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Recommendations to strengthen the National Housing Strategy

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May 18, 2018

Honourable Jean-Yves Duclos
Minister of Families, Children and Social Development
House of Commons
Ottawa, ON, K1A 0A6

Evan Siddall
President and CEO
Canada Mortgage and Housing Corporation
700 Montreal Rd
Ottawa, ON, K1A 0P7 

Dear Minister Duclos and President Siddall:

RE: Recommendations to strengthen the National Housing Strategy

I trust this letter finds you well. The Ontario Human Rights Commission (OHRC) is committed to bringing a human rights perspective to government and community strategies aimed at addressing poverty, homelessness and hunger. I am writing today to commend the Government for introducing Canada’s first National Housing Strategy, and to make recommendations to ensure that it is meaningful, effective, and meets Canada’s obligation to progressively realize the fundamental human right to housing.

Canada must progressively realize the right to housing

The right to housing has been recognized by Canada for over 60 years—since adoption of the Universal Declaration of Human Rights in 1948. By ratifying the International Covenant on Economic, Social and Cultural Rights (ICESCR) over 40 years ago, Canada further committed to recognize and take steps to progressively realize this right, to the maximum of its available resources, including through legislation. All levels of government—federal, provincial, territorial and municipal—are bound by Canada’s international human rights obligations.

The right to housing is affirmed in myriad international human rights treaties to which Canada is a party. Moreover, the United Nations Declaration on the Rights of Indigenous Peoples, which Canada recently adopted and committed to implement, affirms that Indigenous peoples have a right to be actively involved in developing, determining and administering housing programs that affect them.

Canada’s housing crisis demands a rights-based approach, with a special focus on the rights of Indigenous peoples

Despite these binding legal commitments, Canada’s legal protection of rights related to housing is a patchwork and includes tenant protection, health and safety, human rights, as well as many other laws, regulations and programs. Housing organizations and civil society across the country have been tireless in their advocacy for a national approach that is comprehensive, strategic and results-driven.

It is clear that a new approach is needed to ensure the rights of Canadians to adequate housing. Despite being one of the richest countries in the world, Canada is in the midst of a severe housing and homelessness crisis. The Homelessness Partnering Secretariat regularly estimates that between 150,000 and 300,000 individuals experience homelessness in Canada in a given year. Statistics Canada states that in 2014, 8% of Canadians aged 15 and over reported that, at some point in their lives, they had to temporarily live with family, friends, or somewhere like their car, because they had nowhere else to live – a situation referred to as “hidden” homelessness. People with a history of childhood maltreatment, lower levels of social support, people with disabilities, and Indigenous people were more likely to have experienced hidden homelessness.

Too many Canadians are under-housed, homeless or living in poverty. The persistence of hunger and homelessness is evidence of Canada’s failure to progressively realize economic, social and cultural rights, including the right to housing, protected in international law. This situation is especially concerning from a human rights perspective, because many of the people who cannot access stable and affordable housing identify with grounds protected in human rights law. In almost every city, people with mental health disabilities and addictions are over-represented in the homeless population. Women, older persons, children and youth (especially LGBTQ youth), transgender people, and racialized people face unique discrimination and marginalization that impacts their ability to obtain secure housing.

First Nations, Métis and Inuit peoples are also over-represented in the urban homeless population. When Indigenous people obtain housing, it is often substandard. According to Statistics Canada, in 2016, one quarter (24.2%) of Indigenous people in Canada lived in a dwelling in need of major repairs. The proportion of First Nations people who lived in a dwelling that needed major repairs was more than three times higher on-reserve (44.2%), than off-reserve (14.2%). The rights of Indigenous peoples to adequate housing, and to be involved in determining, developing and administering that housing, must be realized – not only in the north and on-reserve, but also off-reserve in rural and urban communities across Canada.

The National Housing Strategy is an unprecedented opportunity to realize the right to housing

Canada’s introduction of a National Housing Strategy is an unprecedented opportunity to progressively realize the right to housing. If properly implemented, and coupled with a National Indigenous Housing Strategy, it will result in real, sustained progress toward ending homelessness, providing adequate housing, and relieving poverty.

The January 2018 report of the UN Special Rapporteur on Adequate Housing sets out the foundational principles of a rights-based housing strategy. We recommend that the National Housing Strategy incorporate these foundational principles. We also support the recommendations of the Ontario Federation of Indigenous Friendship Centres in their January 2018 submission on the National Housing Strategy.

Recommendations from the Ontario Human Rights Commission

To ensure a fully rights-based approach that can realize the right to housing in Canada, we recommend that the National Housing Strategy and related implementation measures:

  1. Explicitly recognize the right to adequate housing as defined in international law.
  2. Refer to the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, the UN Declaration on the Rights of Indigenous Peoples and other international human rights instruments addressing housing rights.
  3. Clearly set out the obligation of all levels of government to progressively implement the right to housing in a timely way.
  4. Commit to addressing systemic inequality in housing on the basis of disability, gender, race, gender identity, and age, prioritizing those most in need.
  5. Provide an accessible, effective public process for hearing, adjudicating and remedying systemic issues related to housing.
  6. Establish measurable goals, indicators and timelines and ensure robust, independent monitoring of progress by a body with jurisdiction to address systemic issues and hold government accountable.
  7. Commit to and begin the process of developing a National Indigenous Housing Strategy, including an Urban Indigenous Housing Strategy, in partnership with Indigenous leaders, housing service providers, and community organizations.

We encourage you to ensure that the National Housing Strategy addresses the concerns and integrates the recommendations of diverse Indigenous communities, the Social Rights Advocacy Centre, Advocacy Centre for Tenants Ontario, researcher-advocate Emily Paradis, the Canadian Alliance to End Homelessness, and the Indigenous Caucus of the Canadian Housing and Renewal Association.

The National Housing Strategy has the potential to make major progress toward alleviating poverty, homelessness and the affordable housing crisis, and to advance the human rights of some of the most vulnerable people in our society. We are encouraged by the Government’s commitment to a human rights-based approach, and urge you to adopt our recommendations in full so that the National Housing Strategy meets its potential to progressively realize the rights protected in international human rights law.


Renu Mandhane, B.A., J.D., LL.M.
Chief Commissioner
Ontario Human Rights Commission

cc: Hon. Jane Philpott, Canada Minister of Indigenous Services

Hon. Peter Milczyn, Ontario Minister of Housing

Hon. Yasir Naqvi, Attorney General for Ontario

OHRC Commissioners