it is a decision made by one of the independent Commissioners to close a complaint. First, a human rights officer assesses the complaint and prepares a recommendation in the form of a "Report for Decision." The parties have the opportunity to comment on that Report. Then a Commissioner — in their role as an independent decision-maker — decides that the file does not warrant referral to conciliation, nor further assessment, nor referral to the Tribunal. The complaint file is therefore closed.

The reality of our role as a screening body is that our dismissal rate will never be zero. Dismissing cases is a necessary part of our role as a screening body and part of our role in supporting access to justice. We have a legislated obligation to assess each complaint and close those cases that will not succeed at the Tribunal because they do not meet the requirements of the law.

What does it mean to render a decision at the preliminary issues stage?

The Commission makes decisions on preliminary issues after accepting a complaint. Preliminary issues are questions that the Commission may need to resolve under section 40 and/or section 41 of the Canadian Human Rights Act before moving an accepted complaint forward. Some examples include: whether the person filing the complaint is unionized and has access to a grievance process that can deal with the human rights issues; whether the complaint is timely and if not, whether the Commission should nonetheless exercise its limited discretion to deal with it.

Helping people resolve disputes through mediation

Each year, the Commission is able to help parties in discrimination complaints resolve their issues through mediation (where participation is voluntary) or conciliation (where participation is required).

Our mediation process is not a hearing. In fact, the parties are free to share their side of the story without being cross-examined. Our mediators can attest that oftentimes, once people feel they have truly been heard, they can move toward resolution.

The Commission's mediation services are confidential and flexible. Our Commission mediators are well trained to take a trauma-informed approach. They bring a keen awareness that racism itself is a form of trauma. They do their best to create a safe environment where everyone feels heard, and that they have as much time as they need to tell their side of the story.

The majority of mediated settlements must remain confidential. In many cases it is because they have deep and personal effects on people's lives. The settlements themselves bring closure and change to those involved, and often they do not want to share their experiences publicly. Some of the cases we dealt with this year even resulted in life-saving measures.

Often, our mediation process serves as an opportunity to learn. By the end of the process, many Canadian organizations have re-evaluated their approaches or have come to see things in a new way.

For example, in a particular case we helped resolve in 2024, a complainant who is hard-of-hearing had filed a complaint with the Commission when she was not selected for a job due to the company's failure to provide proper accommodations. They did not allow her to wear her hearing aid for a technical part of the screening process. Through a successful mediation, the result was not only material change for the complainant, but it also led the employer to review its practices regarding assistive devices.

Learn more about the benefits of our mediation services in our 2024 video "Mediation: A smart path to human rights justice".

Mediated settlements in 2024

In 2024, the Commission's team of mediators, working with the parties, successfully resolved approximately 200 human rights disputes, whether through mediation or conciliation. We saw several common themes this year in the cases the Commission mediated. For example:

complaints involving the human rights of trans prisoners in Canada's federal prison system
complaints about federal funding in First Nations communities for essential services
complaints alleging a lack of adequate accommodation from the airline industry for both passengers with disabilities and employees with disabilities (Note: This type of complaint is normally under the purview of the Canadian Transportation Agency, but at the discretion of the Commission.)
complaints of systemic anti-Black racism in the banking sector, also known as "banking while black"

"Banking while black"

In the cases that came to us for mediation in 2024, the Commission continued to see cases of systemic anti-Black racism in the banking sector, a troubling trend that advocates are now referring to as "banking while Black." It can take many forms: inquiring about a bank loan suddenly turns into a lengthy line of questioning and demands for multiple forms of ID; looking for customer service turns into racial profiling by bank security. Whatever the form it comes in, this is a systemic issue in Canada that is impacting people's socioeconomic rights, and the basic right to dignity when receiving a service.

Litigating for people's rights in Canada

When a discrimination case goes before the Canadian Human Rights Tribunal or Canada's courts, the Commission often participates and represents the public interest. It means our team of litigators are there to advocate for the rights of all the people in Canada who, while not parties to that specific complaint, still stand to have their rights impacted by its outcome.

Cases go before the Tribunal when our independent and appointed Commissioners decide to refer them. They do so with careful consideration of all the evidence, and what potential the case may have for far-reaching, systemic impacts on the lives of many people in Canada.

The Tribunal is an entirely separate organization from the Commission and works similarly to a court — with full hearings, testimony and evidence, which are by default public. Only the Tribunal can decide whether discrimination has taken place. When the Commission objects to a ruling by the Tribunal, we can choose to participate in the judicial review process and litigate the case before Federal Court, and sometimes even the Federal Court of Appeal and the Supreme Court of Canada.

Throughout this entire process, the job of the Commission's litigators is to represent the rights of people in Canada and bring to light any systemic human rights issues that are at stake in the case. The Commission does this so that the individuals, many of whom have no legal representative, do not have to do this on their own.

In 2024, the Commission referred 95 cases to Tribunal.

Of the cases we referred to the Tribunal in 2024:

38% were related to discrimination in receiving a service
61% were related to discrimination in employment
28% involved allegations of harassment

Over the course of 2024, the Commission continued to use strategic litigation to advance anti-racism jurisprudence and legal precedents in race-based discrimination cases. Over the past year, race-based complaints represented an average of 58% of our Tribunal caseload. Of the complaints we referred to the Tribunal in 2024, we participated in 83% of the race-based cases. This includes making legal arguments and presenting evidence in many of the cases, as well as participating in mediation and case management.

What is strategic litigation?

Strategic litigation, also known as impact litigation, is the practice of pursuing specific cases to create social change. In recent years, the Commission has prioritized our role in race-based discrimination cases. We do so to push for systemic anti-racism change, and to strengthen jurisprudence for anti-racism cases in Canadian law, which will make it easier for people to access justice in cases of racial discrimination.

Representing the public interest

For the majority of the human rights cases we litigate, we are unable to comment publicly on the particulars of the case. That said, with permission from the parties, we are able to offer a look at some of the cases we participated in, and legal issues we argued in the public interest in 2024.

The rights of religious minorities in Canada

The Commission continues to participate in legal challenges against Quebec's Bill 21 (An Act Respecting the Laicity of the State), which prohibits government employees in positions of authority, including teachers, from wearing religious symbols or headdresses. The Quebec government invoked the notwithstanding clause to shield the law from any constitutional challenges.

In February 2024, the Quebec Court of Appeal upheld the constitutionality of Bill 21 and ruled that the law is consistent with Quebec's societal choices regarding secularism, despite its implications for religious freedoms. The ruling also overturned a lower court decision that had exempted English school boards from parts of the law.

We had argued before the Quebec Court of Appeal that Bill 21:

infringes on Muslim women's equality rights under Section 28 of the Canadian Charter of Rights and Freedoms
disproportionately restricts women who wear religious symbols from holding certain public positions
enforces gendered limitations that prevent women from accessing public office based on their religious attire
conflicts with Canada's international human rights obligations
imposes unjust barriers to religious expression and equality, and perpetuating systemic discrimination against religious communities

Several parties have sought leave to appeal this decision to the Supreme Court of Canada. In May 2024, the Commission filed its position with the Supreme Court, supporting the request for authorization to appeal the Quebec Court of Appeal's decision.

At the close of 2024, we await the Supreme Court's decision on the request for authorization to appeal.

An important decision that protects guiding legal principles in race discrimination cases

In last year's 2023 Annual Report, we highlighted the case of Dr. Amir Attaran. His original discrimination complaint alleged that the long wait time for the processing of parents' and grandparents' applications for permanent residence amounted to discrimination by Immigration, Refugees and Citizenship Canada. The Tribunal had dismissed Dr. Attaran's complaint that alleged discrimination based on the grounds of race, and national or ethnic origin, age, and family status.

The Canadian Human Rights Commission has a responsibility to advance human rights justice in the broadest sense. That includes showing up in court to litigate in the public interest. The Commission has prioritized our role in race-based discrimination cases like these. We do so to push for systemic anti-racism change, and to strengthen jurisprudence for anti-racism cases in Canadian law.

We sought judicial review of the Tribunal's decision in this case, because we felt that it was an opportunity to get the Federal Court to correct the approach to unconscious bias taken in the decision. We were concerned that if left unchallenged, the decision could be used to make it harder for people to prove racial discrimination.

So, in October 2024, the Commission, along with the other parties, presented oral arguments before the Federal Court, as part of the judicial review of the Tribunal's 2023 decision.

Though outside the scope of this 2024 calendric Annual Report, it bears reporting that in early January 2025, the Federal Court ruled in its judicial review to set aside the original Tribunal decision based on what is known in legal terms as a "reasonable apprehension of bias."

The Commission is pleased with the Federal Court's decision in this case. The decision rejects the idea that unconscious bias is next to impossible to prove. It clarifies that the legal test for reasonable apprehension of bias is not about the actual state of mind of the adjudicator, but rather whether a reasonable observer would believe them to be biased. This is an important decision in the evolving jurisprudence in cases involving racial discrimination.

Now, at the start of 2025, a different Tribunal member has been assigned to the case to conduct a new hearing and decide the complaint on the merits.

The rights of Black and racialized public servants

In our 2023 Annual Report, we shared how the Commission was participating in a Tribunal hearing related to alleged race-based workplace discrimination and harassment within the Canada Revenue Agency. This case began with a complaint brought by a long-time Canada Revenue Agency employee, Frantz Saint-Jean, who has agreed to be named. He alleges that Canada Revenue Agency discriminated against him based on race, colour and national or ethnic origin. Mr. Saint-Jean was supported in his complaint at the Tribunal by the Center for Research-Action on Race Relations. The Commission had argued before the Tribunal that the evidence supported the allegations of systemic and individual discrimination and harassment.

In September 2024, the Tribunal released its decision. To our disappointment, the Tribunal dismissed Mr. Saint-Jean's complaint. The Commission believes that there are errors in the Tribunal decision, and we are asking the Federal Court to overturn it. Mr. Saint-Jean is also seeking judicial review at the Federal Court. This process will take many months, and may not be argued before a Federal Court judge until late 2025.

The rights of prisoners with disabilities

In 2024, the Commission fully participated in a historic and precedential case before the Canadian Human Rights Tribunal regarding the rights of deaf people in federal prison.

Timothy Lidkea, a Deaf Métis man, filed a complaint against Correctional Service Canada. He alleged that Correctional Service Canada failed to accommodate his disability by denying him Sign language interpretation, including in situations that impacted his health, safety, and liberty. He also alleged that Correctional Service Canada failed to provide adequate assistive technology that would enable him to communicate effectively with others. He claims that he experienced profound isolation and that Correctional Service Canada's failure to accommodate him impacted his ability to, among other things, practise his Indigenous culture, communicate with legal counsel, receive medical services, participate in correctional life, and succeed in the community. Mr. Lidkea alleges that Correctional Service Canada has no policy on accommodating offenders with disabilities, particularly those who are Deaf, deafened or hard of hearing.

The rights of contract workers dismissed while on leave

In 2024, the Commission continued to participate in a case involving a truck driver who was terminated from Loomis Express, a cross-border transport company, after a period of health-related leave. In his complaint, the driver alleged that in deciding to terminate him, Loomis Express discriminated against him on the basis of age and disability.

In June, the Federal Court of Appeal upheld the Canadian Human Rights Tribunal's decision to dismiss this case. The Federal Court of Appeal concluded that the complainant's performing freight delivery services under a contract for services with Loomis Express, did not meet the definition of "employment" under section 25 of the Canadian Human Rights Act. When we appeared before the Federal Court of Appeal, we argued that the definition of "employment" under the Act should be given a broader interpretation to include the trucker driver's relationship with the freight delivery company. This case has the potential to create a precedent for workers under contracts for services in Canada in two important ways:

by defining which individual workers under contracts for services are protected under the Act when terminated while on medical leave
by assuring a broad and flexible interpretation of "employment" under the Act so that workers under contracts for services with federally regulated businesses and organizations can claim human rights protections

In September 2024, we sought leave to appeal the Federal Court of Appeal's June decision from the Supreme Court of Canada. If leave is granted, that means the next and final step of this case will be in our highest court.

Landmark settlement: Sexual misconduct in Canada's military

In 2024, the Commission helped parties reach a landmark human rights settlement in a case of sexual assault in Canada's military. This is the first human rights settlement since the implementation of the Honourable Louise Arbour's 2022 recommendations — aimed at addressing sexual misconduct in the Canadian Armed Forces.

As we explained in our joint public statement in 2024, the complainant, a Canadian Armed Forces member, had brought her complaint to the Commission after being sexually assaulted in military housing during an overseas mission. The Commission led the conciliation process between the complainant and Canadian Armed Forces officials.

The historic result was a meaningful settlement that stands to make lasting positive changes across Canada's military. It includes a formal commitment by Canadian Armed Forces to put measures in places that will increase personnel safety and improve support for victims when accessing military medical services.

In the agreement, Canadian Armed Forces specifically committed to:

enhancing personal security of its members, both in Canada and overseas
providing forensic kits and qualified medical personnel during overseas deployments
providing support and treatment for its members who experience sexual assault
maintaining an ongoing commitment to sexual misconduct prevention training

We applaud the courage of the complainant, and also the receptiveness of the respondent. Together, they were able to use our mediation services to arrive at an agreement that will help bring about systemic change and better protection of the safety and well-being of Canadian Armed Forces members.

We advocate for people's rights

As Canada's national human rights institution, the Commission promotes and advocates for human rights in Canada. Each year, we speak out on pressing and emerging human rights issues, provide advice to Parliament, and engage internationally on Canada's human rights obligations. The Commission is also responsible for monitoring Canada's implementation of the United Nations Convention on the Rights of Persons with Disabilities. When we do this work, we are known as the National Monitoring Mechanism. Under this role, we highlight disability rights issues and concerns throughout our international work and advocacy.

Our advocacy work relies upon our working relationship with human rights experts and stakeholders across Canada. As in years prior, in 2024, we engaged with a cross-section of various audiences and partners.

Maintaining "A-status" as a national human rights institution

Over the course of 2024, the Global Alliance of National Human Rights Organizations (GANHRI) conducted a special review of the Commission's A-status compliance with the Paris Principles.

The review was initiated by GANHRI at the request of civil society, who raised concerns about the Commission's compliance with the Paris Principles, alleging that the Commission "is not fulfilling its role in protecting individuals from racial discrimination, as well as the failure to maintain a non-discriminatory and inclusive workplace."

In November, GANHRI completed its independent comprehensive review and concluded that the Commission maintains its A-status. Through its decision, GANHRI has confirmed that it is satisfied with the Commission's progress and our ability to operate effectively.

The Commission provided comprehensive submissions on its efforts and appeared before the GANHRI to answer questions. We were able to share the meaningful changes we have implemented and the anti-racism work we have embedded throughout the Commission, including in our complaints review process:

The percentage of race-based complaints being referred to the Tribunal has been consistently higher than the overall rate since 2020.
The percentage of race-based complaints being dismissed has been consistently lower than the overall rate since 2021.
And race-based complaints represent the largest proportion of the complaints we are accepting, for the first time in our history.

While we welcome GANHRI's decision as independent validation that the progress the Commission has made has put us on the right path, we remain deeply committed to working towards meaningful and measurable anti-racism change. We will continue to use our independent standing before UN bodies to raise human rights issues in Canada, including specifically highlighting the issue of anti-Black racism.

A national voice

One of the Commission's responsibilities is to be a bold, independent, national voice for human rights in Canada. Our independence demands that we push Canada on its human rights commitments and keep calling for action where it is urgently needed. In 2024, we worked closely with our network of stakeholders to stay on top of emerging human rights issues, and keep sounding the alarm about:

the troubling rise over the past year in hate crimes in Canada, as well as antisemitism, Islamophobia, anti-Arab racism, and anti-Palestinian racism.
the need for action on systemic and structural racism faced by Indigenous, Black, and other racialized people.
that Canada needs stronger, enforceable human rights protections at the federal level for people who are experiencing discrimination based on socioeconomic factors, also known as their social condition.
that given the rapidly expanding use of artificial intelligence, assessing for bias and discrimination must be integrated at every stage of AI design, development and implementation.
that all children and youth in Canada deserve safe and inclusive spaces of learning — especially two-spirit, trans, non-binary, and gender diverse youth, who often face having their identity questioned or at times denied by the systems that are meant to support them.
that medical assistance in dying must be a true and informed choice, and not a default for Canada's failure to fulfill its human rights obligations to people with disabilities, and those living in systemic poverty.
that trans people are experiencing some of the most egregious right to housing violations across Canada, including: all aspects of poverty, housing insecurity, homelessness, violence and trauma.
that Canada should swiftly pass Bill C-226, which it did in June! And that those living in communities disproportionately affected by environmental racism and injustice should be able to meaningfully participate in the development of a national strategy on this issue.
that an independent Indigenous human rights system is long overdue, and that we would welcome any changes that would improve access to justice, advance decolonization, and support the distinct rights of First Nations, Inuit and Métis peoples to self-determination.
that the time is now for Canada to ratify the United Nations' Optional Protocol to the Convention against Torture and Other Forms of Cruel, Inhuman or Degrading Treatment or Punishment (OPCAT), and that doing so would improve life for several groups of people in Canada deprived of their liberty, including: migrant families in detention; elderly people in long-term care; people with disabilities who are being institutionalized in inappropriate facilities; and children — particularly Indigenous and Black children — being disproportionately institutionalized through the child welfare system.

Advising government

The Commission is regularly called upon by Parliament and other government bodies to provide our human rights expertise on proposed federal laws, initiatives and policies. This year was no exception. Here are a few key highlights:

Modernizing the Employment Equity Act

For years, the Commission has joined the collective voices of fellow advocates calling for comprehensive reform of the Employment Equity Act (EEA). It has been a long time coming, for bold and progressive changes to the EEA first enacted in 1995. The goal is to create a modern EEA system that can both redress historical harms and effectively address persistent, systemic inequities.

In 2024, we continued to actively participate in the consultative process led by the EEA Task Force. We provided a written submission to Employment and Social Development Canada's Labour Program. This was in response to their request for input on their April 2024 Consultation Paper, "Modernizing the Federal Employment Equity Act." In our submission, we reiterated the substance of our more comprehensive 2022 submission to the EEA Review Taskforce.

We are encouraged by the Labour Program's commitment to remove and update terms such as "Aboriginal peoples" and "visible minorities" within the Employment Equity Act. We welcome the Labour Program's consideration of broadening and disaggregating the designation of persons with disabilities, and how to improve data collection for members of the 2SLGBTQQIA+ community. And we are also encouraged by the participation of diverse stakeholders in the Labour Program's consultation who have emphasized key parts of the EEA Task Force report, such as the need to disaggregate racialized communities, and also highlighted important gaps, including with respect to the experiences of religious communities in Canada.

As it stands, the EEA is out of step with the changing demographics in Canada. In our 2024 submission to the Labour Program, we noted several ways in which enhanced methods and creative approaches to data collection could significantly improve understanding of employment equity issues for employers, legislators and policy-makers. We emphasized how data needs to go beyond the numbers, and capture the lived employment experiences of equity-deserving groups.

We recognized that the Employment Equity Act alone cannot directly address or remedy the root causes of social and economic marginalization, and that many persistent underlying barriers to employment may need to be addressed outside of the EEA.

Improving Canada's disability benefit

In 2024, we provided Parliament with feedback on the Canada Disability Benefit Act regulations. We strongly encouraged the government to strengthen the Canada Disability Benefit and begin rolling out this critical program as soon as possible. It is our position that the Canada Disability Benefit should ensure all people with disabilities in Canada have an adequate standard of living and can live with dignity.

Our key recommendations, published in the Canada Gazette, included expanding the eligibility criteria, increasing the benefit amount, simplifying the application process, preventing claw backs in other benefits, and protecting people from financial abuse.

The passing of the Canada Disability Benefit Act was a monumental step forward. It brought with it the promise to lift people with disabilities across Canada out of poverty and improve their quality of life. However, we are concerned that the details of this new program, as laid out in the Act's draft regulations, will fail to deliver on this promise. We'll be watching this issue very closely.

Calling for protections for those deprived of liberty

In the fall, we were invited to appear before the Subcommittee on International Human Rights of the Standing Committee on Foreign Affairs and International Development. We were asked to participate in their study on the implementation of Canada's 4th Universal Periodic Review (UPR). The UPR is essentially Canada's human rights report card, overseen by the UN Human Rights Council. The Commission has contributed to each cycle of Canada's UPR.

In our remarks to the Committee, we reiterated the urgent need for Canada to ratify the United Nations' Optional Protocol to the Convention against Torture and Other Forms of Cruel, Inhuman or Degrading Treatment or Punishment (OPCAT).

We told the Committee that this issue is not only about people detained in Canada's prisons, but also: children who are institutionalized through the child welfare system; elderly people confined to long-term care facilities; migrant detainees; and people with disabilities who are institutionalized in inappropriate facilities across the country.

We emphasized that eight years ago, the Government committed to ratify OPCAT. Since then, the Commission has been calling on Canada to follow through. We will continue to do so.

Engaging internationally and holding Canada to account

In our role as Canada's national human rights institution, the Commission works closely with the international human rights community to promote human rights here at home. In 2024, this part of our work touched a wide range of human rights issues and brought us into engagements with key human rights players, including:

meeting with the United Nations Working Group on Arbitrary Detention
being invited by the Global Alliance of National Human Rights Institutions to share our work on monitoring the rights of people with disabilities
meeting with the Special Rapporteur on the human rights to safe drinking water and sanitation during his visit to Canada
providing a statement for the regional body of National Human Rights Institutions from the Americas on the critical roles that institutions like us can play in holding their own governments to account by engaging and advocating internationally

Key United Nations submissions in 2024

Each year, the Commission makes submissions to various international human rights bodies to advise on how well Canada is upholding its human rights obligations. Our United Nations submissions raise new and emerging human rights concerns, and draw attention to long-standing inequities in Canada. Here are the highlights from the following UN submissions we delivered in 2024:

1. Human rights of People of African Descent

In September 2024, we contributed to a call for input from the Permanent Forum on People of African Descent. They were seeking topics for discussion during their fourth session. While we recognized that there are a number of different topics that could be considered, we chose to amplify a particular issue of deepening concern: the culture of denial and backlash we are seeing against anti-racism education, and other diversity, equity and inclusion initiative and laws. We urged the planners to integrate this issue, and explore effective responses to it throughout the session agenda.

We also suggested the following three topics for consideration:

policy evaluation
technology
environmental racism

2. Anti-Black racism in criminal justice system

In 2024, we provided a submission to the study being conducted by the International Independent Expert Mechanism to Advance Racial Justice and Equality in Law Enforcement. The Expert Mechanism is a group of experts who together aim to advance racial justice and equality in the context of law enforcement in all parts of the world.

We saw our submission as a good opportunity to draw attention to some of the work being done in Canada to address anti-Black racism in the criminal justice system. Our Submission focused on the context of systemic racism in the criminal justice system in Canada and amplified the work of House of Commons and Senate Committees, provincial counterparts, researchers and advocates in the area of systemic discrimination by law enforcement.

We also saw our submission as a good opportunity to draw the Expert Mechanism's attention to the related human rights violations. In particular, we focused on the use of force. Rates of use of force by law enforcement against Indigenous, Black and racialized people are higher than the general population in Canada. This is true of police interactions with the public, as well as among people in prison. Detainees, many of whom are racialized, are also vulnerable to abuse and discrimination by officials while being held in immigration detention without adequate oversight, recourse or accountability.

3. The fundamental right to safe drinking water and sanitation

In 2024, the Commission met with Pedro Arrojo-Agudo, the UN Special Rapporteur on the human rights to safe drinking water and sanitation.

We took the opportunity to shine a light on the inequitable access to safe drinking water and sanitation in Canada, and how Indigenous peoples and other marginalized communities are being disproportionately impacted by:

inadequate access to affordable and safe drinking water and sanitation
inadequate access to housing that includes, among other things, the availability of basic services such as safe drinking water and sanitation, which is an ongoing barrier
precarious living conditions in the prison system, such as poor air and water quality and unsanitary living conditions in Canadian penitentiaries

Following this meeting, we provided Mr. Arrojo-Agudo with recommendations for his consideration that were based on those three areas of concern.

4. The right of women in Canada to live free from discrimination

Every four years, Canada undergoes a review of how well it is protecting the rights of women. In 2024 the Commission provided a submission to the Committee on the Elimination of Discrimination against Women for Canada's latest review.

The Commission raised a number of concerns regarding gender-based discrimination in Canada, including:

housing insecurity and homelessness
pay equity
sexual harassment and violence, especially for women from other equity-deserving groups
complaints of sexual assault within Canada's military
human rights of women in Canada deprived of their liberty
human rights of Indigenous women and girls
rights of women with disabilities, such as access to health care and legal and financial empowerment
discrimination based on gender identity and expression, and the importance of including trans women in the inequality discussion
rights of racialized women, including their economic, social and cultural rights

5. The human rights of Indigenous peoples in Canada

In January 2024, the Commission contributed to a call for input from the Expert Mechanism on the Rights of Indigenous Peoples. The Expert Mechanism is a group of seven independent experts who provide the Human Rights Council with expertise and advice on the rights of Indigenous peoples.

Our 2024 submission was part of their study on the various legislative and judicial measures member states are taking to achieve the goals of the Declaration on the Rights of Indigenous Peoples.

We noted in our submission that while Canada has made progress, much work still needs to be done to achieve the goals set out in the Declaration here at home. We included updates on various legal instruments in Canada, including:

Canada's criminal justice system
Recent judicial decisions that advance the rights of Indigenous peoples and individuals
Senate Committee of Indigenous Peoples (APPA) study on the topic of a "Canadian Human Rights Framework" and establishing a national independent Indigenous human rights mechanism
The Office of the Correctional Investigator's report on the situation of Indigenous peoples in prisons
The outstanding discriminatory provisions in the Indian Act
Bill C-38, An Act to amend the Indian Act (new registration entitlements)
Various Canadian laws, including:
- United Nations Declaration on the Rights of Indigenous Peoples Act (UNDA)
- The Indigenous Languages Act
- An Act respecting First Nations, Inuit and Métis children, youth and families
- The Accessible Canada Act
- Bill C-29, National Council for Reconciliation Act
- Bill C-53, Recognition of Certain Métis Governments in Alberta, Ontario and Saskatchewan and Métis Self-Government Act

Also in 2024, the Independent Expert on human rights and international solidarity, Cecilia M. Bailliet, put out a call for input into what will become her report on Indigenous Peoples and International Solidarity.

The Commission was eager to provide our input and support. Specifically, we provided input related to the systemic issues that continue to negatively impact the ability of First Nations, Inuit, and Métis peoples from claiming their rights to health care, education, adequate housing, and an adequate standard of living. We also provided information outlining some of the ways in which Indigenous peoples in Canada are subject to hate speech, stereotyping, and discrimination.

6. The human rights of people deprived of their liberty

As featured in our Advocacy section, the human rights of people deprived of their liberty continued to be one of our key priorities in 2024, and this included our international work.

Here are some key highlights:

Our statement to the 55th session of the Human Rights Council

In March 2024, the Commission delivered a video-statement to the 55th session of the Human Rights Council during the adoption of the outcomes of Canada's 4th Universal Periodic Review.

In our statement, we reiterated our call for Canada to ratify the Optional Protocol to the Convention Against Torture, and we thanked member States for taking up this recommendation as well.

We also reiterated our call for Canada to implement recommendations that would help ensure that everyone in Canada can claim their economic and social rights. These recommendations are about ensuring people in Canada can live a life with dignity, equity, and respect.

We thanked Member States for taking up both our recommendations. And we were especially heartened to see that our recommendation for Canada to ratify OPCAT was taken up by the largest number of Member States — with 25 of them calling for Canada to get this done.

Our submission to the UN Special Rapporteur on contemporary forms of slavery

It's important to understand the direct human rights link between the issue of contemporary forms of slavery and the human rights of people here in Canada who have been or currently are incarcerated.

For example, in our submission to the UN Special Rapporteur Obokata, we highlighted a variety of concerns regarding labour exploitation of incarcerated and formerly incarcerated people in Canada. These issues include low wages, lack of workers' rights and benefits and limited educational or vocational training to prepare for competitive job markets upon release from prison.

We also re-emphasized the urgent and ongoing human rights issue of sexual exploitation, coercion and violence in federal prisons and its disproportionate impact on women, trans and gender diverse people.

Our meeting with the UN Working Group on Arbitrary Detention

In May 2024, we met with the UN Working Group on Arbitrary Detention at the United Nations High Commissioner for Refugees offices in Ottawa, during their official visit to Canada.

Some of the key issues that we emphasized at the meeting included:

The need for Canada to ratify the Optional Protocol to the Convention Against Torture.
The situation of migrant detainees, and how the phrase "lawfully present" in the Canadian Human Rights Act creates a gap in human rights protections for migrants who are detained in Canada.
The situation of people with disabilities who are institutionalized in inappropriate facilities due to a lack of adequate community-based supports. We provided an overview of our newly launched monitoring framework on the rights of people with disabilities.
The conditions in Canada's prisons. We raised several issues of concern, including: access to necessary and culturally appropriate programs and services; the treatment of people with substance use disorders; conditions of solitary confinement; and the lack of adequate mental health care services and supports.

7. The use of artificial intelligence technology in administrative justice system

In 2024, we made a submission to UN Office of the High Commissioner for Human Rights. This was in response to High Commissioner's call for input on the application of digital technologies in the administration of justice.

They were asking for information on how the administration of justice is being impacted by such technologies as: generative artificial intelligence, machine learning, biometric identification systems, surveillance systems, predictive analytics, digital case management systems, online hearings, and electronic monitoring.

We submitted that as Canada's National Human Rights Institution, the Commission — alongside rights holders, advocates and civil society experts — plays a crucial role in safeguarding human rights in a rapidly evolving data economy that is accelerating under the power of artificial intelligence.

We noted how we support advancements in technology and innovation that have the potential to lead to the greater realization of human rights in Canada, including through use in the administration of justice. But we emphasized that increasing the use of artificial intelligence systems in the administration of justice raises a number of important and fundamental questions about the potential risks to human rights.

We submitted that as Canada's National Human Rights Institution, the Commission has and will continue to speak out about the need for a robust and comprehensive legal and regulatory framework to prevent the harms of artificial intelligence before they occur, and offer meaningful redress where rights violations are detected.

Other international engagements

In June, we participated in the 17th session of the Conference of States Parties to the Convention on the Rights of Persons with Disabilities. We delivered a statement on behalf of the Global Alliance of National Human Rights Institutions Working Group on the Rights of Persons with Disabilities where we spoke about key elements that are essential to achieving a disability-inclusive future.

We highlighted the importance of recognizing the diverse intersectional identities and lived experiences of people with disabilities, and the protections they have under various international human rights instruments. We emphasized the principle of "Nothing without us," and the importance of including people with disabilities in decisions that affect them, as well as designing inclusively from the start, so that policies, programs, practices and technologies become accessible by design.

As mentioned elsewhere in this Annual Report, in September 2024, we were invited to share information about our new monitoring framework at an event hosted by the Global Alliance of National Human Rights Institutions (GANHRI). This side event to the 57th session of the United Nations Human Rights Council explored the unique roles of National Human Rights Institutions in protecting, promoting, and monitoring the rights of people with disabilities. We were pleased to share our experiences in developing our framework, engaging with people with disabilities, and promoting the intersecting relationship between disability rights and housing rights.

Monitoring housing rights for people with disabilities

A new framework to monitor the right to housing for people with disabilities

In 2024, the Commission, together with the Federal Housing Advocate, Marie-Josée Houle, launched a framework for monitoring the right to adequate housing for people with disabilities.

The Federal Housing Advocate

As independent and non-partisan, the Federal Housing Advocate's work focuses on ensuring housing is treated as a human right. This is why the Advocate and her staff carry out their work under the National Housing Strategy Act from within, but independently from, the Commission.
At the heart of this work is amplifying the voices of those most disadvantaged and advocating for everyone to have safe, affordable housing that meets their needs.
The Federal Housing Advocate will table her third Annual Report and Recommendations to the Minister of Housing, Infrastructure and Communities in 2025.

This framework developed by the Commission and the Office of the Federal Housing Advocate is the first of its kind. We developed it with the invaluable input of people with disabilities, their families, and caregivers, as well as people who have experienced inadequate housing and homelessness.

The framework is an important accountability mechanism. It helps assess whether Canada is meeting its human rights obligations under domestic and international law, including the National Housing Strategy Act and the United Nations Convention on the Rights of Persons with Disabilities (CRPD). Housing for people with disabilities should uphold their fundamental rights. They should be able to access housing that is affordable, safe, accessible, alongside the supports they need to live independently and feel like part of their communities.

Our monitoring framework allows us to track and advocate for the fundamental human right to adequate housing. It gathers publicly available data, primarily with figures from Statistics Canada surveys, on 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.

To date, the findings confirm what people with disabilities have been saying for years: people with disabilities have poorer housing outcomes than people without disabilities and are being denied their basic human rights. More specifically, the findings indicate that, when compared to people without disabilities, people with disabilities are:

four times more likely to experience homelessness
more likely to experience homelessness because of violence or abuse (these figures were even higher for women with disabilities)
more likely to live in unaffordable housing, and almost twice as likely to live in core housing (live in housing that is unaffordable, in bad condition, and too small)
more likely to miss a rent or mortgage payment because of financial issues
less likely to own their homes
more likely to be forced to move due to economic reasons, including financial hardship related to the COVID-19 pandemic
more likely to wait longer for subsidized housing
more likely to live in housing with poor air quality, unsafe drinking water, mould and/ or pests
less likely to feel like part of their communities

The findings also indicate that many people with disabilities:

are unable to choose their place of residence and live in institutions, such as long-term care homes and group homes
don't have the personal assistance necessary to live independently, such as help with bathing, cooking, cleaning, or shopping
lack housing that meets their accessibility needs

In addition to the data, we have learned through our engagement with disability communities, that some people with disabilities are turning to medical assistance in dying (MAiD) because they cannot access adequate housing and supports. In other words, without the supports they need to live with dignity, they are choosing to die with dignity. This is unacceptable.

We have already begun using these findings to advocate for data gaps to be filled. With encouraging interest in our framework, we are hopeful that these findings will not only inform more advocacy across Canada, but also meaningful discussion and change from the Government.

Supporting and leading human rights research

Each year, the Commission cultivates human rights knowledge and expertise by conducting and supporting research into emerging human rights issues, and by working with advocacy groups, civil society and other human rights experts, in addition to people with lived experience.

It all informs the Commission's positions on new and emerging human rights issues in Canada. Informed by this research and knowledge, we advocate and raise awareness among our public audiences, including: educators, academics, public servants, employers, service providers, members of the media, members of the public, and Parliamentarians.

Impacts of artificial intelligence

Since 2021, we have been proud to be one of three organizations collaborating in a joint research project on the human rights impacts of artificial intelligence technologies. This ongoing project is being led by the Law Commission of Ontario, with our Commission and the Ontario Human Rights Commission serving as partners.

As part of this project, we were pleased to be able to contribute to the Law Commission of Ontario's development of a new Human Rights Impact Assessment Tool, launched in the fall of 2024. This tool, one of the firsts of its kind, will protect people in Canada by allowing organizations to approach the use of artificial intelligence in a way that identifies, mitigates and ideally prevents discrimination.

All of this research and development is happening at a critical moment in our history. The use of artificial intelligence is rapidly expanding. Both public and private sector organizations are increasingly using systems powered by artificial intelligence to make key decisions, provide important services, and shape the lives of individuals and communities.

Bias and discrimination amplified by artificial intelligence are real and complex, but can be easily overlooked. Left unchecked, the use of artificial intelligence (AI) can cause deep and long-standing harm to individuals, communities and organizations. Assessing for bias and discrimination is a complex task that should not be an afterthought, nor a minor consideration. It must be integrated at every stage of AI design, development and implementation. This new tool can help.

The Commission will continue to work closely with our partner organizations on new research and any new resources that can help identify and consider discrimination and other human rights issues in the use of artificial intelligence.

Environmental racism and injustice

An emerging area of human rights study that we have been working closely is what fellow advocates and experts are referring to as environmental racism or environmental injustice.

Essentially, it refers to the disproportionate proximity and greater exposure of Indigenous, Black and other racialized communities to polluting industries and environmentally hazardous activities. It describes the negative impacts that living in those areas has on low-income residents' health and human rights. As author Dr. Ingrid Waldron put it in our 2021 Annual Report: "In Canada, your postal code determines your health."

At the beginning of 2024, we published our Summary Report on the Fast Talk roundtable discussion we held with a panel of experts on environmental racism in Canada. We are forever indebted to each of the experts who participated in this meaningful discussion. The valuable knowledge and expertise have made clear the link between environmental racism and human rights in Canada.

They confirmed for us the complex, interconnected factors involved in environmental racism and injustice in Canada, including the role of colonialism and the disregard for Indigenous knowledge. They told us about the negative effect of environmental racism on the human right to adequate housing and on the health of impacted communities and individuals.

One expert participant told us: "The standard that we have, that low-income people live in polluted environments, is really the target. In my opinion, we can change that standard and this is where we need to focus."

Bill C-226 passed in 2024

In June, Parliament passed bill C-226, "An Act to develop a national strategy to assess, prevent and address environmental racism and to advance environmental justice."

This was a victory that we and so many other advocates had been calling for, and it is a welcomed step in the right direction. We will continue to push for environmental racism and environmental injustice to be a fundamental part of any conversation on how to improve the human rights of equity-deserving groups in Canada.

We help prevent discrimination

At the core of the Commission's mandate is not only our mission to promote and protect human rights in Canada, but to help federally regulated employers and organizations put proactive measures in place to foster inclusion and prevent discrimination before it takes place.

Prevention runs through so much of our work. For example, the systemic remedies we help parties reach through mediation and litigation often include preventative policies and programs that the organizations are required to put in place. Other times, the process of mediation can lead to a new awareness for the people involved—a new way of doing things that improves workplaces for many others.

Our research and engagement with right-holders with lived experiences helps inform new guidance we provide to Canadian institutions that will help them prevent discrimination or other human rights issues.

We also support federally regulated employers and service providers across Canada in taking proactive steps to eliminate barriers and meet their legal obligations under:

The Canadian Human Rights Act
The Accessible Canada Act (Office of the Accessibility Commissioner)
The Employment Equity Act
The Pay Equity Act (Office of the Pay Equity Commissioner)

With both the Accessibility Commissioner and Pay Equity Commissioner submitting their own Annual Reports on their progress over the past year, what follows are just some of the highlights of our prevention work in 2024, including our own proactive measures we are putting in place as a federally regulated employer.

Providing new human rights guidance to employers

The Commission regularly provides updated human rights guidance to the Canadian public. While not legal advice, our guidance is meant to provide individuals and employers with a foundation from which to understand their rights and responsibilities, and how to create more inclusive workplaces and organizations.

In 2024, we published a full suite of updated human rights guidance on:

Workplace accommodation

In our updated Workplace accommodation - A guide for federally regulated employers, and its companion accommodation policy template, we explain key human rights workplace concepts, including the duty to accommodate, undue hardship, a bona fide occupational requirement, and we offer a step-by-step approach to developing a workplace accommodation policy.

Environmental sensitivities

Our updated guide on Environmental sensitivities and scent-free policies provides a human rights-based lens for accommodating those with environmental sensitivities, such as Multiple Chemical Sensitivity. The guide provides an overview of this invisible disability, and how people who have environmental sensitivities are protected federally by human rights law. It also offers a list of promising practices when creating a scent-free policy.

Addressing workplace harassment and violence

Our updated guidance on Preventing and addressing workplace harassment and violence, and its companion policy template, is an effective tool that will help federally regulated employers meet their obligations under the Canadian Human Rights Act and the Canada Labour Code, and ultimately prevent harassment, sexual harassment and/or violence in their workplace. The guidance provides clear definitions of key terms and offers a four-point plan on preventing workplace harassment and violence.

Workplace investigations

In 2024, the Commission also published a guide on a human rights-based approach to workplace investigations. The guide is for federally regulated employers who want to learn more about what is required of them when they are looking into a possible issue of workplace harassment or violence that has come to their attention. The guide provides good practices for how to conduct a workplace investigation in a way that respects people's human rights and promotes a healthy and inclusive workplace.

Promoting compliance with the Employment Equity Act

Under the Employment Equity Act, the Commission is responsible for conducting audits to determine if federally regulated employers are taking steps to increase workplace representation for the following designated groups: women, Indigenous peoples, people with disabilities, and racialized people.

Over the course of 2024, the Commission continued using an audit approach we have been adapting and improving for decades. We completed and published our Forward Plan for fiscal years 2024–25 to 2026–27. The forward plan outlines the employers and federally regulated sectors that are set to be audited in the upcoming fiscal years. In line with the forward plan, we started planning for an upcoming audit series that will look at the representation of people with disabilities in the water transportation.

We concluded preliminary assessments for the employer-specific audits (also known as conventional audits) of nine departments and agencies, and one crown corporation. At the close of 2024, the audit reports to individual employers were being drafted, with the reports expected to be issued in the new year.

We also made headway in a series of issue-based audits (also known as horizontal audits) looking at the representation of women in management positions in the air transportation sector. We issued employment equity surveys to 90 employers as part of this issue-based audit and notified the five employers selected for full audits.

In 2024, we notified the eight employers selected for an issue-based audit looking at the representation of racialized people in the ground transportation sector. The assessment of the evidence submitted by employers is underway, with individual audit reports expected to be issued in the beginning of 2025.

We also concluded audits of all remaining employers under the comprehensive, issue-based audit of racialized people in management and executive positions in the public service. The sector-wide report for this issue-based audit is scheduled to be released in 2025. The report outlines the key findings of the issue-based audit and shares the positive practices uncovered that can enhance employers' employment equity programs.

Modernizing the Employment Equity Act

In 2024, the Commission continued to provide our expertise on how best to update the Employment Equity Act so that it can better reflect a Canada of today. We provided input and responses to the ministry of labour during their consultations on the Employment Equity Act Task Force's recommendations. Read more under "Advising Government."

Promoting compliance with the Accessible Canada Act

The Office of the Accessibility Commissioner promotes, monitors and enforces compliance with the Accessible Canada Act and regulations for some 5,000 federally regulated employers in Canada.

Currently, the Accessible Canada Act regulations require federally regulated organizations to:

identify and remove barriers, and prevent new barriers to accessibility in seven areas
develop accessibility plans, feedback process descriptions and progress reports
consult people with disabilities throughout this work
make their accessibility plans, their feedback process, and their progress reports public

This past year marked an important milestone as it was the first year in which all federally regulated organizations had a specific compliance deadline they had to meet under the Accessible Canada Act. Their specific deadlines varied depending on factors such as the size of the organization or whether they are private or public.

By carrying out inspections, responding to inquiries, and conducting in-depth analysis, the Office of the Accessibility Commissioner has been able to gauge the awareness, readiness and compliance of various federally regulated organizations. This data informs how the Office of the Accessibility Commissioner targets and promotes compliance, and how they monitor activities for the upcoming year. Additionally, the Office created a variety of resources to assist regulated organizations in meeting their compliance obligations, such as guidance, templates and videos.

The Office of the Accessibility Commissioner completed upwards of 286 inspections in 2024 — verifying if and how regulated organizations are meeting their regulatory obligations.

The Office of the Accessibility Commissioner also continued to work with the other government organizations who share in the responsibility of implementing the Accessible Canada Act: the Canadian Transportation Agency, and the Canadian Radio-television and Telecommunications Commission. In 2024, they continued to work together to identify emerging issues and best practices in how to keep federally regulated organizations informed of their obligations. Collaboration with federally regulated organizations will remain a vital component of promoting and monitoring compliance.

In 2024, the Office of the Accessibility Commissioner continued to receive and refer hundreds of inquiries from federally regulated organizations and members of the public, looking for technical information about their regulatory requirements. A small subset of the inquiries was related to complaints under the Accessible Canada Act.

While at the close of 2024, no complaints have been substantiated, the Office of the Accessibility Commissioner ensured that complainants were supported in navigating the Accessible Canada Act's complaints system, and that individuals were referred to the appropriate organization to help them.

In 2025, key updates will be presented in the Annual Report to the Minister of Jobs and Families.

Promoting compliance with the Pay Equity Act

The Commission's work towards achieving pay equity across federally regulated organizations is led by Canada's Pay Equity Commissioner, Lori Straznicky. It has been another busy year of milestones for Pay Equity Commissioner Straznicky and her office.

Together, they are actively helping federally regulated entities meet their obligations under the Pay Equity Act. Specifically, a key focus in 2024 was on supporting employers in meeting their September deadlines for posting their first pay equity plans, and paying out increases in financial compensation. Already looking beyond that milestone, the Office focused on the next significant step of the pay equity process. It will require federally regulated organizations to begin the maintenance process, and submit their Annual Statements to the Pay Equity Commissioner.

With the Pay Equity Portal in full operation, the Office has been focusing on responding to questions, processing authorization requests and releasing decisions by the Pay Equity Commissioner. The success of this online resource is evident. The Office received 686 requests for information and 436 authorization requests during 2024.

Also operational in the federal pay equity regime this year:

an Administrative Monetary Penalty Policy
a dispute resolution process, which brought the Pay Equity Commissioner 67 pay equity complaints, seven matters in dispute, and one matter of objection in 2024

The Office of the Pay Equity Commissioner also continued building relationships this year with federal stakeholders, as well as international and provincial counterparts, to keep advancing the Pay Equity Act and the goals of pay equity across Canada.

In 2025, Pay Equity Commissioner Straznicky will provide more detail on this and other key updates in her Annual Report to Parliament.

Holding ourselves accountable as a federally regulated employer

The Commission is a public, federally regulated employer. We hold ourselves accountable to the same anti-racism, diversity, accessibility, equity and inclusion standards to which we hold all federally regulated employers in Canada. In 2024, we continued to strive to create a safe, inclusive and barrier-free workplace for all Commission employees.

We documented our 2024 diversity, inclusion and equity efforts in our self-assessment on the Call to Action on Anti-Racism, Equity, and Inclusion and our self-assessment on actions to advance a renewed conversation on values and ethics delivered to the Clerk of the Privy Council Office, and in our 2024 Accessibility Progress Update, and our forthcoming 2024 Anti-Racism Progress Update.

Upward trend in representation

Approximately 1 in 4 employees at the Commission self-identify as Black or racialized.
Approximately 1 in 3 executives at the Commission self-identify as Black or racialized.
More than 3 in 4 employees at the Commission self-identify as women.
The Commission has the second highest representation of people with disability of any department or agency in the federal public service.

Diversity in our hiring and mentoring

We have launched a multifaceted recruitment strategy that includes setting recruitment goals and promotion goals for Indigenous, Black, and other racialized employees. The strategy also includes mentorship, sponsorship, and other human resources initiatives.
We are leveraging non-advertised appointments — including acting appointments — to increase representation of the four groups designated under the Employment Equity Act.
We have launched and are recruiting employees to participate in our organization-wide Mentorship and Sponsorship Plus Program to increase representation of equity-deserving groups in leadership positions, and ensure they are supported in achieving their career goals.
We are participating in the Treasury Board's Mosaic program, which is designed to develop equity-deserving employees at the EX minus 1 level to support their entry into the executive cadre. This is the second consecutive year that the Commission has successfully nominated employees to Mosaic.
To improve our hiring practices for neurodiverse applicants: we are including the human resources advisor's contact details at the very top of the poster; we are giving candidates clear details in advance, such as how many questions they'll answer and how long the interview will take; and we are ensuring candidates get at least 24 hours to complete and return their examinations.

A psychologically safe Commission for all employees

We are using input from Indigenous, Black, and other racialized employees to develop and finalize our Mental Health Action Plan and continue to ensure employees have access to mental health supports.
We are exploring how the psychological safety of racialized staff is affected at work, and are designing responses such as pursuing leadership training and tools for managers and supervisors, and exploring other forums to address these concerns.

Updating our Code of Conduct

This past year we carried out the first comprehensive review, consultation, and update of our Code of Conduct since 2016. This in-depth review was informed by extensive consultations with people from equity-deserving groups, employees, managers, executives, senior leaders, and bargaining agents. Our priority for our updated Code of Conduct is to ensure it reflects the Commission of today, as well as the diverse perspectives, questions, and feedback of employees.
In the winter of 2024, the Commission held a facilitated discussion with senior leadership — including branch heads and Commissioners — about values and ethics. This dialogue was informed by the changing context of the Commission and the federal public service.
We took the insights we received during the winter discussion and used it to build our newly launched Conflict of interest self-assessment tool. This tool allows employees to reflect on their personal situation and highlights potential risks for conflict.
Our self-assessment tool was included as a promising practice in the Clerk of PCO's summary report on values and ethics.
We developed a training plan that includes mandatory values and ethics training for all levels at the Commission on specific topics such as conflicts of interest.
We are continuing to create safe spaces to enhance learning, nurture commitment, and deepen employee understanding of how to make ethical decisions that balance public service and personal values.

Working towards a more accessible, barrier-free Commission

In our built environments in our Montreal, Toronto and Ottawa offices, we have made physical improvements, including: widening our hallways, installing more automatic doors, making our washrooms more accessible, and ensuring accessible technology tools are available to staff.
We have overhauled our information and communication technologies starting with a comprehensive revamp of the Commission's public website, informed by user feedback. Our new website provides individual users with a more barrier-free and swifter path to the human rights information they need.
We strengthened our contracting directive so that accessibility is considered in the procurement of goods and services.
More detailed updates are available in our 2024 Accessibility Progress Update. We continue to approach these efforts with the deep understanding that people with disabilities are not a homogenous group, but are rather a collective of unique individuals, each with their own set of experiences, needs and perspectives.

HR1-4E-PDF

2560-6352

2025-06-03

Annual reports

Human Rights

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