Standing Committee on Justice Policy

Part 1: Introduction and Context

1.1 Origin of the Committee and Report

In 2024, the Subcommittee on Intimate Partner Violence, a subcommittee of the Standing Committee on Justice Policy, was established with a dual mandate: to examine whether intimate partner violence in Ontario constitutes an epidemic and to address delays in the province’s courts in hearing sexual assault cases. Recognizing the critical importance of these issues to public safety, justice, and societal well-being, the subcommittee committed to conducting a thorough review grounded in evidence-based research, testimony, and stakeholder consultation.

From the outset, the committee’s design and scope were shaped to address the complexities inherent in intimate partner violence and sexual violence, collectively referred to as gender-based violence (GBV). While the term GBV highlights the gendered nature of these forms of violence, the committee acknowledges that victims may include people of all genders and backgrounds, underscoring the need for an inclusive and nuanced approach.

As work began, the committee’s mandate evolved. The committee lead recommended an expanded scope to comprehensively assess the causes, responses, and prevention of both intimate partner violence (also commonly referred to as domestic violence) and sexual violence. This expansion reflected the interconnected nature of these issues and aimed to address the broader spectrum of challenges faced by victims, communities, and the justice system.

The resulting framework became one of the most extensive inquiries of its kind in Ontario, examining every facet of these pervasive societal harms. The committee focused on understanding how these forms of violence manifest, their root causes, and their impacts on victims, families, and communities. It also sought to identify best practices for prevention, intervention, victim support, legal remedies, offender accountability and rehabilitation, and systemic improvements. The subcommittee aimed to offer practical, actionable recommendations that align with Ontario’s capacity to respond effectively and efficiently, providing a roadmap for reducing and ultimately eliminating these forms of violence.

Through its work, the committee engaged with victims, experts, service providers, legal professionals, academics, and advocacy organizations. Testimonies and submissions highlighted the profound and often intergenerational consequences of intimate partner violence and sexual violence, as well as the challenges faced by Ontario’s justice system, social services, and communities in addressing these issues. These insights were instrumental in shaping the recommendations presented in this report.

The breadth of this mandate reflects the reality that intimate partner violence and sexual violence are not isolated issues but intersect with broader systemic, social, and economic factors. Prevention requires addressing these root causes, as well as enhancing Ontario’s capacity to measure and reduce violence, further improve access to justice, and ensure the safety and well-being of all Ontarians.

This report represents the culmination of the committee’s work. It is intended to provide a foundation and a roadmap for ongoing collaboration among governments, stakeholders, and communities as they continue to work together to build a safer, healthier, and more equitable Ontario. The committee’s recommendations are informed by evidence and aim to deliver practical solutions with measurable outcomes, emphasizing both the need for continued action and the long-term benefits of sustained investment in prevention and intervention.

1.2 Is Intimate Partner Violence an Epidemic? A Clear and Definitive Answer

The committee was tasked with addressing the important question: Should intimate partner violence (IPV) in Ontario be declared an epidemic? After careful review, the committee has concluded that IPV is better understood as an endemic issue—persistent, deeply rooted, and profoundly harmful.

This determination does not diminish the seriousness of IPV but instead underscores its true nature as a societal issue that requires sustained, systemic, and multi-sectoral action. Framing IPV as endemic recognizes the complexity and scale of the problem, while emphasizing the need for solutions that address its underlying causes and systemic nature. Recognizing IPV and SV as endemic provides an opportunity to shift from reactive, temporary measures toward sustained, systemic investment in prevention, intervention, and accountability.

It is important to clarify that the committee approached its work from the outset with a clear understanding of IPV’s seriousness. There was never any question that IPV is a pervasive and insidious problem that continues to harm individuals, families, and communities across Ontario. While determining whether IPV constituted an epidemic was part of the committee’s mandate, this was never the central focus of its work. The committee’s primary purpose has been to identify systemic gaps, propose solutions, and develop comprehensive recommendations to strengthen Ontario’s response to IPV and sexual violence (SV).

The committee recognizes that for many victims and advocates, the term “epidemic” carries important symbolic weight as a call for urgency and action. However, this report seeks to move beyond symbolic gestures by emphasizing sustained, systemic solutions that align with the realities of IPV’s deeply rooted nature.

1.2.1 Distinguishing Epidemic and Endemic Concepts

In public health contexts, an epidemic refers to a sudden and widespread increase in a condition or issue that requires urgent, short-term interventions to contain and mitigate its effects. Epidemics are temporary crises defined by their rapid escalation and the effectiveness of reactive measures in reducing prevalence. The WHO defines an epidemic as “the occurrence of disease cases in a specific community or region in excess of normal expectancy,” often requiring immediate, time-limited interventions.¹ Similarly, the CDC describes an epidemic as “the occurrence of more cases of disease than expected in a given area or among a specific group of people over a particular period of time.”²

By contrast, an endemic issue is one that is persistent and entrenched, affecting a population consistently over time. Endemic problems, like IPV and SV, are deeply rooted in societal, cultural, and economic systems. They evolve and adapt over generations, sustained by structural inequities such as gender inequality, economic instability, and inadequate access to services. The CDC explains that an endemic condition has a “constant presence…within a given geographic area or population,” signifying persistent patterns rather than sudden outbreaks.³ Canadian health authorities, such as the Public Health Agency of Canada, underscore that addressing endemic issues often involves tackling systemic and structural factors that perpetuate their existence.⁴

This distinction reveals key challenges in applying epidemic language to IPV and SV. To understand why IPV does not fit the definition of an epidemic, it is essential to consider its key characteristics:

• Chronic and Intergenerational: IPV is not a sudden phenomenon. It has existed throughout history and continues to affect individuals across demographics and geographies. Its intergenerational impact perpetuates cycles of harm, distinguishing it from the temporary spikes characteristic of epidemics.
• Resistance to Reactive Solutions: Epidemics are often addressed through targeted, short-term interventions. IPV, however, is deeply entrenched and cannot be resolved through containment or immediate action. It requires ongoing prevention, education, and systemic reform.
• Societal and Structural Roots: Epidemics typically arise from external factors, such as pathogens or environmental changes. IPV, by contrast, is sustained by structural and cultural systems that require deliberate, long-term dismantling.

Sexual violence shares these endemic characteristics. Like IPV, it is persistent, pervasive, and rooted in systemic inequities and generational traumas. Yet, unlike IPV, there have been no widespread calls to declare SV an epidemic. This disparity, highlighted by several presenters to the committee, underscores the risks of focusing exclusively on epidemic language for IPV. By drawing disproportionate attention to IPV, such efforts can overshadow equally serious and pervasive issues like SV, which remains deeply stigmatized and underaddressed in public discourse.

1.2.2 Context of the “Epidemic” Narrative

The idea of declaring IPV an epidemic in Ontario gained prominence following the release of the 2022 Renfrew County inquest report. The jury, in an effort to highlight the urgency of addressing IPV, recommended that Ontario declare IPV an epidemic.⁵ Testimony from advocates, such as Pamela Cross, emphasized parallels with Ontario’s COVID-19 response, suggesting that similar political will and resource allocation could significantly reduce IPV’s prevalence.

In the years following the inquest, this language has been embraced by numerous municipalities in Ontario and by the Province of Nova Scotia, with declarations that IPV constitutes an epidemic. These decisions, often rooted in good intentions, reflect a genuine desire to validate the experiences of victims and draw attention to the pervasive harm caused by IPV. While such declarations may raise awareness, they remain largely symbolic and lack the operational mechanisms necessary to effect meaningful change.

Although the COVID-19 response serves as a valuable example of what can be achieved with sufficient political will and investment, it is important to recognize the fundamental differences between addressing a pandemic and addressing IPV. COVID-19 was a sudden and acute crisis, requiring immediate containment measures to mitigate its spread and impact. IPV, by contrast, is a deeply entrenched societal issue sustained by systemic inequities and cultural attitudes. It cannot be “contained” through short-term interventions alone, nor is there a single, centralized approach that can address its pervasive and intergenerational nature.

Recognizing IPV and SV as endemic provides an opportunity to shift from reactive, temporary measures toward sustained, systemic investment in prevention, intervention, and accountability. While declarations of this nature may raise awareness, they do not trigger funding mechanisms, systemic reforms, or policy changes. Ensuring that victims and survivors have a clear understanding of the steps required to achieve meaningful, sustained action is essential to fostering trust and creating real progress.

The committee acknowledges the genuine efforts of those who have adopted this language in good faith. However, it maintains that meaningful solutions require systemic, evidence-based action that goes beyond symbolic gestures. Accordingly, the committee declines to make any recommendation to Ontario to follow suit. Victims deserve solutions that address the root causes of violence and create sustained, measurable improvements, grounded in a clear understanding of the complexity and scale of the problem.

1.2.3 The Need for Long-Term, Systemic Solutions

The approach recommended in this report reflects the seriousness of IPV and SV and the sustained effort required to address them. The recommendations are comprehensive, encompassing prevention, intervention, and systemic reform. Many of these measures will take years to implement and even longer to bear fruit, reflecting the complexity of the issue and the commitment required to achieve meaningful change.

This committee prioritizes evidence-based action over symbolic declarations, emphasizing the importance of sustained, coordinated efforts to create lasting change. Recognizing IPV and SV as endemic does not diminish their seriousness; it underscores the necessity of sustained, coordinated efforts to create lasting change. This approach is rooted in responsibility, compassion, and a commitment to ensuring that Ontario’s response is meaningful, sustainable, and effective. Victims and survivors deserve nothing less.

1.3 Historical Background and Evolution of Ontario’s Government Response to Intimate Partner Violence

Ontario’s response to intimate partner violence/domestic violence (IPV/DV) and SV has developed over decades, driven by growing awareness of the profound harm caused by these forms of violence and the need for coordinated, meaningful action. Early interventions in the 1980s and 1990s focused on establishing a safety net for survivors, including emergency shelters, crisis hotlines, and safe homes. These efforts were complemented by public awareness campaigns aimed at reducing stigma and encouraging victims to seek support.

As societal understanding of IPV evolved, Ontario’s strategies became more sophisticated, integrating prevention and education initiatives alongside support services. Programs sought to address not only immediate crises but also the systemic and root causes of violence. Legislative reforms introduced in the 2000s, such as the establishment of Domestic Violence Courts, underscored the province’s commitment to ensuring that IPV cases were handled with sensitivity and expertise.⁶ Public-facing campaigns like “It’s Never Okay” further emphasized prevention through education, aiming to challenge harmful attitudes and foster healthier relationships.⁷

Comparative data from Statistics Canada highlights Ontario’s progress relative to other provinces. Among Canadian provinces, Ontario has the lowest rate (victims per 100,000) of police-reported IPV.⁸ This is a remarkable achievement for a province with Ontario’s size and diversity. While unreported incidents remain a significant challenge nationwide, Ontario’s position is unlikely to change even when accounting for the underreporting that affects all jurisdictions. This data suggests that Ontario’s sustained investments in prevention, support, and justice reforms have contributed to measurable progress in mitigating IPV.

At the same time, IPV and SV remain critical issues in Ontario, as they do across Canada. The prevalence of violence and its devastating impact on individuals, families, and communities remind us that no single initiative or strategy can fully resolve such a complex problem. While past efforts have not eliminated IPV, they have strengthened public awareness, enhanced supports for survivors, and fostered collaboration across sectors. These measures have provided a foundation that continues to inform Ontario’s efforts to address these challenges and respond to the evolving needs of survivors and communities.

1.3.1 Inquests: A Lens into Complex Issues and Remedies

Inquests conducted by the Office of the Chief Coroner into domestic homicides provide invaluable insights into the complexities of IPV and SV. While inquest findings are advisory rather than mandatory, they play a vital role in identifying systemic gaps and offering recommendations to improve prevention, intervention, and support systems.

Over the past 40 years, more than 15 inquests into domestic homicides in Ontario have explored a range of critical issues and provided recommendations to address them. Each inquest reflects the unique circumstances of individual cases while also highlighting recurring themes and challenges faced by society as a whole.

Key Inquests and Their Contributions:

• Arlene May and Randy Iles Inquest (1998): This inquest, following a tragic murder-suicide, resulted in 213 recommendations emphasizing enhanced training and collaboration for police and Crown attorneys and expanded services in rural communities.
• Lori Dupont Inquest (2002): Focused on IPV in the workplace, this inquest led to recommendations on workplace safety policies to better protect employees experiencing domestic violence.
• Gillian Hadley Inquest (2002): Highlighted the importance of safety planning and risk assessment within the criminal court system, particularly in high-risk cases.
• Vu Duy Pham Inquest (2012): Underscored the critical need for better information sharing across systems to ensure coordinated responses to IPV.
• Carol Culleton, Anastasia Kuzyk, and Nathalie Warmerdam Inquest (Renfrew County, 2022): Addressed systemic issues surrounding high-risk offenders and called for enhanced coordination among criminal justice professionals to improve responses in high-risk situations.
• Gladys Ryan Inquest (2023): Focused on domestic violence among aging couples, identifying unique risk factors and challenges associated with this demographic.

While each inquest offered case-specific recommendations, several common themes have emerged over the years:

1. Enhanced Public Awareness and Education: Many inquests called for greater public education campaigns to raise awareness about IPV, promote healthy relationships, and encourage help-seeking behaviour.
2. Professional Training: The need for specialized training for police, Crown attorneys, healthcare providers, and other frontline professionals has been a recurring recommendation to ensure more informed and sensitive responses.
3. Prevention Programs in Schools: Multiple inquests highlighted the importance of prevention through early intervention, recommending school-based programs that teach children and youth about healthy relationships and conflict resolution.
4. Risk Assessment and Safety Planning: Developing standardized risk assessment tools and integrating safety planning into criminal and family court processes has been a consistent focus.
5. Cross-Sector Collaboration: Inquests often emphasized the importance of better coordination and communication across sectors, including law enforcement, healthcare, and social services, to provide seamless support to victims.
6. Data Collection and Systematic Reviews: Recommendations for systematic reviews of domestic homicides led to the creation of the DVDRC in 2003, a pivotal step in monitoring and learning from these tragedies.

1.3.2 The Domestic Violence Death Review Committee (DVDRC): Ontario’s Pioneering Effort

In response to recommendations from these multiple inquest juries, Ontario established Canada’s first-ever DVDRC in 2003 under the Office of the Chief Coroner. Since its inception, the DVDRC has served as a model for similar committees in seven other provinces, as well as in jurisdictions across the United States, Australia, New Zealand, and the United Kingdom. While the organization and funding of DVDRCs vary internationally, their shared purpose is clear: to analyze domestic homicides and identify actionable insights to prevent future tragedies.

1.3.2.1 Scope and Purpose of the DVDRC

Over two decades (2003–2023), Ontario’s DVDRC has reviewed 420 cases involving 606 deaths, providing critical insights into patterns of domestic violence and missed opportunities for intervention. Through its multidisciplinary committee, the DVDRC has access to comprehensive case information, including police investigations, interviews with family and friends, and files from social service and mental health professionals. This in-depth analysis seeks to:

1. Identify risk factors or red flags present before the homicide.
2. Highlight systemic gaps in response to IPV.
3. Provide recommendations to government ministries, professional bodies, and agencies on needed changes in training, policy, and practices.

1.3.2.2 Key Findings from DVDRC Reviews

The DVDRC’s annual reports consistently highlight troubling yet actionable patterns:

• Predictable and Preventable Tragedies: Most domestic homicides reviewed were found to involve multiple identifiable risk factors—often seven or more—known to those closest to the victim and perpetrator or to community professionals. Common risk factors include: recent separations; a history of domestic violence; excessive alcohol or drug use; stalking; prior threats or access to weapons; and controlling behaviors and victim isolation.
• Homicide-Suicides and Child Victims: Approximately one-third of cases involve a homicide-suicide, and 10% include the homicide of children in the context of domestic violence. The majority (85%) of adult victims are women, and perpetrators typically have a documented pattern of domestic violence prior to the homicide.
• Gaps in Perpetrator Intervention: A recurring theme is the lack of engagement in specialized intervention programs for perpetrators. Most of the men involved in these cases had not completed programs designed to address abusive behavior, highlighting the need for enhanced accountability measures and program availability.

1.3.2.3 Recommendations and Themes

A decade-long analysis (2010–2020) of DVDRC reports reviewed 400 recommendations made across the cases analyzed.⁹ These recommendations, often repeated over the years, fall into four primary categories:

1. Education and Training: Increased public awareness and enhanced professional training to identify and respond to IPV risks effectively.
2. Collaboration and Coordination: Improved cross-sector communication and cooperation among service providers and systems.
3. Policy, Program, and Legislative Changes: Recommendations aimed at addressing systemic gaps and ensuring more comprehensive protections for victims.
4. Risk Assessment and Safety Planning: Development and implementation of enhanced risk assessment tools, safety planning protocols, and risk management strategies.

Each recommendation is directed to a specific Ontario ministry, professional body (e.g., social workers, physicians), or agency (e.g., police, children’s aid societies). While most recommendations are acknowledged and often receive initial responses, there is currently no formal mechanism for monitoring or ensuring their implementation. This challenge is one that this report explores further in subsequent sections.

1.3.3 Government Strategies: The Evolution of Ontario’s Response to IPV, SV, and HT

Ontario has been a leader in recognizing domestic violence as a public safety concern. Forty years ago, Ontario became the first province to classify domestic violence as a crime, mandating police and Crown attorneys to pursue charges based on reasonable and probable grounds rather than requiring victims to file private charges. This policy shift underscored a broader societal acknowledgment that domestic violence is not a private matter but a serious public issue. It was accompanied by targeted training programs for police and Crown attorneys, as well as investments in specialized services for victims, perpetrators, and children exposed to violence.

Over the decades, Ontario has developed numerous strategies and frameworks to enhance its response to IPV, SV, and HT. Key milestones include:

• Domestic Violence Advisory Committee (2009): Focused on developing a province-wide approach to IPV.
• Sexual Violence Action Plan (2011): Dedicated resources to improving services for survivors and addressing the root causes of SV.
• Strategy to End Human Trafficking (2016): Aimed at protecting survivors, preventing exploitation, and holding perpetrators accountable.
• Ontario STANDS Action Plan (2023): Standing Together Against Gender-Based Violence through Decisive Actions, Prevention, Empowerment, and Supports (STANDS) is a multi-ministerial framework designed to enhance collaboration across sectors, streamline services, and emphasize prevention and empowerment.

1.3.3.1 Learning from Past Strategies

Ontario’s numerous strategies and action plans have laid the groundwork for progress but have also highlighted areas for improvement. The province’s ongoing efforts provide valuable lessons for the future:

• Building on Existing Initiatives: Many strategies have created innovative pilot programs and collaborative frameworks. The challenge remains to integrate these initiatives and scale successful models across the province.
• Cross-Sector Collaboration: Inter-ministerial and community-based collaboration has been a central focus of Ontario’s approach. Continued emphasis on seamless coordination across systems—such as child protection workers, police, judges, social workers, educators, and healthcare professionals—can strengthen responses and improve outcomes.
• Addressing the Diversity of Ontario Communities: Recognizing the unique needs of Indigenous, rural, and immigrant communities, Ontario has supported culturally responsive services and Indigenous-led initiatives. Tailored approaches remain essential to ensuring equity and effectiveness.
• Data-Driven Approaches: Ontario has made strides in recognizing the importance of data collection, particularly through the work of the DVDRC. Strengthening data infrastructure and outcome measurement systems can enhance the province’s ability to track progress and adapt to emerging challenges.

1.3.3.2 Success Stories

Several initiatives stemming from inquests and DVDRC reports have been recognized as successes in Ontario’s response to IPV, SV, and HT:

• The Domestic Violence Death Review Committee (DVDRC): A model for other provinces and territories, the DVDRC has provided critical insights into domestic homicides and recommended actionable steps to prevent future tragedies. Its findings have informed training programs for police, Crown attorneys, and healthcare professionals.
• Workplace Safety Legislation: Following recommendations from the Lori Dupont inquest, Ontario amended its Health and Safety legislation to include provisions for addressing domestic violence in the workplace.
• Family Law Reforms: Legislative changes to the Ontario Children’s Law Reform Act now require judges to consider family violence and coercive control when making parenting decisions, aligning with recommendations from inquests and DVDRC reports.
• High-Risk Teams and Risk Management Protocols: Many Ontario communities have developed high-risk teams to coordinate responses for the most concerning cases, enhancing safety planning and risk management.

1.3.3.3 Ontario’s Current and Planned Initiatives

Building on its historical foundation, Ontario has outlined several initiatives to address IPV, SV, and HT comprehensively. These measures reflect the government’s focus on prevention, survivor support, and systemic reform.

1. Action Plan to End Gender-Based Violence (2023): Supported by a $1.4 billion provincial investment over four years, the plan aims to enhance prevention, improve victim services, and address legal and housing barriers. Federal funding of $162 million from the National Action Plan to End Gender Based Violence bolsters these efforts.
2. Victim Support Services: Programs like the Victim/Witness Assistance Program (VWAP) and the Independent Legal Advice for Survivors of Sexual Assault Program provide critical support for survivors navigating the justice system.
3. Human Trafficking Initiatives: The Anti-Human Trafficking Strategy includes CARE (Children at Risk of Exploitation) units and culturally responsive programs, such as Indigenous-focused healing lodges.
4. Culturally Responsive Services: Pathways to Safety supports Indigenous-led organizations in delivering IPV services tailored to community needs.
5. Justice System Measures: Domestic Violence Courts (DVCs) coordinate prosecution and support services for IPV cases. The Partner Assault Response (PAR) Program provides rehabilitative services for perpetrators. Judicial training under Keira’s Law supports informed decision-making in IPV cases.
6. Prevention and Awareness: Public awareness campaigns, curriculum updates in schools, and workplace safety measures aim to address the root causes of IPV, SV, and HT.
7. Housing and Economic Supports: The Canada-Ontario Housing Benefit prioritizes survivors, offering financial assistance to secure safe housing. Programs like Investing in Women’s Futures support survivors in achieving economic independence.

1.3.4 Challenges in Previous Strategies and Lessons Learned

While Ontario’s initiatives have laid crucial groundwork in addressing IPV, SV, and HT, they have often faced limitations that hindered their ability to achieve desired outcomes. These challenges, though reflective of systemic barriers, provide valuable insights into opportunities for improvement.

1.3.4.1 Challenges in Previous and Existing Strategies

1. Fragmented and Inconsistent Implementation: Many frameworks were piloted successfully in specific regions but lacked the resources or coordination to be scaled effectively across the province. Variability in funding and resource allocation led to inconsistent service delivery, particularly in underserved communities.
2. Limited Focus on Prevention and Early Intervention: Significant resources were directed toward supporting victims after incidents occurred, while primary prevention and early intervention efforts remained underfunded. The absence of long-term, sustainable prevention strategies perpetuated cycles of violence, impacting both victims and future generations.
3. Insufficient Data Collection and Outcome Measurement: A lack of consistent data infrastructure and standardized outcome tracking limited the ability to evaluate progress or identify effective practices. Despite recommendations from inquests and reports, challenges in establishing data-sharing protocols among agencies hindered improvements.
4. Inadequate Cross-Sector Collaboration: Although collaboration was emphasized in theory, operational challenges and siloed approaches often disrupted seamless cooperation. Limited communication and information sharing between law enforcement, healthcare providers, and social services created gaps in coordinated support for victims.

1.3.4.2 Lessons Learned for a New Path Forward

Ontario’s previous strategies provide essential lessons for developing a more cohesive and effective response to IPV, SV, and HT. By addressing systemic gaps and building on successful initiatives, the province can create a sustainable framework for lasting change.

The Committee’s recommendations are informed by four core pillars:

1. Enhanced Coordination and Scalability: Scale successful programs across all regions with consistent funding, coordination, and training to ensure equitable access to services.
2. Data-Driven Accountability: Invest in infrastructure for consistent data collection and outcome measurement to inform evidence-based adjustments to programs and policies.
3. Primary Prevention and Early Intervention: Prioritize long-term prevention strategies that address root causes and break cycles of violence, protecting future generations from harm.
4. Streamlined Collaboration: Establish clear, standardized protocols for cross-sector cooperation, ensuring seamless support between law enforcement, healthcare providers, and social services.

This report highlights a pivotal opportunity for Ontario to build on its strong foundation and continue leading the way in addressing IPV and GBV as critical public health and safety concerns. By expanding on past successes and leveraging the lessons learned, Ontario is well-positioned to adopt a proactive, system-wide approach that emphasizes prevention, survivor support, and systemic reform.

Through the implementation of the Committee’s recommendations, Ontario can further strengthen its framework to not only meet the immediate needs of survivors but also create lasting solutions that prevent violence and foster safer, healthier communities for generations to come.

1.4 Structure of the Committee and Its Phased Approach

The Subcommittee on Intimate Partner Violence and Sexual Violence was designed to ensure a comprehensive and structured examination of these complex issues. Its work was divided into three phases, each with a distinct focus:

1.4.1 Phase One: Expert Testimony

Phase One prioritized insights from a carefully selected group of experts, including advocacy organizations, service providers, researchers, and academics. These presenters were identified through a detailed research process and invited based on their specialized knowledge and relevance to the committee’s mandate. The subcommittee did not issue an open call for submissions during this phase.

The names and contact information of prospective presenters were provided to the legislative clerk, who managed invitations and scheduling. A total of 10 days were allocated for presentations, with up to 100 slots available. Presenters were required to submit written materials in advance, using structured problem statements to outline key issues, impacts, and potential solutions. These guidelines sought to ensure that submissions were clear, focused, and actionable.

To support participants in preparing their materials, the committee lead offered optional preparatory sessions. These sessions allowed presenters to ask questions, clarify the committee’s objectives, and receive advice on how to maximize the impact of their presentations. While many participants utilized this opportunity, not all opted to do so.

Despite careful planning, some invited presenters were unable to participate. To accommodate cancellations, alternate speakers were identified and invited on short notice. Ultimately, the committee heard from 89 presenters during Phase One. Written submissions from these participants were compiled to form a foundational body of evidence for the committee’s work.

Each presentation was followed by a question-and-answer period, allowing committee members to seek clarification and explore topics in greater depth. This interactive approach ensured a thorough understanding of the issues raised.

The written guidelines provided to participants emphasized the importance of framing their submissions around clearly identified problems and solutions. These guidelines, along with the full list of Phase One presenters, are included as appendices to this report.

1.4.2 Phase Two: Government and Ministerial Testimony

Phase Two of the subcommittee’s work focused on gathering insights from key government ministries involved in addressing IPV and SV. This phase was designed to provide the committee with an understanding of the current provincial responses to these issues, including policy frameworks, legislative initiatives, resource allocations, and inter-ministerial coordination.

The subcommittee invited testimony from ministers overseeing portfolios directly linked to the prevention, response, and mitigation of IPV and SV. These included:

• Charmaine Williams, Associate Minister of Women’s Social and Economic Opportunity, responsible for initiatives addressing gender-based violence and improving women’s safety and economic security.
• Jill Dunlop, Minister of Education, overseeing curriculum development and programs promoting awareness of healthy relationships and consent.
• Sylvia Jones, Minister of Health, and Michael Tibollo, Associate Minister of Mental Health and Addictions, addressing healthcare and trauma-informed mental health supports for survivors of IPV and SV.
• Greg Rickford, Minister of Indigenous Affairs, focusing on culturally responsive approaches to IPV and SV within Indigenous communities.
• Michael Parsa, Minister of Children, Community and Social Services, responsible for child protection services and supports for those impacted by violence.
• Michael Kerzner, Solicitor General, supporting law enforcement and community safety initiatives related to IPV and SV.
• Doug Downey, Attorney General, overseeing the justice system’s role in prosecuting IPV-related offences and supporting victims through legal processes.

Each minister was invited to present an overview of their ministry’s strategies, policies, and programs and to participate in a question-and-answer session with committee members. These presentations were meant to provide insight into the government’s coordinated response to IPV and SV and identify areas of strength as well as opportunities for amendment.

Phase Two served a dual purpose:

1. To provide a comprehensive overview of Ontario’s existing responses to IPV and SV, including inter-ministerial collaborations and the allocation of resources.
2. To ensure that the committee’s recommendations were informed by an understanding of the current provincial landscape, supporting targeted and actionable solutions.

By hearing directly from ministers, the committee emphasized the importance of accountability and cross-sector collaboration. This phase established a foundational understanding of the government’s efforts, setting the stage for the committee’s final analysis and recommendations.

1.4.3 Phase Three: Victim Testimony

Phase Three of the subcommittee’s work focused on hearing directly from victims of IPV and SV, as well as family members of victims who wished to share their experiences. This phase was designed to provide survivors with an opportunity to voice their stories, helping the committee to better understand the systemic challenges and barriers they face. The goal was to ensure that survivors’ lived experiences informed the committee’s recommendations while recognizing the diversity of those experiences.

1.4.3.1 Open Call for Submissions

Participation in Phase Three was open to individuals personally impacted by IPV or SV. A public advertisement invited interested individuals to request to appear before the committee by the deadline of 12:00 p.m. on January 6, 2025. Written submissions were also invited, with a separate deadline of 5:00 p.m. on January 23, 2025.

Testimony during this phase followed a clear and structured format. Each presenter was allocated 20 minutes to make a statement, with the option to participate in person at Queen’s Park or remotely via virtual platforms. The committee allocated availability for 60 separate survivor statements, ensuring a dedicated opportunity to hear from as many individuals as possible within the allotted timeframe. Presenters were not questioned by committee members, a deliberate choice to avoid replicating the adversarial atmosphere of a courtroom, as many survivors had previously engaged with family or criminal court systems.

1.4.3.2 Closed Session Hearings

All Phase Three proceedings were conducted in closed session to protect the privacy and safety of participants. Closed sessions were not recorded or broadcast, and testimony did not appear in Hansard. Present were the legislative clerk, a legislative researcher, and a member of the broadcasting team to manage technical logistics. Each member of the Subcommittee on Committee Business was permitted one staff designate to observe the proceedings. Confidentiality was paramount. Written submissions were accessible only to committee members and designated staff, ensuring that participants’ privacy was fully respected. These measures addressed concerns raised by survivors about the public nature of legislative hearings while encouraging open and trauma-informed participation.

1.4.3.3 Trauma-Informed Supports

Recognizing the need for trauma-informed practices, the committee provided access to mental health counselors during all testimony days. Two counselors, hired specifically for Phase Three, were present in person at Queen’s Park and available by phone for remote participants. Their role was to offer immediate support during and after testimony, helping to mitigate the emotional toll of sharing deeply personal experiences.

1.4.3.4 Purpose of Phase Three

The testimony gathered during Phase Three provided invaluable insights into the lived realities of survivors and their interactions with various systems. While acknowledging the uniqueness of each individual’s journey, the committee sought to identify recurring themes, systemic barriers, and areas for improvement. These contributions informed the committee’s understanding of IPV and SV and shaped recommendations that reflect the voices of those most directly impacted.

Part 2: Prevention

Section 1: Prevention Initiatives in Education

1.1 Introduction: In-School Prevention as Scalable Infrastructure

The prevention of intimate partner violence (IPV), sexual violence (SV), and human trafficking (HT) has historically been treated as a social objective rather than a core component of public safety infrastructure. However, decades of research now suggest that the lack of early interventions—particularly during adolescence—carries measurable consequences across Ontario’s justice, healthcare, and child welfare systems.

Among available delivery mechanisms for prevention, the education system offers the most efficient, equitable, and scalable infrastructure. Unlike community-based interventions, which depend on voluntary participation and may exclude high-risk populations, schools reach nearly all youth across Ontario.

1.1.1 The Fourth R: A Curriculum-Based Prevention Model

The Fourth R (Relationships) is a school-based prevention program designed to reduce interpersonal violence, dating aggression, and risky sexual behaviour through the development of healthy relationship skills. Originally developed in Ontario by researchers at Western University, the program integrates directly into the Health and Physical Education curriculum and is delivered by classroom teachers as part of routine instruction. Its name reflects a core premise: that relationship education is as essential to adolescent development as reading, writing, and arithmetic.

The program includes a sequence of 21 structured lessons delivered across three curriculum units. It is available in English and French, with culturally adapted versions for Indigenous youth and newcomer communities, and is delivered in Grades 7, 8, and 9 across multiple provinces.

Outcome Evaluation: A randomized controlled trial (RCT) involving 1,722 Grade 9 students across 20 Ontario schools found that students who received the program were significantly less likely to perpetrate physical dating violence 2.5 years post-intervention. The effect was especially pronounced among male students.¹⁷

Cost Efficiency: Under a centralized model with Ministry-licensed access and online training, per-student costs have been projected as low as $0.20 per year. The program yields an estimated return of between $5 and $15 per $1 invested when downstream healthcare, justice, and social service costs are part of the modelling assumption.

Estimated Impact at Scale: Full implementation across Ontario’s publicly funded schools would reach an estimated 450,000 students over a three-year cycle. Evaluations suggest province-wide implementation would result in a 61.4% reduction in dating violence perpetration among boys two years post-intervention, an estimated 26,550 fewer boys offending over two years, and an average public sector cost savings of approximately $2,000 per student.

1.1.2 Coaching Boys Into Men: A Sport-Based Prevention Program

Coaching Boys Into Men (CBIM) is an evidence-based violence prevention program that engages athletic coaches as primary agents of change. Developed by Futures Without Violence, the program provides a 12-week curriculum of brief, scripted conversations designed to be delivered during practices or team meetings.

A CDC-funded RCT of implementation in 41 middle schools showed that male athletes receiving the intervention reported increases in positive bystander behaviors by more than 50%, and athletes in schools implementing CBIM had 76% lower odds of abuse against a romantic partner 1 year later.³⁸

In 2023, the Ontario government provided $875,000 in targeted funding to expand CBIM delivery. As of 2024, CBIM has been implemented in approximately 172 publicly funded secondary schools, representing about 20% of the provincial total of 872.

Full implementation in the 700 remaining secondary schools would require a one-time investment of approximately $1.75 million—equivalent to under $3 per student. Annual maintenance costs for retraining coaches are estimated at less than $110,000.

1.1.3 SNAP for Schools

SNAP for Schools adapts the core strategies of the SNAP cognitive behavioural intervention into a universal, classroom-based program for Grades 1–6. Delivered in 12 weekly sessions, it teaches students to “stop, think, and plan” before acting. Evaluation data shows 83% of students demonstrate reduced aggressive behaviour, 86% show improved peer relationships, and 90% exhibit better teacher-student interaction.

1.1.4 School-Based Nutrition Programming

Ontario’s Student Nutrition Program (SNP), administered by the Ministry of Children, Community and Social Services, provides meals and snacks to over one million students annually at an estimated cost of approximately $0.10 per student per day. The program is universal and serves a structural prevention function by reducing reliance on peers or adults for subsistence needs and stabilizing classroom engagement.

1.2 Understanding Modern Adolescent Risk

1.2.2 Teen Dating Violence (TDV)

Over one-third of students in Grades 9 and 10 who reported being in a dating relationship indicated they had experienced physical, emotional, or technology-facilitated abuse from a dating partner within the past year. This equates to over 90,000 Ontario students annually experiencing teen dating violence victimization.⁶⁹

TDV is an established predictor of continued victimization and perpetration across the life course. TDV disproportionately affects youth who experience social marginalization, including LGBTQ+ youth, Indigenous youth, racialized youth, and youth living in poverty.

1.2.3 Technology-Facilitated Teen Dating Violence (TF-TDV)

Technology-Facilitated Teen Dating Violence refers to acts of abuse, control, coercion, or harassment perpetrated by a dating partner through digital tools or platforms. Common manifestations include requiring location-data sharing, installing Bluetooth trackers, demanding access to nude images, and screen-recording private video calls without consent.

Adolescents rarely frame TF-TDV experiences in legal terms, yet they may be subject to charges including criminal harassment, unauthorized use of a computer, extortion, voyeurism, non-consensual distribution of intimate images, and possession of child pornography.

1.2.4 Sexual Violence (SV)

Sexual violence in adolescent contexts encompasses a broad spectrum of nonconsensual behaviours, including sexual harassment, coercion, unwanted touching, assault, and rape. It also includes acts such as sexualized name-calling, persistent propositioning, and the exposure or circulation of sexual rumours. While peer-on-peer sexual violence has received increasing public attention in recent years, it remains structurally minimized within school policy frameworks and is often conflated with less serious categories of interpersonal harm.

1.2.4.1 Prevalence and Demographics

According to Statistics Canada, females aged 15 to 17 represent the single highest-risk demographic group for police-reported sexual assault in the country. In 2022 alone, youth aged 12 to 17 accounted for 30% of all victims in police-reported sexual assault cases. These figures are likely underestimates. Most sexual assaults—particularly those committed by peers—are never reported to law enforcement or school officials. Disclosure rates among adolescents remain low, due in part to fears of social retaliation, self-blame, normalization, and institutional minimization.

The Canadian Centre for Gender and Sexual Diversity (CCGSD) found that over 40% of secondary school students report experiencing unwanted sexual behaviour from peers. This includes being touched, grabbed, or kissed without consent; being subjected to sexual rumours or jokes; and being exposed to sexually explicit comments or gestures. Many of these acts occur in school environments or in settings closely connected to school peer networks.

1.2.4.2 Underreporting and Absence of Policy Classification

In Ontario, there is no statutory requirement for school boards to separately define or report on sexual violence. As a result, incidents are frequently recorded under generic behavioural categories such as “inappropriate behaviour,” “bullying,” or “peer conflict.” The absence of an explicit definition prevents data collection, masks patterns, and limits both public accountability and internal risk identification. Some boards do use internal administrative tracking tools (e.g., Safe Schools Incident Reporting forms), but these forms do not consistently disaggregate sexual violence as a standalone category. Without a naming mechanism, there is no corresponding expectation to develop targeted training, policy, or response infrastructure.

1.2.4.3 Educator Readiness and Barriers to Student Disclosure

In the absence of explicit definitions or consistent training, educators often lack clarity on how to identify sexual violence—or how to distinguish it from conduct that may appear mutual or “social.” When youth disclose, they may meet with minimization or misunderstanding, particularly when the acts involve digital platforms, alcohol use, or complex peer relationships. This discourages further disclosure and erodes student trust in adult systems.

Institutional misclassification may also result in procedural inequity. For example, schools may treat both parties as equally culpable in cases of retaliatory disclosure, without recognizing the relational power differential or coercive context. In other instances, schools may require a “witness” or written evidence before acting—an evidentiary burden not typically placed on youth reporting other categories of harm.

1.2.4.4 Intersectional Risk and Systemic Compounding

Sexual violence disproportionately affects youth who are already subject to structural marginalization. LGBTQ+ youth, Indigenous youth, and racialized students report higher rates of both sexual victimization and institutional betrayal. For example, CCGSD’s national survey found that trans students were significantly more likely to report both peer-based sexual harassment and teacher inaction or dismissal.

People in rural or northern regions may face risks due to lack of anonymity, transportation barriers, and entrenched community dynamics. In such contexts, young victims may be forced to share classroom or extracurricular spaces with the person who harmed them, with no alternative options available. Policies governing transfers or class reassignments often do not apply when the alleged perpetrator is another student rather than a staff member.

1.2.5 Technology-Facilitated Sexual Violence (TFSV)

The emergence of generative AI tools has created new vectors for sexual violence. Apps such as Nudify, DeepNude, and DreamGF allow users to create realistic nude images of individuals from fully clothed photos. In 2024, police in both Winnipeg and London, Ontario confirmed the existence of such images created by students targeting peers. In both cases, no charges were laid due to gaps in applicable law.

1.2.6 Legal Exposure Among Adolescents

Adolescents who engage in digital behaviours involving sexual content, image sharing, or surveillance often do so without a clear understanding of their legal exposure. Many are unaware that their actions constitute offences under the Criminal Code—or that they can be charged, prosecuted, and registered as sex offenders even when the conduct occurs within a peer relationship. As a result, a growing number of youth are being criminalized for behaviours they do not perceive as criminal, with long-term consequences that outstrip their developmental comprehension.

1.2.6.1 Applicable Criminal Offences

Several Criminal Code provisions are regularly applied to adolescent conduct involving sexual or relational harm. These include s. 162.1 (non-consensual distribution of intimate images), s. 163.1(2), (3), and (4) (making, distributing, or possessing child pornography), s. 264 (criminal harassment), s. 346 (extortion), s. 162 (voyeurism), and s. 430(1.1) (mischief in relation to data).

Many of these offences were not designed with adolescents in mind and do not account for developmental capacity, relational coercion, or normalized peer dynamics. For example, a 14-year-old who forwards a nude image of a classmate—even one initially shared voluntarily—may be charged with distributing child pornography. A youth who receives a coerced sexual image and stores it on their device may be deemed to be “in possession” of child pornography under Section 163.1(4).

These charges apply regardless of the minor status of the individuals involved. While Crown discretion and Youth Criminal Justice Act (YCJA) principles may result in diversion or alternative measures, the potential for criminal record exposure, police flagging, and sex offender registration remains.

1.2.6.2 Developmental Capacity and Risk Misperception

Adolescents are particularly vulnerable to criminalization for behaviours they do not fully understand. Numerous studies have found that youth often lack the cognitive and emotional capacity to assess risk, anticipate long-term consequences, or distinguish between private and public digital spaces. Many do not realize that deleting a message does not prevent others from saving it, that screenshots can be taken silently, or that location data can be passively harvested by apps or metadata.

Advocates emphasize that messaging aimed at youth—such as “never send a nude” or “once it’s out, it’s out”—is not only ineffective but counterproductive. These messages can reinforce shame, deter disclosure, and exacerbate panic in situations of sextortion or image leakage. Youth often believe that there is no path to repair or recovery after a sexual image circulates, which may contribute to the risk of suicide among victims of sextortion, particularly boys.

In such cases, victims may avoid seeking help for fear that they themselves will be criminally charged. Cybertip.ca has documented cases where youth who attempted to report sextortion were flagged as potential offenders due to their possession of images shared with them in the grooming process.

1.2.6.3 Variable Enforcement and Systemic Inconsistencies

While many police services and Crown attorneys exercise discretion when responding to adolescent image-sharing offences, outcomes vary significantly across jurisdictions. Some services prioritize education and prevention, while others rely on formal charges. This creates a fragmented legal landscape in which similar behaviours may be treated as diversionary in one region and criminally in another.

Youth may also be subject to non-criminal but serious administrative consequences. School boards may refer cases of image sharing or sextortion to police under mandatory reporting policies, even when the conduct involved no malicious intent. Once a police file is generated, the incident may appear in vulnerable sector checks or future records screening—even in the absence of conviction or formal diversion.

1.2.7 Technologies Commonly Used in Adolescent Digital Abuse

Common platforms and tools include Snap Map and location-sharing platforms, Apple AirTags and Bluetooth trackers, shared account access and device mirroring, AI-generated content tools and deepfake apps, encrypted sharing and group-based image circulation, and screen recording and livestream capture.

1.2.8 Caregiver Awareness Gaps

Most Canadian parents and caregivers remain unaware of the digital landscape inhabited by adolescents. While general concerns about “screen time” and “cyberbullying” are increasingly common, most adults do not understand the specific technologies, tactics, or interpersonal dynamics that define modern adolescent relationships. This misalignment between perceived and actual risk constitutes a major barrier to prevention, intervention, and policy development.

1.2.8.1 Knowledge Gaps and Misconceptions

Recent national research confirms that parents are under-informed about both the prevalence and nature of technology-facilitated violence. Many parents assume digital harms are rare, or that only “other people’s children” engage in sexting, image sharing, or location tracking. Caregivers tend to frame such behaviours as isolated mistakes rather than patterns of coercion, surveillance, or structural harm.

Common misconceptions include: belief that most teens are “too smart” to share nude images; assumption that images must be voluntarily shared to be circulated; unawareness that AI-generated synthetic nudes can be created from fully clothed images; equating TF-TDV with “jealousy” or “drama” rather than coercive control; and assuming that sextortion and deepfake abuse only affect girls.

These misconceptions prevent parents from asking informed questions, identifying warning signs, or intervening early. They may also inadvertently perpetuate stigma by reinforcing messages such as “you should have known better” or “just don’t send nudes,” which can deter youth from disclosing harm.

1.2.8.2 Limitations of Common Caregiver Prevention Messaging

The dominant parental prevention message—“Don’t ever send a nude”—is widely regarded by researchers as both ineffective and harmful. While well-intentioned, this guidance assumes that harm arises solely from a youth’s decision to share content, rather than from coercion, manipulation, theft, or synthetic fabrication. This message also positions image-based abuse as the victim’s fault, rather than as an act of violence perpetrated by others.

This framing is particularly damaging in cases involving sextortion. Boys who are blackmailed by strangers posing as girls frequently internalize the belief that they are solely to blame for the situation and that there is no way to recover once an image is captured. This belief—reinforced by parental messaging and social stigma—has been cited in multiple suicide cases in Canada over the past three years.

1.2.8.3 Impact of Adult Underreaction on Youth Disclosures

When youth attempt to disclose abuse or coercion, they are often met with confusion, panic, or minimization from adults. Some youth are told by parents to “stay off that app” or to “block the person,” without acknowledgment of the relational or reputational dynamics at play. Others are told to “just stop talking to him,” despite being in emotionally or digitally entangled relationships involving shared passwords, mutual image possession, or peer reputation exposure.

This adult response—though often grounded in concern—can exacerbate harm. Youth may experience increased shame, fear of punishment, or reluctance to disclose future incidents. Adolescents often prefer to resolve digital abuse through informal or non-legal channels, but require adult guidance that is non-punitive, informed, and emotionally neutral.

The systemic impact is significant. When parents are uninformed, school administrators receive incomplete context, police officers encounter reluctant complainants, and policymakers face inconsistent input from constituents. Public understanding remains limited, preventing the broad societal recognition required to generate structural reform.

1.2.9 Gaps in Ontario’s Educational Policy

Neither the Education Act, RSO 1990, c E.2 nor its associated regulations define teen dating violence, sexual violence, technology-facilitated sexual violence, or technology-facilitated dating violence. No provision mandates schools to record or respond to sexual violence or dating violence separately from bullying.

Policy/Program Memoranda (PPMs) 144, 145, and 166 offer no definition or obligation regarding TF-TDV or TFSV. This absence prevents standardized reporting, consistent staff training, and public accountability.

1.2.10 The Operational Significance of Statutory Definitions

Definitions are not symbolic. In education law and regulatory frameworks, definitions determine whether a harm must be tracked, reported, trained for, or responded to in policy. They form the basis for coding categories, data reporting fields, and staff expectations. When a harm is not defined, it is not measured. When it is not measured, it is not monitored, resourced, or addressed.

1.2.10.1 Definitional Precision as a Policy Lever

School boards are legally obligated to implement policies aligned with terms defined in the Education Act, ministry memoranda, and board-specific student conduct codes. However, in the absence of definitions for terms such as teen dating violence, technology-facilitated dating violence, technology-facilitated sexual violence, or image-based abuse, school boards are under no obligation to report or track them. Policy obligations default to the terms available—such as “bullying,” “sexual harassment,” or “inappropriate behaviour”—which are too broad to capture the unique risk patterns or intervention needs of the harms in question.

This lack of specificity prevents standardized reporting of incidents across boards, consistent staff training and disciplinary protocols, public accountability for school-based sexual violence or dating abuse, and survivor access to dedicated support or alternative arrangements.

1.2.10.2 Precedents from Other Jurisdictions

Other provinces have implemented statutory or regulatory definitions for digital sexual harm. Nova Scotia’s Intimate Images and Cyber-Protection Act, SNS 2017, c 7, includes image-based abuse under a civil remedy framework. Manitoba amended its Intimate Image Protection Act in 2023 to explicitly include AI-generated synthetic images, setting a precedent for recognizing technologically mediated forms of abuse even in the absence of physical nudity.

In the United States, many states have now adopted education laws that define teen dating violence as a distinct form of peer violence requiring separate policy responses. These laws vary in scope but typically require boards to define the harm, create prevention policies, and provide educator training. Several require districts to track TDV prevalence and report incidents to the state education authority.

Canada has no equivalent provincial legislation. Ontario does not define TDV, TF-TDV, SV, or TFSV in its education laws, and thus requires no board-level obligation to address or document them.

1.2.10.3 Cascading Consequences of Omission

Without formal definitions: victims are not consistently identified; perpetrators may be misclassified, criminalized, or untreated; patterns cannot be tracked longitudinally; staff are not trained to intervene or refer appropriately; and prevention messaging lacks specificity and credibility.

Definitional clarity does not resolve harm, but it creates the conditions under which institutions can begin to respond. It delineates responsibility. It enables infrastructure. It permits the tracking of what is otherwise invisible.

1.2.11 Institutional Effects of Definitional Absence

The absence of statutory, regulatory, and policy recognition for Teen Dating Violence (TDV), Technology-Facilitated Teen Dating Violence (TF-TDV), Sexual Violence (SV), and Technology-Facilitated Sexual Violence (TFSV) has cascading consequences. These consequences manifest not only in student outcomes but in systemic misclassification, staff uncertainty, and institutional exposure.

1.2.11.1 Misclassification of TFV in Incident Reporting

Without definitional guidance, most incidents of sexual harm, coercive digital abuse, or dating violence are recorded under general behavioural categories such as “bullying,” “misuse of technology,” or “peer conflict.” This framing strips the conduct of its gendered, coercive, or relational dynamics and places it on par with non-violent misconduct. The resulting data is functionally useless for identifying prevalence, trends, or intervention outcomes. Board- and province-wide tracking systems are not equipped to identify or flag escalating risk.

In high-profile cases of deepfake pornography, image-based extortion, or coercive password-sharing, schools often rely on administrative tools such as internal discipline logs or Safe Schools Incident Reporting forms—which contain no fields to distinguish sexual violence from general misconduct.

1.2.11.2 Victims are Unrecognized and Unsupported

Where a harm is unnamed, support systems do not follow. Students who experience dating violence or sexual abuse by peers may not be referred to guidance, social work, or trauma-informed support. Some are disciplined under general behavioural codes or told to “avoid each other” in class or hallways. Others are not believed, particularly where there is no physical evidence or where the behaviour occurred digitally.

For LGBTQ+, racialized, or Indigenous students, disclosure risks are further amplified by documented distrust of authority, fear of retaliation, and low expectations of confidentiality. Students may withdraw from school altogether, avoid reporting, or experience ongoing exposure to perpetrators due to lack of internal transfer options.

1.2.11.3 Lack of Training and Institutional Protocols

Educators, school administrators, and front-line staff are not trained to recognize or intervene in patterns of TF-TDV or TFSV unless their school board has developed policies independently. In the absence of province-wide policy requirements, training is optional, inconsistent, or nonexistent.

Front-line reports gathered through PREVNet, the DIY Digital Safety Project, and teacher associations confirm that many staff do not know how to distinguish a “fight” from coercive relationship violence, how to respond to sextortion, or how to support a student who has discovered a synthetic sexual image of themselves online. In such cases, victims are often told to “stay off that app” or “report to the platform,” while the institutional role is abdicated.

1.2.11.4 Gaps in Intervention and Disciplinary Clarity

Where staff do not recognize the pattern of abuse, or when definitions do not guide policy, perpetrators may go entirely unchallenged. Alternatively, they may be disciplined administratively without recognition of the harm’s criminal dimensions. In other cases—particularly involving image circulation or sextortion—youth may be referred directly to police or charged under child pornography or harassment offences.

This leads to outcomes that are simultaneously under-protective and over-punitive. Youth who have caused serious harm may never be confronted with a behavioural intervention or clinical support. Others may face criminal records for behaviours they did not understand, within relationships they perceived as consensual. The lack of structural clarity leaves both prevention and accountability to chance.

1.2.12 From Screen Time to Structural Risk

Reports of online sexual luring of Canadian children and youth has increased 815% in the last five years, and reports of sextortion have jumped by 150% since June 2022. Ontario’s current education policy does not include a grade-banded framework for student awareness of technology-facilitated violence, digital coercion, or the mechanics of social media manipulation.

1.2.13 School Resource Officers (SROs)

Between 2020 and 2022, several of Ontario’s largest school boards formally ended their SRO programs following concerns raised by Black and Indigenous students, families, and advocacy organizations. The program removals were not based on outcome evaluations of school safety, student well-being, or disclosure trends, and occurred without replacement infrastructure for early intervention.

1.2.14 Localized Policy Development and System Fragmentation

In recent years, the Ontario government has taken meaningful steps to support school-based prevention policy by issuing centralized directives on topics of public concern. In particular, the Ministry of Education’s introduction of Policy/Program Memorandum No. 166 on school board sex trafficking protocols (2021), and the province-wide policy on cellphone and vape use in classrooms (2024), both reflect a commitment to student safety and the Ministry’s willingness to respond directly to the risks facing Ontario youth.

These initiatives demonstrate that Ontario can lead coordinated, province-wide policy development where appropriate. At the same time, outside of these few centrally led examples, Ontario’s overall model continues to rely heavily on local board discretion for the development of policies addressing gender-based violence (GBV), teen dating violence (TDV), technology-facilitated harm, and sexual exploitation. This delegation of responsibility has resulted in considerable variation in both the quality and scope of school-level prevention frameworks.

1.2.14.1 Delegation of Policy Responsibilities Without Structural Support

Where the Ministry has issued policy/program memoranda (PPMs) but not prescribed model policies, school boards are responsible for developing and maintaining their own internal frameworks. PPM 166, for example, requires all boards to establish anti-sex trafficking protocols that include staff training, student identification, and partnership with community organizations. However, the memorandum does not prescribe a specific template or implementation standard, nor does it define uniform criteria for policy review, evaluation, or update cycles.

The result is wide variation across the province. Some school boards have developed robust, detailed anti-trafficking protocols with embedded collaboration, cross-sector referral procedures, and contextual adaptation for local demographics. Others have produced short statements or minimal frameworks that meet the letter of the directive but vary in operational detail. Boards differ in how they define trafficking, identify at-risk youth, address digital recruitment, and engage with trauma-informed approaches.

This variability is not unique to human trafficking policy. It also applies to board-level policies on dating violence, sexual violence, coercive control, and digital safety—areas where no formal definitions currently exist in provincial education law.

1.2.14.2 Structural Redundancy and Missed Opportunities for Efficiency

Allowing more than 70 publicly funded school boards to independently create policies addressing the same categories of harm results in unnecessary duplication of effort. Policy development requires legal review, consultation, and training support, all of which are being replicated across the province. Service providers who work across multiple jurisdictions must navigate different policy frameworks, expectations, and language.

Boards developing prevention-related policies independently often face delays in implementation, resource limitations, and challenges in identifying or adopting evidence-based best practices. Without shared infrastructure—such as model policies, implementation guides, or training templates—many boards are left to construct systems from the ground up. The absence of coordinated policy review mechanisms or standard language further contributes to variability in student protection and staff preparedness.

Centralized policy development—where appropriate—can streamline implementation, reduce administrative costs, and improve quality and consistency across all boards. Shared frameworks still allow for local adaptation, while eliminating redundant development and ensuring province-wide coverage.

1.2.14.3 Uneven Implementation and Equity Gaps

Board-developed prevention frameworks vary not only in content, but also in scope and resourcing. Some boards have adopted dedicated TDV or TFSV prevention modules, while others have no specific programming. Staff training varies by board, as does the use of trauma-informed frameworks, external referral networks, and school-community partnerships.

This variation produces unintended inequities. Students in one board may have access to structured digital safety education, while students in a neighbouring jurisdiction may receive little to no prevention content. Parents may encounter comprehensive protocols in some regions and general policy statements in others. Educators may receive tailored TF-GBV training in one setting but lack basic awareness of digital abuse indicators in another.

Geographic differences in program delivery and policy depth mean that a student’s access to protection, information, and referral pathways is dependent not on their risk, but on their postal code.

1.2.15 Operational Considerations for School-Based Prevention Delivery

1.2.15.1 Board-Level Discretion and Variable Openness

Under Ontario’s current governance model, school boards maintain significant autonomy in determining which prevention programs to adopt, how to allocate instructional time, and which external service providers are permitted to deliver programming. While some boards actively seek out prevention partnerships, others maintain more restrictive policies, particularly in relation to non-instructional content, community-led initiatives, or scheduling capacity.

This discretion means that even when evidence-based programs are made available, access remains contingent on board-level decisions. In practice, this creates uneven implementation, with some boards piloting violence prevention models in multiple schools while others opt not to engage at all. Boards may cite competing instructional priorities, concerns about program alignment with local values, or scheduling limitations. Without centralized policy or funding directives, adoption often depends on the presence of a local champion or service provider with the capacity to navigate school board protocols.

1.2.15.2 Collective Agreement Constraints

Ontario’s education sector operates within a structured collective bargaining framework. Prevention programs that involve delivery by individuals who are not certified teachers may raise concerns about role encroachment, workload expectations, or pedagogical jurisdiction.

This is particularly relevant for programs such as Coaching Boys Into Men (CBIM), which are designed to be delivered by athletic coaches or violence prevention educators—some of whom may not be Ontario Certified Teachers (OCTs). While some boards have adopted CBIM using internal coaching staff, others have expressed uncertainty about whether non-teacher delivery is permissible under local collective agreements or aligns with board policy.

In practice, successful implementation of non-teacher-delivered programming has depended on factors such as explicit support from local school administrators, pre-existing relationships with Violence Against Women (VAW) agencies, clarity about roles, responsibilities, and instructional boundaries, and flexibility in how program time is scheduled (e.g., during lunch hours, advisory periods, or co-curricular blocks).

1.2.15.3 Cost Duplication and Administrative Inefficiency

In practice, Ontario funds multiple versions of similar programming through overlapping grant streams and pilot initiatives. Each project requires individual evaluation, onboarding, oversight, and reporting. Boards and community partners must coordinate delivery models, negotiate school access, and navigate consent and referral protocols—often without cross-provider alignment.

This creates unnecessary cost duplication. It also delays the scaling of already-proven programs by continually reinvesting in short-term evaluation of pilot variations. Rather than embedding successful programming into infrastructure, resources are spent testing delivery in new schools, under slightly different conditions, with limited longitudinal impact.

In contrast, province-wide implementation of a small number of evaluated, curriculum-aligned programs would streamline delivery, reduce administrative burden, and allow for centralized quality control.

1.2.15.4 Programs No Longer in Need of Piloting

Ontario is already home to several violence prevention programs with extensive evaluation histories and demonstrated impact, including:

• The Fourth R: A classroom-based program aligned with Ontario’s Health and Physical Education curriculum, evaluated through randomized controlled trials showing reductions in dating violence and peer aggression.
• Coaching Boys Into Men (CBIM): A coach-delivered program focused on male athletic teams, supported by CDC-backed research and Ontario pilot implementation with broad service provider support.
• SNAP for Schools: An early intervention and self-regulation program for Grades 1–6, backed by decades of longitudinal evidence and implemented in multiple Ontario school boards.

Each of these programs has completed the piloting stage. Each has been evaluated, adapted to Ontario’s education context, and delivered in school settings across the province. Continued piloting of these programs is neither cost-effective nor necessary.

1.2.15.5 Scheduling, Space, and Integration Barriers

Prevention programs that are not explicitly embedded in curriculum may face logistical challenges in securing space within the school day. Schools report high demand on instructional time, limited availability of shared spaces, and challenges accommodating new initiatives within existing timetables. This can limit access for community-based programs, even when board-level approval is granted.

Program fidelity can also be compromised when delivery is fragmented or scheduled sporadically around other priorities. Programs that are designed to be delivered in sequence—such as Fourth R or SNAP for Schools—require consistent access to students over time. Without predictable scheduling and staff support, delivery may be truncated, diluted, or discontinued after initial uptake.

1.2.15.6 Referral Systems and Infrastructure Gaps

Programs addressing IPV, SV, HT, or technology-facilitated abuse often include referral pathways for students who disclose harm or show signs of victimization. However, many schools do not have dedicated staff trained in trauma-informed response or equipped to provide support beyond a basic referral. Guidance counsellors, social workers, and administrators may vary in their availability or training, and service availability differs significantly across urban and rural regions.

The absence of consistent internal infrastructure can discourage program adoption or lead to concerns about follow-up capacity. Some schools may be reluctant to engage with prevention programming if they do not feel prepared to respond effectively to disclosures.

1.2.15.7 Delivery Vulnerabilities in Athletics-Based Programming

Coaching Boys Into Men follows a delivery model that differs meaningfully from classroom-based programming. CBIM is designed to be facilitated by coaches during a sports season, using brief, structured conversations aligned with regular team activities. This relationship-based approach offers a contextually relevant opportunity to engage boys in violence prevention content within spaces they already inhabit.

Because CBIM is embedded in extracurricular athletics rather than curriculum, it is subject to operational factors specific to school sports. These may include coaching staff turnover, reassignment, or differences in availability; competing demands between athletic and academic scheduling; variations in season length, practice frequency, or sport structure; differences in staff comfort or confidence delivering sensitive content; and lack of standardized guidance on when and how program delivery should occur.

These conditions do not limit CBIM’s effectiveness, but they do highlight the importance of supporting implementation through clear planning and alignment with athletic operations. Any broader policy consideration would need to consider the distinctive logistics of school sport delivery models to ensure consistency and sustainability.

1.2.17 Surveying Student Experience – Infrastructure for Oversight and Policy Renewal

Ontario’s current education system lacks a standardized, province-wide mechanism for collecting anonymized, pattern-level data on students’ lived experiences of violence, coercion, and relational risk. While some school boards participate in voluntary or research-driven surveys, there is no common framework, no required reporting structure, and no consistent use of indicators that would allow the Ministry to assess province-wide trends in teen dating violence (TDV), technology-facilitated sexual violence (TFSV), or related harms.

This absence presents a foundational challenge for policy design, implementation oversight, and prevention program evaluation. In a prevention system that seeks to reduce long-term exposure to gender-based violence, coercion, and exploitation, the lack of a provincial data infrastructure constitutes a structural blind spot.

1.2.17.1 Inconsistent Survey Delivery Across Boards

Some school boards in Ontario participate in optional, externally administered surveys related to student well-being. Others develop board-specific surveys, often in partnership with local public health units, postsecondary institutions, or community organizations. These efforts are not coordinated, and participation is inconsistent across regions and school types. No existing model requires that all students across Ontario be asked a common set of questions about TDV or TFSV at consistent intervals. As a result, the system lacks a shared evidence base to guide province-wide prevention efforts.

1.2.17.2 Absence of Common Indicators and Tracking Infrastructure

There is currently no provincial definition of teen dating violence or technology-facilitated sexual violence in education law or policy. Accordingly, there are no common indicators, no shared tracking metrics, and no centralized repository for data related to student experiences with coercive or exploitative behaviour. Unlike academic outcomes or graduation rates, which are monitored systematically, exposure to violence is not tracked in a way that allows for longitudinal assessment or equity monitoring.

1.2.17.3 Policy Design Without Visibility

In the absence of anonymized, experience-level data, Ontario policymakers are required to design prevention strategies based on general literature from other jurisdictions, evaluations conducted in pilot settings or limited samples, and incident reports, which reflect only the most visible and reported harms. This creates a disconnect between the experience of students and the information available to decision-makers. Harms that are normalized, hidden, or underreported—such as sextortion, image-based abuse, and coercive dating dynamics—remain unquantified.

1.3 Recommendations (Education)

Recommendation 1: Amend the Education Act to Define Teen Dating Violence and Technology-Facilitated Abuse

Recommendation: Amend section 1 of the Education Act to include definitions of Teen Dating Violence, Technology-Facilitated Teen Dating Violence, Sexual Violence, and Technology-Facilitated Sexual Violence. These definitions shall be considered distinct from “bullying” and “cyberbullying” as defined in the Act.

Recommendation 2: Mandate Ministry-Authored Policy on TDV, TF-TDV, TF-SV, and SV Prevention and Response

Recommendation: The Ministry of Education shall develop, issue, and mandate a standardized policy governing school-based prevention and response to TDV, TF-TDV, SV, and TF-SV, applying to all publicly funded elementary and secondary schools in Ontario.

Recommendation 3: Define Core Content Requirements for the Ministry’s TDV/TFV/SV School Policy

The Ministry of Education shall ensure that the mandated policy includes core components covering application scope and terminology guidance; disclosure and reporting framework; developmentally appropriate operational guidance; referral and partnership expectations; staff roles and responsibilities; alignment with prevention programs; integration of Erin’s Law obligations; and a review and update cycle.

Recommendation 4: Mandate Province-Wide Delivery of the Fourth R Curriculum in Grades 7–9

Context and Purpose: The Fourth R is an evidence-based, Canadian-developed program designed to prevent dating violence, sexual violence, and related harms through structured, skill-based education. It is currently aligned with Ontario’s Health and Physical Education curriculum but is not mandated or consistently delivered across the province. Allowing individual school boards to determine whether and how to use The Fourth R has resulted in significant variability in student access, teacher training, and overall program quality. To ensure consistency, efficiency, and cost-effectiveness, Ontario should mandate province-wide implementation of The Fourth R for all students in Grades 7, 8, and 9 and establish a standardized framework for delivery and maintenance.

Jurisdiction: The Ministry of Education holds the authority to approve and mandate curriculum-aligned instructional resources across Ontario’s publicly funded education system. The proposed implementation model mirrors existing approaches used for centrally endorsed resources tied to mandatory curriculum strands. Program licensing and delivery oversight fall within provincial jurisdiction, as does the authority to fund and direct teacher training.

Recommendation: The Ministry of Education shall license, fund, and mandate delivery of The Fourth R curriculum across all publicly funded Ontario schools for students in Grades 7, 8, and 9. This implementation shall include:

1. Full integration of The Fourth R curriculum into Health and Physical Education instruction in Grades 7–9, delivered by classroom teachers.
2. Distribution of electronic curriculum materials and training modules to all Grade 7–9 health teachers and all Faculties of Education across Ontario.
3. Faculties of Education should incorporate The Fourth R into teacher preparation programs for those intending to teach Health and Physical Education in Grades 7–9.
4. The Ministry of Education should provide provincial funding for a minimum of five years, including:
   • Initial province-wide licensing and resource distribution
   • Online and in-person training modules for educators
   • Ongoing technical and pedagogical support
5. Co-development of a standardized delivery and implementation policy in consultation with the program originators (Western University Centre for School Mental Health) and relevant education and prevention experts.
6. Francophone, Indigenous, and alternative education adaptations of The Fourth R shall be made available to support culturally responsive implementation, provided they maintain core program fidelity.
7. A review and renewal process every 4–5 years, ensuring that instructional materials remain evidence-aligned and that delivery models are periodically evaluated.

The program shall be treated as a Ministry-mandated curriculum supplement. School boards shall not substitute locally developed alternatives for any component of The Fourth R.

Implementation Considerations:

• Licensing and training must be structured to accommodate new teachers, long-term occasional staff, and turnover in the teaching population.
• Professional development timelines and Ministry communications must ensure that teachers are provided with protected time to review and prepare program materials.
• The Ministry may wish to clarify the use of proprietary programming within the broader context of curriculum implementation policy.
• Implementation must be staged to align with school-year planning cycles and educator availability.

Rationale: Standardizing the delivery of The Fourth R is the most efficient and cost-effective way to ensure that all Ontario students receive high-quality, evidence-based prevention education during a critical window of adolescent development. The program aligns directly with Ontario’s Health and Physical Education curriculum and has been extensively evaluated for impact on reducing dating violence, improving student skills, and promoting safer school climates. Mandating province-wide delivery eliminates inconsistency, enables centralized training and resource support, and ensures that teachers are not expected to create or vet prevention materials independently. The Fourth R offers a scalable, tested solution that can be implemented without altering curriculum structure or requiring new instructional time.

Recommendation 5: Mandate School-Based Delivery of Coaching Boys Into Men in Grades 7–12 Athletics

Recommendation: The Ministry of Education shall mandate delivery of Coaching Boys Into Men (CBIM), or its recognized Ontario equivalent (e.g., CLEAR), to eligible school sports teams across all publicly funded schools in Grades 7–12.

Recommendation 6: Mandate Province-Wide Delivery of SNAP for Schools in Elementary Grades

Recommendation: The Ministry of Education shall mandate province-wide delivery of SNAP for Schools in elementary settings (Grades 1–6).

Recommendation 7: Amend the Education Act to Authorize Ministerial Designation of Provincial Priority Programs

Recommendation: Amend section 8(1) of the Education Act to authorize the Minister to designate specific instructional programs or models as provincial priority programs and require all boards to implement such programs.

Recommendation 8: Develop and Distribute Standardized Parent Communication Materials for All Mandated Prevention Programs

Context: As Ontario moves to implement province-wide violence prevention programs and policies across the education system, consistent and accessible parent communication will be essential to promote understanding, prevent misinformation, and support successful rollout.

Jurisdiction: Ministry of Education.

Recommendation: The Ministry of Education shall develop and disseminate standardized, province-wide parent education and communication materials related to The Fourth R curriculum (Grades 7–9), Coaching Boys Into Men (CBIM) delivery through school athletics (Grades 7–12), SNAP for Schools implementation in elementary settings (Grades 1–6), and the Ministry-authored policy on TDV, SV, TF-TDV, and TFSV. These communication materials should include a province-wide letter from the Minister of Education; short, plain-language summaries of each initiative; a centralized, Ministry-hosted webpage; guidance for boards on hosting optional information sessions; parent-facing materials co-developed with youth advisors, educators, and trauma-informed practitioners; communications carefully framed to avoid misinterpretation; and internal-facing briefing materials for school administrators and staff.

Implementation Considerations: Materials must be provided in both English and French. Messaging must remain neutral, factual, and aligned with the Ministry’s violence prevention and student safety objectives. Parent materials should be developed well in advance of implementation deadlines.

Rationale: Clear, centralized parent communication is a critical component of successful implementation for any province-wide education initiative. Without consistent messaging, prevention programs may face unnecessary public resistance or misunderstanding. Centrally developed materials reduce the burden on boards and schools, ensure alignment with policy intent, and promote trust in the broader prevention strategy.

Recommendation 9: Align Prevention Program Rollout with Established School-Year Planning Cycles

Context: School-based prevention initiatives are most effective when implemented in a timely, structured, and coordinated manner. Launching programs mid-year or on short timelines can increase confusion, strain staff capacity, and reduce delivery fidelity.

Jurisdiction: Ministry of Education.

Recommendation: That, in the event the Ministry of Education proceeds with the implementation of provincially mandated prevention programs or policies—such as The Fourth R, CBIM, SNAP for Schools, or the TDV/TFV/SV school policy—the Ministry should coordinate rollout timing with major school-year planning milestones (September or January), ensure that all required elements are prepared in advance of rollout, and provide school boards with sufficient lead time to integrate the programs into professional development days and classroom operations.

Implementation Considerations: Different boards may require flexibility based on size, capacity, and staffing. Training and communications should be finalized early enough to avoid summer bottlenecks or last-minute implementation pressure.

Rationale: Aligning implementation with natural planning cycles helps prevent late-stage confusion, ensures consistent delivery, and supports system readiness.

Recommendation 10: Strengthen Ontario’s School Nutrition Program and Position It for Federal Integration

Context: School nutrition programs are not traditionally classified as violence prevention, but food insecurity is a documented risk factor for exposure to IPV, SV, and HT. Ontario’s Student Nutrition Program (SNP) serves over 600,000 students annually through a decentralized, community-led model.

Jurisdiction: Ministry of Children, Community and Social Services (MCCSS); Ministry of Education.

Recommendation: That the Ministry of Education, in collaboration with MCCSS, modernize the Student Nutrition Program through a two-phase strategy. Phase 1 (Infrastructure and Delivery Modernization): conduct a province-wide review of current SNP operations, develop a centralized procurement and distribution strategy, establish a standardized provincial program framework, and clarify governance roles across ministries. Phase 2 (Strategic Investment and Federal Integration): develop a long-term provincial investment and delivery plan, engage with the federal government to align Ontario’s system with the National School Food Program, and demonstrate delivery readiness to position Ontario as a primary delivery partner for federal school food funding.

Implementation Considerations: Community delivery partners may require technical or administrative support. Initial modernization may expose infrastructure gaps requiring long-term capital planning. The model should preserve universal access and avoid stigmatizing delivery frameworks.

Rationale: A modern, efficient, and scalable school nutrition program is essential to supporting student well-being and reducing vulnerability. Strengthening infrastructure and centralizing coordination will enable more consistent delivery, reduce inefficiencies, and position the province to receive and scale federal investment.

Recommendation 11: Rebuild a Provincial Framework for School–Police Partnerships to Support Student Safety and Violence Prevention

Context: Since 2020, several large school boards have ended their formal SRO programs. However, in the absence of any structured replacement, many schools now lack consistent access to community policing support, creating unevenness across the province.

Jurisdiction: Ministry of Education; Ministry of the Solicitor General.

Recommendation: The Ministry of Education and the Ministry of the Solicitor General shall jointly develop a provincial framework to guide school–police partnerships across all publicly funded school boards. This framework shall affirm that school–police collaboration is a structural component of Ontario’s student safety infrastructure; allow for local flexibility in how partnerships are implemented; clearly define the intended role of school-assigned officers emphasizing trust-building, prevention education, and non-enforcement-based support; set expectations for the selection and qualifications of officers assigned to school partnership roles; require each school board and local police service to complete a standardized school–police partnership protocol; provide province-wide implementation guidance; and acknowledge that school boards shall not bear the cost of police staffing.

Implementation Considerations: Boards and police services may need support to rebuild partnerships after program termination. Smaller or rural communities may require resource sharing or provincial assistance. Equity and inclusion concerns must be addressed directly.

Rationale: Student safety, violence prevention, and early intervention depend on strong inter-agency partnerships. This recommendation supports the development of a new provincial framework that recognizes the value of positive police–school relationships while setting clear boundaries, expectations, and safeguards.

Recommendation 12: Establish a Standardized Student Survey to Track Teen Dating Violence and Technology-Facilitated Violence in Ontario Schools

Context: Ontario lacks a consistent, province-wide mechanism for collecting data on student experiences of TDV, TF-TDV, SV, and TFSV. Without this data, the province cannot reliably track prevalence, evaluate prevention programs, or respond to emerging patterns of harm.

Jurisdiction: Ministry of Education.

Recommendation: Amend the Education Act, RSO 1990, c E.2, to add to s. 8(1) a provision requiring boards to participate in the administration of surveys to collect data respecting student experience of TDV, SV, and technology-facilitated violence; and to add to s. 11(1) regulation-making authority respecting the development, content, frequency, administration, and reporting of such surveys. The survey instrument shall be administered annually to students in fixed developmental grades (e.g., Grade 7 and Grade 10), collect data on all four forms of violence, use anonymous aggregate-only reporting, be supported by parent opt-out provisions and trauma-informed delivery guidance, and produce publicly available summary data.

Implementation Considerations: Survey questions must be carefully designed to avoid distress. Boards will require operational guidance and scheduling support. The Ministry should consider a centralized administration model similar to how EQAO assessments are coordinated. Provincial privacy standards must be observed.

Rationale: Ontario’s current lack of standardized data on student experience of TDV, TF-TDV, SV, and TFSV leaves a significant gap in prevention strategy evaluation, risk identification, and policy development. A recurring, grade-based survey structure offers a low-cost, high-value mechanism for understanding trends, assessing program impact, and directing resources where needed.

Recommendation 13: Develop and Field Test a Social Media Literacy and Digital Harms Prevention Module for Ontario Schools

Context: Ontario students are exposed to technology-facilitated violence, coercive control, sextortion, deepfake abuse, and algorithmically reinforced peer harm through social media platforms. Ontario currently provides no structured, grade-banded, school-based education on these risks.

Jurisdiction: Ministry of Education.

Recommendation: The Ministry of Education shall develop and field test a grade-banded, school-based social media literacy module that addresses digital coercion, surveillance, and jealousy; sextortion and image-based abuse; platform manipulation, deepfakes, and consent violations; and safety planning, help-seeking, and reporting options. The module shall be structured for developmental appropriateness with differentiated content for Grades 4–6, 7–9, and 10–12; designed for regular revision with annual content updates; accompanied by parent-facing materials; and field tested across diverse boards including at least one large urban board and one rural or remote board.

Implementation Considerations: The content will require central coordination and scheduled updates. Boards may raise concerns regarding teacher workload. The purpose of the field test is to assess delivery and system feasibility—not to determine whether the program is needed.

Rationale: Technology-facilitated abuse increasingly results in student mental health crises, school discipline escalation, guidance referrals, and police involvement. A prevention-aligned social media literacy program enables early intervention and reduces the burden on crisis response systems. Existing violence prevention programs do not address platform-specific harms, algorithmic manipulation, or synthetic sexual content.

Recommendation 14: Include the Ministry of Education in Justice Sector Planning and Coordination Frameworks

Context: Ontario’s public education system plays a foundational role in youth violence prevention, early risk identification, and structured support for children and adolescents exposed to harm. While public safety initiatives increasingly emphasize early intervention, the Ministry of Education is not routinely included in inter-ministerial planning frameworks for justice system modernization.

Jurisdiction: No statutory barrier exists to the inclusion of the Ministry of Education in multi-ministerial justice system strategies.

Recommendation: That the Ministry of Education be formally included in all relevant justice sector planning frameworks where school-based prevention, youth risk factors, or student safety are material considerations. This includes multi-year strategic planning processes involving the Ministry of the Solicitor General, Ministry of the Attorney General, and MCCSS; cross-ministerial initiatives aimed at addressing youth violence, sexual exploitation, or early justice involvement; and system modernization efforts that seek to improve coordination between prevention, enforcement, adjudication, and reintegration functions.

Implementation Considerations: No change to the Ministry of Education’s mandate is proposed; participation would occur through existing inter-ministerial planning and policy coordination mechanisms. Inclusion should focus on upstream prevention and risk mitigation, not operational policing or enforcement.

Rationale: Children and adolescents affected by violence, exploitation, or abuse are most likely to be identified in school settings—often before they come into contact with police, courts, or child protection. Schools also serve as primary sites for preventive intervention and structured programming. Aligning education-sector planning with justice sector modernization ensures that prevention efforts are integrated, risk factors are addressed earlier, and system-level resources are deployed more effectively.

1.4 Addendum: Implementation Limitations in Ontario’s Dual School System — Structural Observations on Catholic Curriculum Delivery

1.4.1 Constitutional and Historical Origins of Ontario’s Catholic School Boards

1.4.1.1 Pre-Confederation Origins: Religious School Rights in British North America

The existence of publicly funded Catholic school boards in Ontario is the result of legal arrangements dating to the pre-Confederation period. In the mid-nineteenth century, the colonial administration of Upper Canada (now Ontario) operated a system of “common schools,” which, though non-denominational in name, reflected a broadly Protestant orientation in practice. Curriculum materials included readings from the King James Bible and religious moral instruction aligned with Anglican and Methodist teachings. Roman Catholic communities, largely composed of Irish immigrants and descendants of French settlers, expressed concern about the incompatibility of this educational model with Catholic teachings. In response to sustained political advocacy, the Separate School Act of 1855 was enacted by the Parliament of Canada West, granting Roman Catholic electors the legal right to establish publicly funded separate schools with their own governance structures.¹⁶⁶ These rights were formalized and extended under the Separate Schools Act, 1863, which remained in force at the time of Confederation.¹⁶⁷

In Lower Canada (now Quebec), where Catholics were the majority, an analogous structure was established for Protestant minorities. The Education Act of Lower Canada (1861) provided legal recognition of “dissentient schools,” allowing Protestant communities to operate publicly funded schools distinct from the Catholic-majority system.¹⁶⁸

This reciprocal accommodation—Catholic schools in Ontario, Protestant schools in Quebec—formed part of the Confederation compromise and became the foundation of Section 93 of the Constitution Act, 1867.

1.4.1.2 Constitutional Entrenchment: Section 93 of the Constitution Act, 1867

Section 93 of the Constitution Act, 1867 delegates legislative authority over education to the provinces while preserving pre-existing denominational school rights. The text of Section 93(1) reads:

“In and for each Province the Legislature may exclusively make Laws in relation to Education, subject and according to the following Provisions: (1) Nothing in any such Law shall prejudicially affect any Right or Privilege with respect to Denominational Schools which any Class of Persons have by Law in the Province at the Union.”¹⁶⁹

This clause protects only those rights and privileges that were legally in place in each province as of 1867. In Ontario, this means the rights of Roman Catholic separate school electors; in Quebec, it historically referred to Protestant dissentient schools. Other provinces are unaffected unless their school systems contained denominational guarantees at the time they joined Confederation.

The scope of the provision is both jurisdiction-specific and time-frozen. Rights must be (1) legally recognized by provincial law at the time of Union and (2) held by a defined “class of persons.” The courts have interpreted this to mean that the provision protects only those denominational rights already enjoyed under legislation in force at Confederation.¹⁷⁰

1.4.1.3 Judicial Interpretation and Charter Immunity

Section 93 operates as a constitutionally entrenched exception to the general application of the Canadian Charter of Rights and Freedoms. The Supreme Court of Canada has affirmed that denominational rights protected under Section 93 are not subject to Charter challenge. In Reference re Bill 30, An Act to Amend the Education Act (Ont.) (1987), the Court held that the extension of full public funding to Catholic high schools—despite unequal treatment of other religious or secular schools—was constitutionally valid and immune from scrutiny under the equality rights provisions of the Charter.¹⁷¹

Chief Justice Dickson, writing for a unanimous Court, described Section 93 as “a comprehensive code” and stated:

“Section 93 is not subject to the Charter. The denominational school rights protected thereby are immune from Charter challenge. The Charter cannot be used to invalidate or limit these rights.”¹⁷²

This remains the leading authority on the matter. Subsequent jurisprudence has upheld the principle that if a right or privilege was held at Confederation and falls within the scope of Section 93, it is constitutionally insulated from judicial review under the Charter.

1.4.1.4 Preservation of Religious Character

The scope of Section 93 includes not only funding but also the preservation of the denominational character of the schools themselves. Catholic boards retain the right to frame curriculum, policies, and staffing expectations in alignment with Catholic doctrine, provided such practices are consistent with what existed in law at the time of Union. The courts have upheld the right of Catholic school boards to require employees to act in accordance with Catholic values and to maintain curriculum and disciplinary frameworks that reflect Church teachings.

Under Canada’s amending formula, any effort to repeal or alter Section 93’s application in Ontario would require a formal constitutional amendment under Section 43 of the Constitution Act, 1982. This type of amendment applies to provisions affecting one or more, but not all, provinces. It requires the passage of a resolution by the Legislative Assembly of Ontario and the House of Commons and Senate of Canada. Unlike some other constitutional amendments, it does not require consent from other provinces.¹⁷³

1.4.1.5 The Quebec Exception: Repeal of Section 93 Protections in 1997

In contrast to Ontario, the province of Quebec no longer maintains a denominationally structured education system. In 1997, Quebec requested a formal constitutional amendment to remove the application of Section 93 in its jurisdiction. The amendment, enacted under Section 43 of the Constitution Act, 1982, resulted in the addition of Section 93A to the Constitution Act, 1867, which reads:

“Paragraphs (1) to (4) of section 93 do not apply to Quebec.”¹⁷⁴

This amendment was initiated by a unanimous resolution of the Quebec National Assembly on April 15, 1997, and was adopted by the federal Parliament through resolutions passed by the House of Commons and the Senate in October 1997. The amendment process under Section 43 requires the consent of the provincial legislature and both houses of Parliament but does not necessitate the approval of other provinces.¹⁷⁵

Following the amendment, Quebec passed legislation reorganizing its public education system along linguistic rather than denominational lines. Catholic and Protestant school boards were dissolved and replaced by French-language and English-language boards. The change took effect on July 1, 1998.

The repeal was motivated by a shift in public sentiment following the Quiet Revolution of the 1960s, during which Quebec underwent a rapid process of secularization. By the 1990s, the denominational structure was widely viewed as inconsistent with both demographic realities and the province’s commitment to laïcité.¹⁷⁶ The constitutional amendment provided the necessary mechanism to reorganize Quebec’s education system without contravening Section 93. No similar amendment has been proposed in Ontario.

1.4.1.6 Variations Across Other Provinces

While Ontario maintains constitutionally protected Catholic separate schools, the situation varies across other provinces:

• Alberta and Saskatchewan: Upon joining Confederation in 1905, both provinces included provisions similar to Section 93 in their respective founding acts, thereby protecting denominational school rights.¹⁷⁷
• Manitoba: Initially provided for denominational schools upon joining Confederation in 1870. However, the Manitoba Schools Act of 1890 abolished public funding for Catholic schools, leading to significant legal and political disputes. The issue was eventually resolved through political compromise rather than constitutional amendment.
• Other Provinces: Provinces such as British Columbia, New Brunswick, Nova Scotia, and Prince Edward Island did not have legislated denominational school rights at the time of their entry into Confederation and thus are not subject to Section 93 protections.¹⁷⁸

1.4.2 Statutory and Operational Structure Under Ontario’s Education Act

1.4.2.1 Catholic School Boards Under the Education Act

Ontario’s Catholic school boards are governed by the Education Act, R.S.O. 1990, c. E.2, which implements the constitutional protections of Section 93 of the Constitution Act, 1867. The Act defines Catholic boards as “separate school boards” and affords them distinct governance rights. Under Section 58.5, separate boards are authorized to administer publicly funded Roman Catholic schools and to levy education taxes from Catholic ratepayers. They are empowered to elect trustees, control hiring preferences for Catholic staff, and deliver curriculum consistent with Catholic values.¹⁷⁹

Section 264 of the Act outlines teachers’ duties. Section 264(1)(c) requires educators to “inculcate by precept and example respect for religion and the principles of Judaeo-Christian morality,” and Section 264(1)(m) obliges them to cooperate with other staff to maintain order and discipline.¹⁸⁰ In Catholic boards, these duties are interpreted to include fidelity to Catholic doctrine, particularly in courses involving religion, sexuality, and family life.

1.4.2.2 The Institute for Catholic Education (ICE)

The Institute for Catholic Education (ICE) was established in 1986 by the Ontario Conference of Catholic Bishops (OCCB) in response to the extension of full public funding to Catholic high schools through Bill 30. ICE was created to ensure that all curriculum delivered in Catholic schools adhered to Catholic doctrine and ecclesiastical authority.¹⁸¹

ICE is not a statutory entity and does not receive direct provincial funding. Its operations are supported financially through contributions from the Assembly of Catholic Bishops of Ontario and cost-sharing by member organizations, including the Ontario Catholic School Trustees’ Association (OCSTA), the Ontario English Catholic Teachers’ Association (OECTA), and other affiliated bodies. Per ICE documents, the Catholic school boards have also contributed financially.¹⁸²

ICE’s board includes representatives from:

• Assembly of Catholic Bishops of Ontario (ACBO)
• Ontario Catholic School Trustees’ Association (OCSTA)
• Ontario English Catholic Teachers’ Association (OECTA)
• Ontario Catholic Supervisory Officers’ Association (OCSOA)
• Catholic Principals’ Council of Ontario (CPCO)
• Ontario Association of Parents in Catholic Education (OAPCE)
• Ontario Catholic School Business Officials’ Association (OCSBOA)

1.4.2.3 Curriculum Adaptation “Through a Denominational Lens”

Catholic schools in Ontario are required to deliver the provincial curriculum but may do so “through a denominational lens.” While this phrase is not defined in statute, ICE and Catholic board documentation consistently refer to curriculum being taught “through the lens of faith.” This denotes the practice of aligning curriculum delivery with Catholic doctrine as interpreted by the Bishops of Ontario and facilitated through ICE-approved materials and teacher guidance.¹⁸³

ICE states:

“While curriculum across all subject areas is adapted so that it can be taught through the lens of faith, some subject areas, such as Religious Education and Family Life Education, deal more directly with the teachings of the Catholic Church.”¹⁸⁴

In practice, this allows for adaptations to how topics such as consent, sexuality, gender identity, and same-sex relationships are taught. For example, while Ministry curriculum emphasizes legal consent, Catholic curriculum situates consent within a broader moral theology. ICE resources explain that family life education in Catholic schools is “an opportunity… to talk to students about a distinctively Catholic view of human life, sexuality, marriage and family.”¹⁸⁵ In ICE materials, sexual consent is framed within a moral context that emphasizes chastity and the sanctity of marriage. For example, students are taught that “sexual intimacy is intended only for marriage” and that choices around sexual activity should be made in light of a “Christian understanding of authentic human growth in relationship and community.”¹⁸⁶

Catholic curriculum documents present sexual activity outside marriage as inconsistent with Catholic moral teaching. Abstinence is framed not only as a protective behavior, but as a positive moral choice grounded in dignity and respect for human sexuality. Instructional guidance emphasizes chastity as a virtue, and resources discourage presenting all student choices as morally equivalent. While human dignity is emphasized for all students, discussions of gender identity and sexual orientation are framed within the theological anthropology of the Church. The curriculum emphasizes care and respect for all persons, while maintaining doctrinal consistency with Catholic teaching on sexuality.¹⁸⁷

1.4.2.4 Limits to Litigation of the Denominational Lens

To date, the concept of teaching “through a denominational lens” has not been the subject of litigation in Ontario courts. No constitutional challenge has succeeded in contesting the way Catholic boards deliver curriculum in accordance with ICE guidance.

This legal insulation is due to the doctrine articulated in Reference re Bill 30 (1987), in which the Supreme Court of Canada held that Section 93 rights are immune from Charter scrutiny. Chief Justice Dickson wrote:

“Section 93 is not subject to the Charter. The denominational school rights protected thereby are immune from Charter challenge. The Charter cannot be used to invalidate or limit these rights.”¹⁸⁸

Therefore, unless Ontario seeks and receives a constitutional amendment under Section 43 of the Constitution Act, 1982, Catholic boards retain the right to modify curriculum content as long as they meet provincial learning expectations in form, even if the delivery diverges in substance.

1.4.2.5 The Magisterium: Doctrinal Framework for Curriculum

All Catholic curriculum adaptation in Ontario is governed by the teachings of the Magisterium—the official teaching authority of the Roman Catholic Church. The Magisterium includes:

• The Ordinary Magisterium (ongoing teachings by the Pope and bishops),
• The Extraordinary Magisterium (infallible teachings declared ex cathedra).

ICE curriculum resources consistently reference the Magisterium as the doctrinal foundation for instruction on topics such as sexuality, gender, and relationships. Religious Education materials emphasize that students should develop an “intelligent articulation of their faith” and demonstrate understanding of “the Church’s creeds, doctrinal statements, and the authoritative teachings of the Magisterium.” These teachings are applied to moral formation and classroom instruction through curriculum developed in alignment with Catholic anthropology and theology. Materials do not affirm sexual activity outside of marriage or self-defined gender identity. Instead, sexuality and identity are presented through the framework of complementarity and vocation.¹⁸⁹

This approach applies even where Ministry documents mandate the inclusion of sexual diversity and gender identity. In ICE-adapted resources, these topics are addressed in ways that emphasize:

• The dignity of each individual;
• The distinction between personhood and conduct;
• The non-affirmation of sexual or gender identities inconsistent with Church doctrine.

ICE explains that these adaptations are essential to delivering the curriculum in “a manner consistent with the beliefs and practices of the Catholic faith.”¹⁹⁰

1.4.3 Structural Observations Relevant to Violence Prevention Programming

The Ontario Health and Physical Education (HPE) curriculum includes mandated prevention content related to IPV, SV, TDV, and TFSV. This material is most frequently situated in Grades 7–12 and delivered through units focused on healthy relationships, personal safety, consent, and digital risk awareness.

In Ontario’s publicly funded Catholic schools, this content is delivered through adaptations developed by the Institute for Catholic Education (ICE). These adaptations reflect Catholic moral teaching and are guided by the doctrinal authority of the Magisterium. The resulting curriculum overlays are designed to integrate Ministry expectations with Catholic theology, particularly in areas involving human dignity, moral development, sexuality, and personal conduct.

The adaptations are substantive rather than cosmetic. Key examples from ICE curriculum documents demonstrate how prevention-related topics are reframed:

1. On abstinence: “The message to young people is that abstinence is not just a way of avoiding negative consequences—it is a value that protects the dignity of the person and the sacredness of human sexuality.”¹⁹¹
2. On consent: “While consent is a legal requirement, Catholic schools present sexual intimacy as morally appropriate only within the context of marriage.”¹⁹²
3. On sexting: “The sharing of sexual images or messages (sexting) is presented as a serious risk to both personal integrity and future reputation.”¹⁹³
4. On pornography: “Pornography is not only degrading to human dignity, it distorts the meaning of sexuality and undermines the virtue of chastity.”¹⁹⁴
5. On student disclosure: “If a student discloses sexual experience, the teacher should respond respectfully and without judgment, while gently affirming the Church’s teaching on chastity and the dignity of the person.”¹⁹⁵

These teachings are presented within the broader moral framework of Catholic anthropology. Instruction is oriented toward the development of virtue, formation of conscience, and cultivation of relationships grounded in covenantal love and marital fidelity. While respect, care, and the prevention of harm are emphasized, the framing of topics is distinctly theological.

Evidence-based prevention programs such as The Fourth R adopt a contrasting approach. These models are designed using principles of public health, social equity, and harm reduction. They encourage open discussion of power dynamics, dating norms, digital consent, and gender-based violence across a spectrum of relationships and identities. Program design is typically grounded in adolescent development research, trauma-informed pedagogy, and inclusivity standards aligned with secular education policy.

The structural distinctions between these models are evident in the following areas:

The result is not a refusal to teach prevention content, but a recontextualization of that content in alignment with Catholic doctrine. As ICE explains in its policy framework, these adaptations are designed to deliver provincial expectations “in a manner consistent with the beliefs and practices of the Catholic faith.”¹⁹⁶

This reframing may influence how students interpret or engage with prevention content—particularly where that content addresses identity, technology-facilitated conduct, or interpersonal boundaries in contexts that do not reflect Catholic moral teaching. In some cases, materials that affirm sexual diversity, normalize adolescent sexual autonomy, or promote inclusive representations of gender may not be implementable within the existing ICE curriculum overlays. Similarly, students may encounter barriers to disclosure if classroom framing implies that certain behaviors are not only risky but morally disordered.

No statutory or judicial authority currently permits the provincial government to require Catholic boards to deliver unmodified curriculum content that contradicts doctrine protected under Section 93 of the Constitution Act, 1867. Catholic boards retain full constitutional discretion to determine how prevention-related content is framed and delivered, so long as Ministry expectations are addressed in form.

1.4.4 Summative Observational Note

Ontario’s 29 English-language Catholic school boards educate over 575,000 students in more than 1,500 schools. An additional 76,500 students are served by eight French-language Catholic boards. Collectively, these systems account for more than 30% of Ontario’s publicly funded student population.¹⁹⁷ As outlined in this section, the delivery of Ministry-mandated curriculum content within denominational boards is subject to doctrinal alignment requirements. While these structures are constitutionally established and outside the scope of this report’s recommendations, they may give rise to implementation variability in prevention programming, particularly in relation to content concerning relationships, sexuality, digital conduct, and identity. These dynamics may warrant consideration by the Government of Ontario and other relevant policy authorities as part of any future planning for equitable and consistent delivery of school-based safeguarding and IPV/SV/HT prevention initiatives.

Section 2: SNAP, Triple P, and Kids Help Phone

2.1 Stop Now And Plan (SNAP): Scalable Early Intervention Infrastructure

SNAP is a structured, multi-component intervention designed to address early externalizing behavior problems in children who are at risk for escalation into more severe forms of antisocial behavior. The program was developed for compatibility with Canadian criminal, education, and child protection systems. It remains one of the only evidence-based early intervention frameworks that was both originated and scaled within Ontario.

SNAP consistently demonstrates a 78.1% reduction in conduct disorder diagnosis rates. For every dollar spent on SNAP over a three- to six-month treatment period, there is an estimated saving of four dollars per year. The cost of one year of SNAP intervention is equivalent to approximately three days in a secure youth custody facility. Province-wide delivery of SNAP to 20,000 high-risk children annually would be expected to prevent roughly 2,000 juvenile reoffences per year.

Plain-Language Summary: Assuming a 30% diversion rate sustained over ten years, a $135 million annual investment in SNAP implementation would be expected to result in approximately $85.65 billion in public net savings over the following 20 years, corresponding to approximately 105,000 avoided criminal charges.

2.1.8 “Tyler’s Troubled Life”—A Costed Case Model of System Failure

Tyler’s Troubled Life is a cost-modelling prototype developed by Public Safety Canada to illustrate the cumulative public expenditure associated with untreated high-risk youth trajectories.²²² The model presents a fictional but representative case, using detailed cost data from Canadian, American, and Australian sources to quantify the financial impact of repeated multi-system involvement over the life course. The report includes over 100 discrete cost inputs spanning health care, child welfare, education, policing, courts, and corrections.

Tyler’s risk profile is visible from birth. He is born to a teenage mother with no educational attainment, and by age two has already been exposed to family violence, parental criminality, unstable housing, and social services involvement. By age three, he has been removed from licensed daycare due to aggression and placed with a neighbour for supervision. By five, he has entered the foster care system following a substantiated injury sustained while in the care of his father.

Between the ages of six and ten, Tyler cycles through three more foster homes, is diagnosed with ADHD, placed in special education, and begins refusing psychiatric treatment. He accumulates suspensions and is repeatedly involved in schoolyard aggression.

By age twelve, Tyler begins interacting with the police and is formally charged with property offences. He is sentenced to community supervision and probation, fails to comply, and is returned to court. As he enters adolescence, he becomes truant, drops out of school, and is sentenced to secure custody following multiple assaults. By age 18, Tyler is charged with drug trafficking and later convicted of aggravated assault against a domestic partner during a pregnancy-related dispute.

Between the ages of 18 and 30, Tyler spends a total of ten years in correctional custody. His cumulative public cost—including policing, court attendance, social assistance, education loss, health care, and incarceration—totals $1,403,476 in 2015 dollars, or approximately $1.7 million in 2025 dollars.²²³

Within the model, three interventions are costed as possible points of diversion. One of these is SNAP, modelled as a behavioural intervention applied at age 10, with cost avoidance beginning at age 11. The projected system cost savings attributed to SNAP—based solely on reduced system involvement from age 11 onward—are estimated at $1.2 million per child in 2015 CAD, or $1.45 million in 2025 CAD, accumulated over the course of approximately 20 years, up to age 30.²²⁴ Costs incurred before age 11 are not included in the projected savings.

Tyler’s case does not involve mass violence, firearms, or homicide. His offences include assault, theft under $5,000, break-and-enter, and drug trafficking. These are not extraordinary offences, nor do they represent extraordinary circumstances. Tyler reflects a known, high-cost, high-visibility profile: a male child exposed early to family violence, struggling with early aggression, diagnosed with ADHD, removed from home, placed in special education, and eventually drawn into the criminal system.

His trajectory includes documented, repeatable warning signs seen in schools, CAS records, ER visits, and police contact logs across Ontario. Tyler is not exceptional—he is the archetypical “lost boy,” the child that fell between the cracks, the default outcome of unaddressed, early-stage behavioural risk. The costing model underscores that long-term public expenditures begin accumulating before school entry and continue into adulthood, often across generations.

2.1.9 SNAP Cost Avoidance Modelling—Time-Bounded Scenarios Based on the Tyler Trajectory

Tyler’s Troubled Life is a cost-modelling prototype developed by Public Safety Canada to quantify the cumulative public expenditure associated with an untreated high-risk youth trajectory.²²⁵ The model spans from early childhood through age 30 and includes detailed public system costs drawn from child welfare, education, health care, policing, courts, and corrections.

The SNAP program was tested in this model as an early behavioural intervention applied at age 10, with projected cost avoidance beginning at age 11.²²⁶ In the Tyler costing model, its per-child delivery cost was estimated at $6,700 (2015). Its projected cost avoidance—based solely on reduced system contact—was over $1.2 million (2015) or $1.45 million (2025) accumulated over a 20-year period. This figure includes only costs incurred from age 11 onward and excludes all expenditures already accrued prior to program delivery.²²⁷

To project population-level impact, this analysis models the delivery of SNAP to 200,000 high-risk children over a 10-year implementation period (20,000 annually). For each child served, public cost avoidance is tracked beginning at age 11 and projected over a 20-year horizon—consistent with the Tyler model, which estimates cumulative savings per participant from age 11 through 30. For example, a child receiving SNAP in 2026 would begin generating cost avoidance from age 11 onward, continuing through 2046. A child served in 2034 would generate savings through 2054. These are long-term fiscal impacts that accumulate across cohorts over time. All per-child costs and avoided costs are adjusted to 2025 CAD.

To assess the fiscal implications of SNAP at scale, two diversion scenarios are presented: a deliberately conservative 5% diversion rate, representing 10,000 of 200,000 children served, and a 30% diversion rate in keeping with demonstrated outcomes, corresponding to 60,000 successful diversions.²²⁸

For each diversion scenario, projected cost avoidance is calculated using Tyler’s post-intervention cost estimates across three cumulative time horizons: 10 years (age 11–20), 15 years (age 11–25), and 20 years (age 11–30). Savings are measured per child, then scaled to match the size of the diverted cohort. The per-child avoided cost is based on line-item estimates from the Tyler model and includes direct expenditures only—such as justice involvement, court appearances, corrections, child welfare, special education, and emergency health care.²²⁹ To reflect current Ontario implementation costing, a per-child delivery cost of $6,700 (2025 CAD) is subtracted from the total avoided cost to calculate net public savings. The resulting figures reflect what Ontario would save, even after accounting for the full cost of delivering SNAP to all 200,000 high-risk children.

2.1.10 Outcome-Based Diversion Estimate

Outcome data from peer-reviewed studies and program evaluations suggest that the actual diversion rate achieved by SNAP may substantially exceed 5%. One multi-site study found that 68.5% of SNAP participants no longer met the clinical threshold for externalizing behaviour problems at program discharge, with gains sustained at 12-month follow-up.²³⁰ An Ontario youth justice evaluation reported a 38% reduction in reoffending among probation-involved SNAP participants compared to matched controls.²³¹ Randomized controlled trials have shown that SNAP produces the strongest effects in children with the most severe behavioural profiles, who are most likely to follow high-cost trajectories without intervention.²³²

Using a midpoint estimate of 30% diversion, grounded in the outcome literature, the projected cost avoidance would exceed $86 billion over a 20-year horizon.²³³ The cost of delivering SNAP to a cohort of 200,000 children over ten years is approximately $1.35 billion, using CDI’s current bundled per-child delivery cost of $6,750, regardless of outcome variation.²³⁴ In this model, the majority of participating children—those not diverted from chronic offending—still receive full program services, but the overall savings remain substantial due to the high per-child cost of inaction.

This cost-neutral delivery baseline makes even modest rates of high-risk trajectory avoidance fiscally significant. The value proposition of SNAP lies not in universal prevention of offending, but in producing reliable reductions in risk indicators and in diverting even a fraction of participants away from chronic, system-heavy outcomes.

2.1.11 Projected Avoided Costs by Time Horizon

To support fiscal planning understanding, projected avoided costs are also presented by time horizon. These estimates are based on Tyler’s post-intervention cost model, assuming an even distribution of avoided costs over 20 years.

At a 5% diversion rate (10,000 children):

• 10-Year Avoided Cost (Age 11–20): $7.25 billion
• 15-Year Avoided Cost (Age 11–25): $10.88 billion
• 20-Year Avoided Cost (Age 11–30): $14.5 billion
• Net savings (after $1.35B program cost):
  • 10 years: $5.90 billion
  • 15 years: $9.53 billion
  • 20 years: $13.15 billion

At a 30% diversion rate (60,000 children):

• 10-Year Avoided Cost (Age 11–20): $43.5 billion
• 15-Year Avoided Cost (Age 11–25): $65.3 billion
• 20-Year Avoided Cost (Age 11–30): $87.0 billion
• Net savings (after $1.35B program cost):
  • 10 years: $42.15 billion
  • 15 years: $63.90 billion
  • 20 years: $85.65 billion

2.1.12 Estimated Justice System Impact

Based on the Tyler model’s adult offending trajectory, each untreated high-risk youth is estimated to incur an average of 1.75 adult criminal charges between ages 18 and 30.²³⁵ Under a 5% diversion scenario, this corresponds to 17,500 avoided charges, with approximately 10,500 of these charges occurring within the first 10 years post-intervention.²³⁶

2.2 Triple P: A Scalable, Evidence-Based Parenting Intervention

The Positive Parenting Program (Triple P) is a multi-tiered, evidence-based public health intervention. A landmark U.S. RCT found that counties implementing the full Triple P system experienced 13% fewer hospitalizations for abuse injuries, 31% fewer substantiated cases of child maltreatment, and 21% fewer out-of-home placements.

2.3 Referral Infrastructure and Access Pathways: Cross-Program Considerations

The SNAP and Triple P programs are both designed for early intervention and treatment with high-risk children, youth and families, but neither program currently operates within a standardized provincial referral system. Access to both programs is generally limited to specific service regions, and program entry typically depends on local practitioner awareness, informal partnerships, or voluntary parent engagement. While both SNAP and Triple P are well-established within their respective fields, public visibility and professional uptake remain inconsistent across Ontario.

SNAP referrals are most common through youth justice, school boards, and child welfare services. Some police services and Crown offices also refer to SNAP as a condition of diversion or bail. However, these pathways are not provincially mandated, and access may vary depending on the availability of local affiliate sites.²⁶¹ While CDI provides implementation infrastructure through its SNAPiT system—including intake protocols, fidelity monitoring, and outcome tracking—there is currently no centralized referral intake or province-wide service directory. Participation often depends on local school awareness or the discretion of front-line workers within police or CAS settings.

Triple P referrals are similarly fragmented. In Ontario, delivery is offered by a mix of public health units, school-based mental health teams, and family service agencies, but there is no centralized referral platform or standardized intake mechanism.²⁶² In many cases, access depends on whether a provider organization has opted into offering Triple P and whether front-line practitioners are aware of its availability. Families may self-refer through public seminars, be offered brief interventions by clinicians, or be connected through informal outreach by schools, parenting support groups, or social workers.

For both programs, this structure limits both reach and equity. Families may qualify for services but never be referred. Conversely, some practitioners may be trained but underutilized due to lack of visibility or cross-sector coordination. As a result, access is often opportunistic rather than intentional, and uptake may vary substantially between neighbouring jurisdictions.

Early intervention programs such as Triple P and SNAP are most effective when delivered as part of a coordinated system of care, with consistent referral points, clear service eligibility, and cross-sector professional awareness. In the absence of standardized referral infrastructure—including shared intake, program directories, and public communication strategies—system navigation remains a barrier to access. This limits the ability to scale evidence-based prevention programming across the province.

2.4 Kids Help Phone

Kids Help Phone (KHP) is Canada’s largest 24/7 digital mental health service for youth, offering confidential counselling, crisis support, and resource navigation by phone, SMS text, and web-based platforms. Services are delivered by trained professional counsellors and volunteer responders, and are available in English, French, and offers translation services for many other languages.²⁶³

KHP is free, anonymous, and does not require a referral, health card, or identification to access. These features—particularly 24/7 availability, anonymity, and digital accessibility—are consistently identified by youth as critical enablers of help-seeking. Research has shown that youth experiencing abuse, suicidal thoughts, or mental health distress are more likely to reach out to anonymous digital services than to in-person providers, especially when stigma, safety concerns, or mistrust of formal systems are present.²⁶⁴

In 2022, the service recorded over 1.2 million interactions across Canada, including phone calls, text conversations, and online chats—more than 430,000 of which originated in Ontario.²⁶⁵ In early 2024, KHP reported that 57% of all one-on-one counselling interactions nationally came from Ontario, despite the province representing only ~39% of Canada’s youth population.

KHP is frequently accessed by youth experiencing intimate partner violence (IPV), coercive control, family abuse, or exploitation. In its 2024 submission to the Standing Committee on Justice Policy, KHP reported that 73% of all one-on-one counselling interactions related to IPV, coercive control, or family abuse originated from Ontario.²⁶⁷ These disclosures are most commonly made through text-based support platforms, which are often preferred by youth in controlling or monitored households.

KHP has estimated that $3 million in annual funding would be required to maintain current service levels for Ontario youth, based on current provincial usage volumes.²⁷⁰ This estimate is not associated with program expansion, but reflects operating costs already being absorbed by the national platform in response to demand from Ontario users.

2.5 Recommendations (SNAP, Triple P, Kids Help Phone)

Recommendation 1: Fully fund province-wide implementation of SNAP Clinical for a minimum 5-year period (~$135 million/year).

Recommendation 2: Require standardized data reporting for all SNAP delivery sites.

Recommendation 3: Fully fund province-wide delivery of Triple P for a minimum 5-year period.

Recommendation 4: Require standardized implementation and outcome data from all Triple P delivery partners.

Recommendation 5: Provide annualized base funding for Kids Help Phone.

Section 3: Early Childhood Education and Child Care

3.1 Introduction: Strategic System Investment

Throughout the Committee’s proceedings, multiple presenters emphasized that child care access is not ancillary to violence prevention efforts but rather a core structural determinant of women’s ability to exit or avoid abusive situations. Witnesses consistently identified the availability of affordable, high-quality early childhood care as a precondition for financial independence, workforce participation, educational advancement, and service access.

3.1.2 Economic Dependency and the Infrastructure of Entrapment

Childcare access emerged repeatedly in committee testimony as a prerequisite for financial independence among women experiencing or at risk of intimate partner violence. Victims unable to secure childcare may be unable to attend addiction recovery programming, access transitional housing, or comply with family court conditions. The Jean Tweed Centre remains the only women’s addiction treatment facility in Ontario with on-site licensed childcare.

3.1.3 Quality Matters

International research demonstrates that the developmental benefits of early childhood education accrue most reliably in high-quality programs. Programs such as Perry Preschool and the Abecedarian Project illustrate the impact of intensive, high-quality early intervention. Economic evaluations of the Perry Preschool Project estimate a 7 to 13 percent annual return on investment per participant.

3.1.5 Structural Constraints and Systemic Gaps

As of 2025, the Financial Accountability Office projects that over 227,000 new spaces would be required to meet potential take-up under the current CWELCC framework, leaving a projected gap of over 140,000 spaces. More than 16,000 additional registered early childhood educators (RECEs) would be needed by 2026–27.

3.2 Recommendations (Early Childhood Education)

Recommendation 1: Develop a Provincial Costing and Structural Design Model for Tiered Early Childhood Education Delivery

Context and Purpose: Ontario currently lacks a technical framework for estimating the cost, delivery requirements, and long-term public value of early childhood education programs differentiated by service format and intensity. While the Canada-Wide Early Learning and Child Care (CWELCC) initiative has increased access and affordability, it does not provide a basis for evaluating the cost-effectiveness of more structured or intensive early learning environments—such as those modeled on the Perry Preschool Project—or for determining how such models might be adapted to Ontario’s current workforce, regulatory, and geographic conditions.

To support future decision-making, Ontario requires a structured, Treasury Board–aligned framework that clarifies what types of program delivery exist, what they cost to operate in various settings, and what long-term system value they may generate.

Jurisdiction: Ministry of Education (lead); Ministry of Finance; Treasury Board.

Recommendation: The Government of Ontario should commission the development of a provincial costing and structural design model for early childhood education, capable of:

• Defining multiple delivery formats based on observable service characteristics, such as hours of operation, staff-to-child ratios, educator qualifications, use of curriculum frameworks, and availability of additional family supports;
• Estimating the full cost of delivering each format across provider types and regions, with adjustments for urban, rural, and remote service contexts;
• Projecting long-term public value and return on investment (ROI) associated with more structured and intensive delivery models, using existing research and Ontario-specific assumptions;
• Establishing a credible, costed foundation for future pilot design, system planning, and intergovernmental negotiation.

For modeling purposes, the framework may distinguish between delivery formats that vary by structural intensity—for example:

• Foundational models, which offer part- or full-day licensed care focused on safety, supervision, and basic developmental exposure;
• Instructional models, which include trained educators, curriculum-informed programming, and group-based learning goals; and
• Enhanced models, which incorporate lower child-to-staff ratios, dedicated planning time for educators, family engagement supports, and structured developmental targets.

These terms are illustrative only and may be refined during the design process to reflect provider diversity and regulatory requirements.

Implementation Considerations: Key implementation challenges include the availability of standardized cost data across provider types, particularly in mixed-model environments that blend education and care functions. Rural and remote service delivery may require separate modeling assumptions to account for staffing shortages, transportation constraints, and capital infrastructure needs. Additional complexity may arise from the lack of publicly available wage benchmarks and the variability in non-salary operating costs across regions. Sector engagement may be required to ensure accuracy and to avoid unintended framing that could devalue existing programs. Language used to describe delivery tiers must be politically neutral and avoid evaluative labels.

Rationale: The narrative identifies a persistent gap between what Ontario funds through CWELCC and what research identifies as high-return early learning environments. While some programs operate with intensive instructional design, many provide custodial care with limited developmental structure. The lack of a standardized framework to define, cost, or compare program types limits Ontario’s capacity to plan strategically or negotiate effectively with federal partners. Modeling multiple delivery tiers—without applying evaluative labels—enables a fiscally responsible approach to identifying which investments deliver the greatest long-term impact, including for violence prevention, labour market participation, and public system cost avoidance.

Recommendation 2: Pilot a Structured Early Learning Program Based on Modernized Perry Design Principles

Context and Purpose: While the Perry Preschool Project remains one of the most rigorously evaluated early learning interventions in North America, its original structure—developed in 1960s Michigan—relied on staffing, home visiting, and delivery practices that are unlikely to be appropriate or acceptable in a contemporary Ontario context. However, the project’s long-term impacts on education, employment, and justice system contact continue to inform policy discussions on the value of early intervention, particularly in structurally disadvantaged communities.

To test how a high-structure early learning model might function in Ontario today, and to identify both the cost and operational complexity of delivering such a program, a time-limited pilot is required. The goal is not to replicate Perry, but to adapt its core principles—low child-to-educator ratios, structured pedagogy, and sustained developmental focus—within a modern regulatory and cultural environment.

Jurisdiction: Ministry of Education (lead); with evaluation support from the Ministry of Finance or Ministry of Economic Development, Job Creation and Trade.

Recommendation: The Government of Ontario should fund and evaluate a structured early learning pilot that adapts key design principles from the Perry Preschool model for the Ontario context. The pilot should:

• Be implemented in multiple sites that reflect geographic and demographic diversity, including communities facing structural disadvantage as defined by regional income, service access, or historical underinvestment;
• Use the delivery formats and cost assumptions developed under Recommendation 1 to ensure alignment with fiscal modeling;
• Exclude historical Perry elements that are not appropriate for modern delivery, such as teacher-led home visiting, and instead integrate with existing Ontario-based supports (e.g., SNAP and Triple P) where available;
• Include a formal evaluation component to track short- and medium-term outcomes for children and families, as well as staffing feasibility, intake processes, and site-level implementation challenges.

Implementation Considerations: Delivery may be constrained by educator availability, facility limitations, and parent engagement barriers, particularly in rural or lower-density regions. Political sensitivity around pilot site selection should be anticipated and managed through transparent, equity-informed intake and outreach processes. Intake mechanisms such as geographic lottery or community nomination may help avoid stigmatization while still reaching high-return populations. Pilot evaluation timelines must be long enough to capture developmental effects but short enough to inform near-term planning decisions.

Rationale: While modeling is essential, it cannot substitute for real-world delivery testing. A carefully designed pilot will allow Ontario to observe how structured early learning programs function under current workforce, facility, and cultural conditions. Evidence from the Perry Preschool Project shows that children facing early structural disadvantage often receive the greatest long-term benefit from intensive early learning. Adapting this logic to Ontario requires implementation-specific insight into program design, cost containment, equitable access, and outcome measurement. Initial pilot implementation should focus on high-return settings not as a permanent limitation, but as a pragmatic starting point. While all children may benefit from enriched early learning, the strongest developmental and economic returns are most consistently observed in communities experiencing socio-economic adversity. Prioritizing those settings enables the province to maximize public value from a limited investment and build a credible, costed foundation for future expansion, without pre-committing to universal delivery or scale.

Recommendation 3: Encourage Regional Hubs to Monitor Child Care Access as a Structural Barrier to Victim Stability

Context and Purpose: Committee testimony identified the absence of accessible child care as a recurring barrier to service uptake, recovery, and long-term stability among victims of intimate partner violence, sexual violence, and human trafficking. Victims who are unable to secure care may be forced to delay entry into addiction treatment, withdraw from workforce re-entry programs, or lose housing or custody supports due to non-compliance with program requirements. These gaps contribute to avoidable system cycling and undermine the effectiveness of publicly funded interventions.

While OIVPRN hubs²⁹⁵ are not responsible for delivering or funding child care, they are well positioned to observe where access barriers routinely interfere with service connection or program completion. Enabling hubs to track these trends informally may support future cross-sector planning, partnership development, or funding design.

Jurisdiction: Ministry of Children, Community and Social Services (MCCSS); OIVPRN governance.

Recommendation: The Government of Ontario should encourage OIVPRN regional hubs to:

• Liaise with local municipal governments and licensed, non-profit child care operators to maintain general awareness of regional care availability and service constraints;
• Track and document recurring references to child care access as a barrier to treatment, court compliance, or service engagement;
• Incorporate these observations into regional planning and funding discussions where relevant.

Implementation Considerations: This recommendation does not create new reporting requirements or operational mandates. It is intended to support informal data gathering and trend awareness only. Hubs should not be expected to maintain waitlists or conduct formal mapping exercises, but may benefit from basic coordination with municipal or nonprofit partners to identify shared infrastructure challenges. Where appropriate, hubs may use this information to support future regional funding proposals or local planning discussions.

Rationale: Child care access was repeatedly cited by service providers as a practical determinant of whether victims were able to engage with supports, complete recovery programs, or maintain court compliance. These barriers are not limited to early childhood education or affordability—they also include geographic availability, scheduling conflicts, and waitlist length. Allowing hubs to maintain a basic level of situational awareness supports more informed regional planning and ensures that cross-system access constraints are considered in violence prevention infrastructure. By approaching this role informally and through existing relationships, hubs can support more effective local coordination without adding administrative burden.

Recommendation 4: Continue to Seek Full Federal CWELCC Funding While Exploring Interim Stabilization Options

Context and Purpose: Ontario’s implementation efforts have focused on maintaining access and preserving sector continuity within the constraints of the federal agreement. However, the persistence of a federally created funding gap may require the province to consider short-term mitigation options to stabilize service access and avoid permanent erosion of capacity while intergovernmental solutions are pursued.

Jurisdiction: Ministry of Education; Ministry of Intergovernmental Affairs; Ministry of Finance; Treasury Board.

Recommendation: The Government of Ontario should continue to actively engage with the federal government to address the structural funding gap under CWELCC, and concurrently assess short-term provincial options that may help stabilize access while longer-term negotiations proceed. These options may include targeted, time-limited mitigation strategies in regions where service risk is high, and cross-ministerial review of existing funding levers (e.g., workforce or infrastructure support programs) that could be temporarily aligned to offset delivery gaps.

Implementation Considerations: Any short-term provincial measures should be clearly framed as interim stabilization tools, not permanent commitments. Language should reinforce that Ontario’s role is to safeguard access while federal mechanisms are recalibrated. Care should be taken to avoid public framing that implies Ontario is assuming long-term financial responsibility for gaps created by national program design.

Rationale: The CWELCC framework, as currently structured, does not provide sufficient federal funding to maintain Ontario’s pre-implementation system capacity. Even with full federal compliance, these shortfalls create measurable risk of service contraction. Ontario’s short-term stabilization measures—framed as fiscally responsible and time-limited—may be necessary to avoid access degradation and system strain, while maintaining a clear negotiating position with federal counterparts.

Recommendation 5: Integrate Economic Development and Labour Analysis into Ontario’s Child Care Strategy

Context and Purpose: Child care access is a critical enabler of labour market participation, skilled trades retention, and foreign direct investment. As Ontario competes globally for investment and talent, particularly in high-growth sectors such as advanced manufacturing and clean technology, the availability of reliable child care infrastructure increasingly influences workforce planning, site selection, and employment decisions—especially among women and early-career workers.

Despite these impacts, child care planning in Ontario is largely housed within the education sector and has not been systematically integrated into economic development, labour forecasting, or workforce retention strategies.

Jurisdiction: Ministry of Education, Ministry of Economic Development, Job Creation and Trade; Ministry of Labour, Immigration, Training and Skills Development; Ministry of Finance.

Recommendation: The Government of Ontario should formally direct the Ministry of Economic Development, Job Creation and Trade and the Ministry of Labour, Immigration, Training and Skills Development to work in coordination with the Ministry of Education to support integrated economic and workforce planning related to child care. Areas of collaboration should include developing economic impact projections related to child care availability, identifying child care infrastructure as a strategic factor in investment attraction, assessing how child care access influences worker retention, and supporting cross-ministerial alignment on data sharing and fiscal modelling.

Implementation Considerations: The Ministry of Education retains lead responsibility for policy, funding, and delivery of early childhood education. The intent is to supplement that work with economic and labour forecasting expertise—not to shift operational control.

Rationale: The economic value of child care has been clearly established through workforce participation, long-term earnings, and reduced reliance on social programs. By integrating economic development and labour analysis into the child care strategy, the province can ensure that infrastructure planning reflects both fiscal and social returns and can more effectively align system expansion with job creation, skills development, and investment attraction priorities.

Section 4: Sports

4.1 Background: Violence and Abuse in Sport

4.1.1 Abuse Is Present Across All Levels of Sport

4.1.1.1 Abuse in Youth, School, and Recreational Sport

Sexual, physical, and psychological abuse occurs across all levels of sport, but a substantial proportion of both reported and unreported harm originates in youth, school, and recreational settings. These environments are often structured around community participation, parental trust, and volunteerism. As such, they are frequently less equipped with dedicated oversight mechanisms, standardized screening practices, or independent complaint pathways.

A 2022 national study conducted by the Canadian Centre for Child Protection (C3P) documented 290 school personnel in Canada who were criminally charged or professionally disciplined for sexual offences against students between 2017 and 2021. Seventy-four percent of those individuals also held roles as coaches. Offences occurred in both classroom and extracurricular contexts, and 42% of the cases involved grooming via Snapchat or Instagram.²⁹⁶ A separate C3P report from 2018 found similar dynamics, emphasizing that the pattern of access granted to coaches—through both school sport and club systems—creates a persistent structural risk.²⁹⁷

An international study conducted a prevalence study of 4,000 athletes in Belgium and the Netherlands, finding that 38% had experienced psychological violence, 17% physical violence, and 14% sexual violence in their sport environment. Coaches were the most frequently reported perpetrators.²⁹⁸ Although this study was conducted outside Canada, its findings reinforce the structural vulnerability present in youth sport, where informal hierarchies and performance pressure may obscure early indicators of harm.

In Ontario, the 2024 Coaching Report released by the Coaches Association of Ontario surveyed over 1,000 active coaches and found that 40% were aware of hazing among youth athletes, and 60% had experienced hazing themselves as athletes.²⁹⁹ While most respondents affirmed a commitment to respectful and inclusive sport, the report identified a gap between coaching values and observed behaviour in team environments.

An investigative series published by CBC in 2019 identified over 200 coaches in Canada who had been convicted of sex offences against minors between 1998 and 2018, involving more than 600 victims. Ontario had the highest number of recorded convictions.³⁰⁰ These cases spanned multiple sports and included both school-affiliated and club contexts. In many cases, the accused maintained access to athletes over extended periods, and many incidents were disclosed only years later.

Canadian Women & Sport’s 2020 She Belongs report found that the top predictor of sustained participation among girls in sport was not performance but a sense of belonging. Conversely, early dropout was linked to experiences of social exclusion, unsupportive team culture, and lack of meaningful adult support.³⁰¹

Analysis across multiple studies and reports indicates that certain recurring structural features consistently elevate risk in youth, school, and recreational sport settings:

• Diffuse accountability between school boards, sport clubs, and municipalities;
• Informal or discretionary screening practices;
• Lack of formal education for coaches on grooming, boundary violations, and trauma-informed communication;
• Inconsistent visibility of reporting pathways for athletes and families;
• Cultural valorization of “team loyalty” or “coach authority.”

4.1.1.2 Abuse in Amateur, Collegiate, and Community Settings

Amateur, collegiate, and community sport environments exist across a wide spectrum of formality—from organized leagues affiliated with post-secondary institutions to unaffiliated adult leagues and club teams. These settings are often outside the jurisdiction of school boards or national sport organizations, and oversight structures vary widely by location, funding model, and organizational maturity.

While post-secondary institutions in Ontario have developed campus-level sexual violence policies, those policies often apply only to incidents that occur within the university’s administrative purview. Student athletes competing under third-party governance structures—such as intercollegiate or extramural leagues—may fall outside formal reporting pathways unless the institution has taken additional steps to clarify policy jurisdiction.

4.1.1.3 Abuse in High-Performance and National Team Environments

High-performance and national team sport environments differ significantly from youth, community, and collegiate settings in their structure, culture, and pressure dynamics. Athletes operating at this level often train in centralized environments, live away from home, and compete under contracts or carding agreements that create dependencies not typically present in lower levels of sport. These dynamics may elevate the likelihood of coercion, silence, or complicity when harm occurs.

A 2021 prevalence study conducted by Willson, Kerr, and Stirling documented high rates of maltreatment among Canadian national team athletes. The study found that psychological harm was the most common form of abuse, followed by physical and sexual harm. Female athletes reported significantly more incidents than their male counterparts, particularly in relation to body policing (e.g., monitoring of weight or appearance), training restrictions tied to perceived femininity or discipline, and relational boundary violations such as inappropriate comments, unreciprocated physical contact, or emotional dependence with coaches or staff.³⁰⁶

Parliamentary investigations conducted by the House of Commons Standing Committee on the Status of Women (FEWO) and the Standing Committee on Canadian Heritage (CHPC) reinforced these findings. Witnesses described systemic failures to prevent abuse, protect complainants, or establish trauma-informed complaint systems at the national sport level.³⁰⁷ FEWO’s 2023 report, Time to Listen to Survivors, emphasized the role of centralized training centres in fostering dependence and suppressing disclosure.³⁰⁸ CHPC’s 2024 report, Safe Sport in Canada, drew attention to the use of non-disclosure agreements, funding pressure on athletes, and perceived bias in complaint response pathways.³⁰⁹

High-profile national news stories, such as the 2022 Hockey Canada case involving the use of registration fees to quietly settle sexual assault claims, prompted public scrutiny of governance structures within high-performance sport.³¹⁰ There is concern that processes to address concerns exist in system as “duplicitous by design,” due to collusion between funding bodies, performance expectations, and discretionary complaint suppression.

While many coaches, administrators, and sport leaders act with integrity, the architecture of high-performance sport continues to produce elevated risk when it fails to separate performance oversight from participant protection. Oversight mechanisms tied directly to funding, selection, or carding may create real or perceived conflicts of interest. In several testimonies heard by FEWO and CHPC, athletes described fear of deselection or lost sponsorship as barriers to reporting abuse.

4.1.2 Peer Abuse, Hazing, and Normalized Harm

4.1.2.1 Hazing, Humiliation, and Peer-Based Sexual Violence

Peer-based abuse in sport—including hazing, coercion, and sexual violence—has been identified as a significant form of harm across multiple levels of organized sport. While institutional abuse by coaches and administrators has been more prominently documented, research and investigative reports consistently show that athletes may also be harmed by teammates or peers, particularly in settings where peer cohesion is tightly linked to identity, status, or advancement.

Vertommen et al.’s international prevalence study found that sexual and physical violence in sport often occurred between peers rather than from coaches or staff.³¹¹ Among the 4,000 athletes surveyed, peer-initiated sexual hazing and coercion were reported in both youth and amateur competitive settings.

In Ontario, the 2024 Ontario Coaching Report found that 40% of surveyed coaches were aware of hazing occurring among athletes under their supervision. Sixty percent had experienced hazing themselves during their own time as athletes.³¹² While most respondents disapproved of hazing in principle, it was often framed as an informal “rite of passage” or team-building exercise.

Federal committee investigations have confirmed the presence and impact of peer abuse, particularly in junior-level and male-dominated sports. The 2023 Time to Listen to Survivors report by the Standing Committee on the Status of Women (FEWO) includes testimony from athletes who were pressured by teammates to participate in degrading, sexualized rituals.³¹³ The 2024 Safe Sport in Canada report by the Standing Committee on Canadian Heritage (CHPC) documents cases of forced nudity, alcohol abuse, and coerced sexual acts within team settings.³¹⁴ In both reports, athletes linked these experiences to longer-term trauma, withdrawal from sport, or normalization of harm.

In one high-profile Ontario case, multiple students at St. Michael’s College School in Toronto were criminally charged in relation to a hazing incident that involved the sexual assault of a teammate with a broomstick.³¹⁵ The case received national attention and prompted public discussion about the limits of school oversight and the cultural framing of hazing as tradition.

The Canadian Centre for Child Protection has also documented the role of digital tools in peer harm. In its 2022 study on abuse by K–12 school personnel, the Centre noted that coercion and harassment sometimes originated among peers within athletics programs, particularly through private group chats and social media platforms.³¹⁶

4.1.2.2 Team Culture and “Rites of Passage”

Team culture plays a central role in shaping athlete behaviour, especially in environments where group cohesion is strongly emphasized. Hazing and informal rites of passage are often presented as longstanding team traditions. Although such practices are frequently described as harmless bonding exercises, they have been linked in the literature to reinforcement of power hierarchies, exclusion, and normalization of violence.

A 2017 report by Raliance explicitly calls out hazing as a vector for the socialization of violence-supportive norms.³¹⁷ It situates team rituals as an opportunity for early intervention—where culture-setting can either reinforce or interrupt pathways toward abusive behaviour. The report links rites of passage to IPV and SV normalization when those rituals emphasize humiliation, obedience, or sexual bravado.

A 2023 report by Fogel and Quinlan examined Canadian university sport and concluded that team bonding practices often blurred the line between camaraderie and coercion.³¹⁸ In some instances, players described ritualized initiation as both formative and distressing—leaving lasting impacts even when no formal complaints were filed. The researchers argued that framing abusive practices as team tradition acts as a barrier to cultural change.

CBC reporting on the St. Michael’s College School incident also reinforced how the language of “tradition” has been used to shield violent rites from scrutiny.³¹⁹ Although this case involved criminal charges, similar practices often continue informally in environments lacking external oversight.

4.1.2.3 Normalization of Harm, Loyalty, and Silence

The normalization of harm in sport is often reinforced not only through repeated exposure, but through cultural narratives that frame violence, coercion, or silence as expected features of athletic participation. Athletes across sport levels report that abuse—whether peer-based or institutional—is routinely minimized or reinterpreted as discipline, bonding, or mental toughness. These dynamics contribute to a culture in which individuals who experience or witness harm may feel discouraged from reporting or intervening. Hazing, verbal abuse, or even sexual harassment were reframed as tradition or “just part of sport.”

White Ribbon have similarly called for examination of the role of masculine norms in reinforcing silence.³²⁰ In sport settings, toughness, emotional restraint, and loyalty to male peer groups were described as more socially rewarded than speaking out against harm. The report warned that unless the structure and language of team bonding is deliberately examined, silence will remain an implicit expectation.

In its 2023 report, the Standing Committee on the Status of Women (FEWO) included testimony from multiple athletes who were explicitly told not to “make it a big deal,” or who feared being dropped from teams for disclosing abuse.³²¹ Silence was often framed as a form of team loyalty, and reporting was equated with weakness or betrayal. Environments where SV jokes, dismissive language, or gender-policing are tolerated without correction contribute to the cumulative effect of normalized harm that shapes how athletes perceive their options.

4.1.3 Grooming, Silence, and Institutional Blind Spots

4.1.3.1 Grooming Behaviours and Boundary Transgressions

Grooming refers to a pattern of deliberate behaviours used by individuals in positions of power to build trust, gain access, and gradually desensitize victims to boundary violations or future abuse. In the context of sport, grooming can occur in both institutional and peer relationships, but most often involves adults—particularly coaches—who exploit role-based authority and structural proximity to young athletes.

The Universal Code of Conduct to Prevent and Address Maltreatment in Sport (UCCMS) defines grooming as any deliberate conduct by an individual to facilitate future sexual maltreatment or reduce the likelihood of disclosure or detection. This includes behaviours such as isolating an athlete, establishing preferential treatment, engaging in excessive or secret communication, or gradually violating physical or emotional boundaries.³²²

Studies by the Canadian Centre for Child Protection (C3P) note that grooming often occurred online in parallel to in-person interactions and points out that teachers frequently held dual roles, increasing their access to students and extending contact beyond the classroom or training environment.³²³

Testimony submitted to the Standing Committee on the Status of Women (FEWO) echoed these findings. Athletes described grooming patterns that began with emotional support and escalated into surveillance, training control, or restrictions on family contact.³²⁴ Grooming was not always recognized as a threat by the athlete at the time, particularly when it was framed as mentorship, motivation, or specialized attention.

Sport environment assessments commissioned through the now-defunct Office of the Sport Integrity Commissioner (OSIC) similarly identified normalization of boundary violations as an early-stage grooming concern. For example, the 2023 Gymnastics Canada assessment reported instances where “preferential treatment” involved exclusive, non-transparent relationships between coaches and athletes, including private travel and unsupervised social activities outside the training environment.³²⁵ The Volleyball Canada assessment cited “emotional dependency” patterns arising from excessive late-night texting, private mentorship relationships, and blurred professional boundaries.³²⁶ The Hockey Canada assessment documented a culture where “special treatment” manifested in unequal enforcement of team rules, privileged access to scouts and events, and informal favoritism within team structures.³²⁷

4.1.3.2 Silence and Retaliation: Cultural and Structural Barriers

Athletes and coaches who experience or witness harm in sport environments frequently report barriers to disclosure, including fear of retaliation, social exclusion, or reputational damage. These barriers are rarely the product of a single policy or actor but rather reflect broader structural dynamics that discourage transparency. Cultural norms around loyalty, toughness, and discretion often intersect with opaque or discretionary reporting systems to produce silence.

The 2023 report Time to Listen to Survivors from the Standing Committee on the Status of Women documented multiple examples of athletes who were discouraged from reporting misconduct.³²⁸ Witnesses described experiences where disclosing harm was equated with disloyalty to the team, or where athletes were warned—formally or informally—that disclosure could jeopardize selection, funding, or team cohesion.

The 2024 Safe Sport in Canada report by the Standing Committee on Canadian Heritage similarly identified retaliation as a significant structural risk.³²⁹ Athletes reported being ostracized, defamed, or silently deselected after raising concerns. In some cases, teammates who supported victims also experienced exclusion. The report emphasized that even the perception of retaliation can have a chilling effect on disclosure.

The Canadian Safe Sport Think Tank described retaliation not only as an interpersonal risk, but as an organizational pattern.³³⁰ Survivors and advocates recounted how entire systems—teams, national sport organizations, or support staff—closed ranks to protect reputations. Complaint suppression occurred through legal mechanisms (e.g., NDAs), through omission (e.g., not publishing sanctions), or through relational control (e.g., isolation or coaching reassignment). Moreover, it is important to note that reporting is often impeded not only by formal consequences but by informal culture. When locker room language includes rape jokes, homophobic slurs, or gendered policing, athletes who experience or witness abuse may be less likely to view disclosure as a viable or safe option.

4.1.3.3 Conflicts of Interest and the Self-Protective Nature of Sport Systems

Organizational responses to athlete complaints often reflect an underlying structural tension between safeguarding mandates and brand protection. In many sport systems, the individuals or bodies tasked with investigating or responding to harm are also responsible for team performance, coach recruitment, or reputation management. These overlapping roles can create perceived or actual conflicts of interest, undermining trust in the integrity of complaint systems. This leaves open opportunities for organizations to prioritize risk containment over resolution.

A legal review conducted by Mazzucco and Findlay in 2024 found significant variation in how the Universal Code of Conduct to Prevent and Address Maltreatment in Sport (UCCMS) is applied across jurisdictions.³³¹ In some cases, sport organizations publicly claimed to follow the UCCMS while maintaining internal policies that allowed discretionary handling of allegations. The review emphasized that without legally binding enforcement, self-regulation creates incentives to minimize disclosure.

Parliamentary reports from both the Standing Committee on Canadian Heritage (CHPC) and the Standing Committee on the Status of Women (FEWO) raised concerns about the credibility of complaint handling.³³² Witnesses described complaint processes that were selectively activated, delayed, or circumvented by organizational leadership. In some cases, coaches accused of serious misconduct were permitted to resign quietly, without notification to athletes or downstream institutions.

Survivor testimony presented in The Current’s 2019 investigative segment confirmed this dynamic.³³³ Interviewees described how local clubs responded to complaints by advising silence, shifting coaches to other roles, or discouraging athletes from pursuing external redress. These patterns were not limited to elite sport but extended to community and school-based programs.

CBC reporting in 2023 on Hockey Canada also reinforced these concerns.³³⁴ The organization was found to have used registration fees to settle sexual assault claims privately, without disclosure to the public or changes to internal policy. Subsequent testimony revealed that key leadership was aware of the allegations but declined to take independent action until compelled by media attention and political pressure.

4.1.4 Linkages Between Early Harm and Later Violence

4.1.4.1 Developmental Pathways from Peer Harm to IPV and SV Perpetration

Peer-based harm in sport—including sexual harassment, hazing, coercion, and psychological aggression—has been associated with a range of long-term behavioural outcomes. These include elevated risk of perpetrating future violence, particularly in the form of teen dating violence (TDV), intimate partner violence (IPV), or sexual violence (SV). While the mechanisms vary, evidence from longitudinal and population-based studies suggests that early exposure to coercive peer environments can shape how individuals manage power, conflict, and emotional regulation later in life.

A longitudinal study examined how peer sexual victimization during early adolescence influenced future aggression.³³⁵ Youth who had been targeted by peers were more likely to engage in both relational aggression (e.g., exclusion, manipulation) and physical aggression in later years. The study emphasized that experiences of harm in sport and school settings could disrupt typical developmental trajectories, fostering externalizing behaviours as coping mechanisms.

The cumulative exposure to coercive and boundary-violating environments aligns with research on the developmental impacts of early harmful experiences. While not confined to sport-specific risks, broader meta-analytic research confirms that exposure to coercive environments during formative years is associated with elevated risk of later violent and antisocial behaviour. Although much of the meta-analysis focuses on intergenerational transmission between parents and children, the findings reinforce that persistent exposure to coercive norms—whether from parents, coaches, or peer environments—can disrupt social development, emotional regulation, and non-violent conflict management.

4.1.4.2 Rape-Supportive Norms and Masculine Socialization

Certain norms related to masculinity, hierarchy, and sexuality have been identified in the literature as increasing risk for harmful behaviours when reinforced through sport culture. These include beliefs that downplay consent, normalize sexual conquest as a measure of social status, or suggest that expressions of dominance are essential to athletic or personal success. These beliefs are sometimes referred to as “rape-supportive norms”—a term used in academic and prevention contexts to describe social attitudes that minimize the seriousness of sexual violence, shift blame onto victims, or excuse harmful behaviour as misunderstanding or miscommunication.

Studies examining adolescent and collegiate sport settings have found that participation in high-contact, male-dominated sports can be associated with stronger endorsement of these norms, particularly when team culture emphasizes aggression, control, or loyalty above accountability.³³⁶ These patterns are not attributed to individual athletes, but to the reinforcement of attitudes through group cohesion, rituals, and leadership dynamics.

Longitudinal data shows that athletes who hold these beliefs early in their athletic development are more likely to engage in coercive or violent behaviour in later relationships.³³⁷ Risk is elevated when athletes are exposed to environments where harmful comments or behaviours go unchallenged, and where leadership does not model clear standards for consent, respect, or emotional regulation.

The 2017 How Sport Can End Sexual Violence report emphasized that sport environments—particularly those involving adolescent boys—present a critical opportunity for positive intervention.³³⁸ It notes that most boys in sport do not hold rape-supportive beliefs, and that the presence of strong, respectful role models can prevent normalization of these norms. The report argues for coaching and team leadership to serve as a proactive buffer against the reinforcement of stereotypes that can translate into future violence.

The VAW Learning Network has similarly noted that prevention is most effective when it focuses on healthy expressions of masculinity and group cohesion, rather than framing masculinity itself as problematic.³³⁹ Creating space for peer leadership, bystander intervention, and meaningful discussion about respect and boundaries is highlighted as essential to long-term cultural change.

4.1.4.3 Prevention Potential of Early Sport-Based Interventions

Evidence from prevention research highlights organized sport as a highly effective environment for the early delivery of violence prevention strategies—particularly those focused on social norms, healthy relationships, and respectful peer conduct. Programs delivered in athletic contexts benefit from two key structural assets: first, the consistent presence of adult mentors (typically coaches) who are in regular contact with youth; and second, the influence of peer group cohesion, which can amplify or disrupt harmful social attitudes depending on how norms are shaped.

Evaluations of the Coaching Boys Into Men (CBIM) program—a coach-led violence prevention initiative delivered in high school athletics discussed earlier in the Committee’s report—found that adolescent boys exposed to the intervention were significantly more likely to intervene when witnessing harmful behaviour and significantly less likely to perpetrate dating violence.³⁴⁰ The program’s efficacy was highest when delivered by coaches already trusted by their athletes, and when integrated into regular team routines.

The CBIM model uses brief, structured discussions focused on respect, consent, and peer accountability, delivered by the coach as part of standard team practice. Participants demonstrated higher levels of pro-social bystander behaviour, reduced endorsement of harmful gender norms, and greater willingness to challenge peer misconduct. These outcomes were sustained over time, suggesting that prevention delivered in sport environments can have durable impact when implemented with fidelity.

Similarly, the Be More Than a Bystander initiative—developed in partnership with EVA BC and BC Lions football players—has reached over 29,000 youth in schools and community settings through athlete-led messaging about SV prevention. The program combines storytelling, discussion, and practical intervention strategies. Preliminary evaluations suggest it improves both knowledge and confidence related to disclosure, boundary-setting, and peer support.

A 2014 review of men’s engagement strategies in gender-based violence prevention emphasized that sport settings offer unique access to youth audiences who may not otherwise engage in social-emotional programming.³⁴¹ The review cautioned that prevention is most effective when messages are not framed as accusatory or ideological, but when they align with existing values around leadership, respect, and fairness.

Sport-specific prevention efforts are most successful when implemented as ongoing team culture strategies rather than standalone presentations. Evaluations of effective programs emphasize the importance of consistency, credible messengers, and integration into regular team practice.³⁴² Coaches are especially well-positioned to shape behavioural expectations, provided they are supported with clear guidelines and training.

4.1.5 Equity, Intersectionality, and Disproportionate Risk

4.1.5.1 Girls and Women in Male-Dominated Spaces

Sport offers unique opportunities for building community, leadership skills, and confidence among young people. Participation in team and individual sports has been associated with positive social outcomes across a wide range of studies. However, historical patterns in some sport environments—particularly those traditionally male-dominated—have presented additional challenges for girls and women seeking to access and benefit from these opportunities.

The 2020 She Belongs report by Canadian Women & Sport found that feelings of belonging and inclusion were critical factors influencing girls’ continued participation in sport.³⁴³ Girls who reported strong peer relationships, clear communication from coaches, and opportunities for leadership were significantly more likely to remain engaged over time. Conversely, perceptions of exclusion, unclear team roles, or cultural barriers were associated with early dropout.

Research on sport culture in high-contact and male-dominated disciplines has highlighted that strong team cohesion can sometimes unintentionally create social barriers for athletes who are perceived as “different” or outside established team norms.³⁴⁴ These barriers may be logistical, such as inequitable access to training resources, or relational, such as limited mentorship opportunities.

Ensuring that girls and women feel fully integrated into the broader fabric of sport participation supports not only individual development but the overall health of the sport community. Studies suggest that inclusive team cultures are associated with higher athlete retention rates, improved peer accountability, and more supportive environments for skill development.³⁴⁵

Best practices identified in the literature for fostering a sense of belonging among all athletes include:

• Providing equitable access to training and competition opportunities;
• Encouraging leadership roles and mentorship opportunities for all athletes;
• Communicating clear expectations around respect, teamwork, and accountability;
• Celebrating contributions to team success beyond athletic performance.

Building environments where all participants feel welcome strengthens not only the individuals involved but the teams and organizations they represent. Recognizing and addressing logistical and relational barriers—while preserving the competitive spirit and camaraderie central to sport—can help sustain participation and community connection across diverse athlete groups.

4.1.5.2 Building Inclusive Participation Across Sport Communities

Community sport environments play an important role in fostering belonging, leadership, and confidence among young people from a wide range of backgrounds. Accessible, welcoming sport programs help support community integration, encourage youth development, and contribute to social cohesion.

Participation rates among athletes who are newcomers, queer, racialized, or part of smaller cultural communities vary significantly across regions, often reflecting broader patterns of access to information, transportation, funding, and recreational infrastructure.³⁴⁶ Research suggests that targeted community outreach, strong leadership from coaches and administrators, and clear communication about participation opportunities can help strengthen the connection between these athletes and the broader sport community.

Athletes living with disabilities also benefit from sport environments that emphasize accessibility, integration, and visibility. Programs such as Challenger Baseball and special hockey leagues have demonstrated how inclusive sport models can foster belonging, skill development, and leadership opportunities for athletes and families alike.³⁴⁷ These programs serve not only as athletic opportunities but as important points of community connection.

Studies show that when sport organizations prioritize belonging and inclusion, all athletes benefit—not only those from underrepresented groups. Inclusive practices have been linked to higher team cohesion, greater leadership development among peers, and lower rates of withdrawal from sport.³⁴⁸

Promising practices identified in the literature include:

• Providing flexible registration processes and accessible facilities;
• Encouraging diverse leadership across coaching, officiating, and administration;
• Building relationships with community organizations to share information and strengthen recruitment;
• Emphasizing teamwork, respect, and enjoyment alongside skill development.

Efforts to strengthen participation must be integrated into broader community-building strategies, ensuring that all athletes have an opportunity to access the social, developmental, and leadership benefits that sport can provide.

4.1.5.3 Systemic and Institutional Barriers to Belonging and Safety

Sport can provide a strong foundation for youth development, confidence-building, and community connection. However, when structural barriers go unacknowledged or unaddressed, athletes may struggle to access the full range of benefits that sport participation can offer. These barriers may include inconsistent access to facilities, fragmented program delivery, or uncertainty about how to seek support if concerns arise.

Athletes from smaller or less formally connected communities—including those who are new to a sport, living with a disability, or unfamiliar with institutional sport systems—may encounter difficulties navigating eligibility, registration, or reporting processes. In some cases, athletes or parents have reported confusion about which organization governs their sport, whether protections apply, or what to do if concerns emerge.

For athletes living with disabilities, access barriers may include not only physical infrastructure limitations but also a lack of program visibility, transportation options, or organizational preparedness. Studies suggest that when accessibility is framed as an integral component of sport culture—rather than an add-on—participants report stronger engagement, retention, and a greater sense of belonging.

Some barriers are relational rather than procedural. Research indicates that when teams or programs are dominated by homogenous peer groups or leadership structures, new or different athletes may feel pressure to conform or self-exclude. This can be particularly salient in performance-driven environments where cohesion is valued and where perceived difference is framed as a liability rather than a strength.

Clear communication, consistent leadership, and adult mentorship all play protective roles in helping athletes feel connected and supported. Inclusive environments are not necessarily defined by demographics but by the presence of relational practices that welcome questions, encourage feedback, and support help-seeking.

Efforts to improve sport access and retention benefit from recognizing that logistical, informational, and interpersonal challenges are often interconnected. Strategies that reinforce psychological safety, organizational transparency, and communication clarity may help reduce avoidable dropout and strengthen the protective role of sport in young people’s lives.

4.1.6 Safe Sport and Abuse-Free Sport: Terms, Programs, and Confusion

4.1.6.1 Safe Sport vs. Abuse-Free Sport: What’s the Difference?

“Safe Sport” is a broad conceptual framework that refers to the idea that all sport environments should be inclusive, respectful, and free from abuse, harassment, or discrimination. In Canada, “Safe Sport” has also been used as a federal brand label for public awareness campaigns, coach education modules, and national oversight initiatives.³⁴⁹

“Abuse-Free Sport” was a distinct federal programmatic framework launched in 2022. It encompassed the Office of the Sport Integrity Commissioner (OSIC), the Universal Code of Conduct to Prevent and Address Maltreatment in Sport (UCCMS), complaint intake and management processes, and educational resources.³⁵⁰ Abuse-Free Sport branding was phased out following the April 1, 2025 transition to the Canadian Safe Sport Program (CSSP), administered by the Canadian Centre for Ethics in Sport (CCES).

The UCCMS serves as the national standard for defining and responding to abuse, harassment, neglect, and boundary violations in Canadian sport. Ontario has not formally adopted the UCCMS as a provincial standard. However, the existence of a national Code creates a potential foundation for provincial alignment.

4.2 Evidence-Based Prevention Models and Cultural Interventions

Sport environments offer a unique platform for early intervention through coach-led and athlete-led programming. The Coaching Boys Into Men program and the Be More Than a Bystander program have both demonstrated measurable success in shifting norms around respect, consent, and peer accountability. Bystander training and peer leadership programs empower athletes to recognize, interrupt, and challenge harmful behaviours among peers.

Social belonging and a sense of inclusion have been identified as protective factors against both experiencing and perpetrating violence. Professional sports organizations are increasingly recognized as powerful cultural influencers. In Ontario, partnerships between professional sports teams (Hamilton Tiger-Cats, Toronto Argonauts, Ottawa Redblacks) and community organizations have been instrumental in promoting GBV prevention, reaching over 3,000 youth.

4.3 Systemic Barriers and Gaps in Sport-Related Violence Prevention

Athletes who experience or witness harm frequently report fear of personal or professional consequences. Most athletes in Canada do not participate at the national level and remain outside federal complaint oversight. Ontario does not directly regulate sport through a comprehensive administrative framework, but multiple provincial and municipal laws, policies, and funding mechanisms touch sport delivery. Rowan’s Law established Ontario’s concussion safety framework and provides a structural precedent.

Ontario recognizes Provincial Sport Organizations (PSOs) through a formal recognition process. While organizations are encouraged to develop internal safe sport policies, there is currently no mandatory requirement for recognized PSOs to demonstrate external safe sport certification or UCCMS alignment. Safe Sport compliance is not currently a condition of general provincial sport funding eligibility.

All Ontarians have a legal obligation to report suspicions of child abuse or neglect under the Child, Youth and Family Services Act, 2017 (CYFSA). This duty applies to all adults working or volunteering with children, including coaches, officials, and administrators. Despite clear legislative obligations, operationalization of mandatory reporting duties in sport environments remains fragmented.

4.4 Federal Evolution and Interjurisdictional Complexity

The structure of maltreatment oversight in Canadian sport has evolved significantly. OSIC was launched in 2022 under the Sport Dispute Resolution Centre of Canada (SDRCC), and in 2025 complaint management transitioned to the CSSP administered by the CCES. However, CSSP jurisdiction applies only to participants of federally funded sport organizations. No formal federal-provincial implementation bridge exists.

As of June 2024, Ontario is the only province in Canada with a dedicated Ministry of Sport, led by Minister Neil Lumsden. Ontario’s current safe sport framework presents opportunities for growth. While the province does not yet have a safe sport Commissioner, independent complaint portal, or formalized oversight mechanisms, these areas are recognized as important for further development.

4.5 Recommendations (Sports)

Recommendation 1: Provide the Ministry of Sport with the Mandate to Lead the Ontario Safe Sport Strategy

The Government of Ontario should formally assign the Ministry of Sport the lead role in developing and implementing the Ontario Safe Sport Strategy. This mandate should include coordinating cross-ministerial work, leading stakeholder consultations, and supervising development of a provincial Safe Sport Act, certification frameworks, complaint intake systems, signage standards, and sanction publication mechanisms.

Recommendation 2: Establish an Ontario Safe Sport Implementation Advisory Committee

The Government of Ontario should establish a Safe Sport Implementation Advisory Committee, tasked with providing technical and sectoral advice on the design and phased rollout of the Ontario Safe Sport Strategy. The Committee should include representation from organized sport, municipal recreation, the education sector, child protection and violence prevention experts, legal experts, and public safety representatives. It should operate on a time-limited basis (e.g., one year).

Recommendation 3: Develop and Pass an Ontario Safe Sport Act

The Government of Ontario should develop and pass an Ontario Safe Sport Act, establishing a provincial legal framework for athlete safeguarding, maltreatment prevention, and sector accountability. Key elements should include a statutory declaration that all participants have the right to participate in a safe, respectful, and abuse-free environment; enabling authority for the Minister to make regulations regarding mandatory training, signage, a complaint intake system, publication of disciplinary findings, and compliance conditions on grants and facility access. The Act should mirror the flexible enabling structure used in Rowan’s Law.

Recommendation 4: Launch Stakeholder Consultation and Jurisdiction Mapping

The Ministry of Sport should immediately initiate a dual process of stakeholder consultation (targeting amateur sport organizations, municipal recreation departments, school boards, colleges and universities, child protection agencies, and athlete representatives) and jurisdiction mapping (a legal and operational review to identify statutory, regulatory, and funding levers). This process should be completed within 12 months.

Recommendation 5: Develop an Ontario Safe Sport Certification Program

The Government of Ontario should develop and implement a mandatory Safe Sport Certification Program, requiring all adults who supervise, coach, officiate, or directly oversee organized sport activities involving participants under the age of 26 to complete approved Safe Sport training. Core curriculum topics should cover power dynamics, grooming behaviours, peer-on-peer violence, trauma-informed communication, cultures of respect and consent, and digital boundary management. Certification should be valid for a fixed term (e.g., 5 years). A centralized verification system should be established. The program should be similar in concept to Smart Serve and mandatory OHSA training.

Recommendation 6: Create a Publicly Accessible Ontario Safe Sport Certification Brand

The Government of Ontario should develop and launch a publicly accessible Ontario Safe Sport Certification Brand, awarded to organizations that demonstrate compliance with mandatory training, adopt provincially approved Safe Sport policies, and meet signage and reporting requirements. A public registry of certified organizations should be maintained.

Recommendation 7: Establish an Independent Ontario Safe Sport Commissioner

The Government of Ontario should establish an Independent Ontario Safe Sport Commissioner, empowered to receive confidential and anonymous complaints, conduct investigations using trauma-informed methods, adjudicate complaints, impose administrative sanctions, maintain a public sanctions registry, and provide system-level recommendations to the Minister. The Office could initially be created within the Ministry of Sport and later spun out as an arm’s-length agency.

Recommendation 8: Develop a Mandatory Safe Sport Signage Program

Safe Sport information shall be prominently posted in school-based athletic facilities, municipal recreation centres, and private sport facilities receiving public funds. Signage must include a summary of rights and responsibilities, a plain-language outline of prohibited conduct, and clear instructions for reporting concerns (including QR codes linking to the Commissioner’s intake portal). Standardized templates shall be available in English and French and meet accessibility standards.

Recommendation 9: Establish a Public Sanctions Reporting Framework

The Government of Ontario should establish a Public Sanctions Reporting Framework under the Ontario Safe Sport Act, providing for the structured, standardized publication of sanctions imposed following disciplinary findings. Only final adjudicated findings—not unproven allegations—should be published. The sanctions registry should be free, searchable, and accessible to the public, modelled on existing professional regulatory registries (Law Society of Ontario, College of Physicians and Surgeons, Ontario College of Teachers, etc.).

Recommendation 10: Condition Facility Access and Public Funding on Compliance with Safe Sport Standards

Access to public sport and recreation facilities, and eligibility for provincial sport-related funding, should be conditional on compliance with Safe Sport standards. Organizations must demonstrate that supervising adults have completed Ontario Safe Sport Certification, adopt the provincially standardized Safe Sport policy, and post required signage. Municipalities should embed Safe Sport compliance into facility rental agreements.

Recommendation 11: Partner with CFL and Invite Broader Professional Sport Participation in a Violence Prevention Public Education Campaign

The Government of Ontario should seek to partner with CFL franchises already engaged in violence prevention leadership initiatives to support a co-branded public education campaign. The campaign should promote leadership, loyalty, and protection of others; reinforce that real strength is demonstrated through standing up for teammates and communities; and support the protection and dignity of women and girls. Ontario should invite additional professional sports teams (NHL, MLB, NBA, OHL) to participate. Campaign delivery should include prime-time television, digital media, outdoor advertising, and community-based youth outreach.

Section 5: Newcomers, Community Education, CAS and Professional Associations

5.1 Violence Prevention, Disclosure, and Accountability Infrastructure in Ontario Post-Secondary Institutions

Ontario’s post-secondary institutions represent a critical setting for violence prevention and early intervention. The majority of students enrolled in colleges and universities fall within the 18–24 age range, the demographic most statistically at risk for sexual violence (SV).

5.1.1 Prevalence and Disclosure Barriers

Sexual violence disproportionately affects post-secondary students, particularly women, 2SLGBTQ+ students, and other marginalized populations. In the 2018 Student Voices on Sexual Violence survey, 63.2% of university students and 49.6% of college students reported experiencing sexual harassment, while 23% of university students and 16.3% of college students reported experiencing non-consensual sexual contact. Disclosure rates remained low: fewer than 10% of survivors reported to a formal institutional office.

Research has identified multiple barriers to disclosure, including uncertainty about where to report, fear of being disbelieved, concerns about confidentiality and retaliation, and mistrust of institutional motives. The 2019 Courage to Act national framework noted that disclosure was especially low among international students, students with disabilities, and racialized students.

5.1.2 Legislative and Policy Framework

In 2016, Ontario passed Bill 132, the Sexual Violence and Harassment Action Plan Act, requiring all publicly funded post-secondary institutions to develop a standalone sexual violence policy, consult students in policy creation, and review policies every three years. However, the legislation did not mandate uniform program standards, minimum training expectations, or evaluation mechanisms. In 2021, the Ministry announced a $6 million investment in sexual violence prevention, but without formal KPIs or province-wide accountability standards.

5.1.3 Prevention Programs and Intervention Models

The Enhanced Assess, Acknowledge, Act (EAAA™) program—commonly known as Flip the Script—is one of the most rigorously evaluated sexual violence prevention programs for post-secondary students in North America. A 2015 RCT involving 893 first-year students found that participants experienced 46% fewer completed rapes, 34% fewer attempted rapes, and 22% fewer other forms of sexual assault over 12 months. A 2023 evaluation confirmed the program maintained its impact under real-world conditions. As of 2024, EAAA is offered at a limited number of Ontario universities.

Western University’s “Mustangs for Consent” program provides a two-part prevention approach: Consent 101 (a 90-minute online module) and Undressing Consent (a 90-minute live-facilitated program). As of 2022, both components were mandatory for first-year students entering residence. Male students had less knowledge of what constitutes sexual violence and were less likely to show significant change in knowledge and attitudes than female and non-binary students.

5.2 Child Welfare and CAS Responsibilities in Family Violence Prevention

5.2.1 Legislative and Structural Authority

Ontario’s CASs are designated under the Child, Youth and Family Services Act, 2017 (CYFSA). CASs are independently incorporated nonprofit organizations governed by local boards, legally empowered to investigate allegations that a child may be in need of protection. There is no statute or regulation that specifically names IPV, SV, or coercive control as standalone grounds for protection. However, section 74(2)(e) of the CYFSA defines “a child in need of protection” to include a child who suffers emotional harm from exposure to conflict between caregivers.

5.2.2 CAS Discretion and Local Variation

While all CASs operate under the CYFSA, they exercise significant discretion in service delivery, risk assessment, training, and case planning. The Ministry does not require CASs to use a standardized risk assessment framework for identifying IPV or coercive control. The Eligibility Spectrum includes limited references to exposure to domestic violence but does not contain detailed indicators for coercive control, non-physical abuse, or cumulative pattern-based risk.

5.2.3 Intersection with IPV, SV, and Coercive Control

The 2018 Ontario Incidence Study (OIS-2018) found that 45 percent of all substantiated child maltreatment investigations involved exposure to IPV. Among those, nearly 80 percent of child protection interventions focused on the mother as the primary caregiver. Multiple studies have noted that CASs may conflate exposure to violence with failure to protect, resulting in responses that emphasize maternal compliance rather than safety planning or systemic coordination.

5.2.4 Findings from the DVDRC

A 2020 multi-disciplinary review of DVDRC recommendations to child welfare recommended that all child protection workers receive mandatory training on identifying and responding to coercive control, and that CASs adopt policy frameworks recognizing the protective role of non-abusive parents. These recommendations are not currently codified in regulation or funding policy.

5.2.5 Training, Capacity, and Provincial Levers

MCCSS does not require all CAS staff to complete mandatory training specific to IPV, SV, or coercive control. As of 2024, there is no provincial requirement for societies to document IPV or SV as a case characteristic, record whether a risk assessment was completed, demonstrate use of trauma-informed practices, or participate in interagency risk panels.

5.2.6 Indigenous Child and Family Well-Being Agencies Under Part X of the CYFSA

Ontario’s child welfare system includes both mainstream CASs and a distinct group of Indigenous agencies designated under Part X of the CYFSA. As of 2024, there are 13 designated agencies. These agencies are legally designated under provincial law but operate through agreements negotiated with Indigenous governments.

Indigenous agencies are not subject to review by the Auditor General of Ontario. It is unknown whether ICFWBAs are required to use the province’s centralized Child Protection Information Network (CPIN). There is no publicly available system to monitor how ICFWBAs use risk assessment tools, deliver staff training, or participate in interagency case planning involving IPV, SV, or coercive control.

Indigenous children are disproportionately represented in Ontario’s child welfare system. As of the 2018 Ontario Incidence Study, Indigenous children made up approximately 4% of the child population but accounted for 10% of all substantiated maltreatment investigations. Rates of intimate partner violence are significantly higher in Indigenous communities. According to Statistics Canada, 61% of First Nations women, 64% of Métis women, and 44% of Inuit women have experienced IPV in their lifetime.

As of 2024, no province-wide data has been published confirming whether the proportion of Indigenous children in care has declined since the implementation of Part X.

5.3 Reaching Newcomer and Immigrant Communities: Disclosure, Trust, and Cultural Infrastructure

5.3.1 Structural Risk and Disclosure Barriers

Newcomer women in Ontario face a distinct and compounded set of structural barriers that inhibit access to early intervention, shelter, police protection, court processes, and long-term recovery. These barriers are rooted in the intersection of immigration status, language access, family sponsorship models, collectivist cultural norms, religious authority structures, and systemic mistrust. Multiple sources emphasize that immigrant and refugee women may not disclose abuse through conventional help-seeking pathways.

5.3.2 Cultural Norms, Shame, and Help-Seeking Expectations

In collectivist societies, victim experiences are often understood in relation to family honour, social cohesion, and community perception. Research has shown that when survivor narratives rely heavily on individualist models (e.g., urging separation or criminal complaint), many women from collectivist cultures will disengage entirely.

5.3.3 Legal System Complexity and Procedural Burden

Cases involving victims or accused persons with limited English proficiency, immigration status complications, and limited financial independence often require court-appointed interpreters, immigration lawyers, publicly funded translators, additional adjournment time, and cultural context assessments. These complexities lengthen proceedings significantly and increase court costs.

5.3.4 Rights Education and Prevention Through Messaging

There is no province-wide system in Ontario for delivering multilingual, culturally grounded information about the rights of women and children in Canada. Most translated materials are created locally, inconsistently funded, and do not form part of a coordinated strategy.

5.3.5 Trusted Messengers and Community-Based Prevention Models

The Muslim Resource Centre for Social Support and Integration (MRCSSI), based in London, Ontario, has piloted one of the most well-documented culturally integrative models to date. Its Culturally Integrative Family Safety Response (CIFSR) model involves trained cultural mediators, faith leaders, and mainstream service providers working together to assess risk and deliver safety planning. While CIFSR shows promise, it has not yet been formally evaluated at scale. As of 2024, no provincial funding stream exists to support its replication.

5.3.6 The Newcomer’s Assistance Program

The Newcomer’s Assistance Program (NAP), piloted by the Toronto Police Service, provides proactive outreach by officers in collaboration with settlement agencies at newcomer-focused events, religious institutions, or local community spaces. As of 2025, NAP remains small in scale but participating officers and community partners have reported strong positive anecdotal feedback. NAP may warrant structured pilot funding for external evaluation and model refinement.

5.3.7 Public Education and Multilingual Messaging Gaps

Ontario currently lacks any centralized or sustained system for delivering public-facing, multilingual information on IPV, SV, or human trafficking. No provincial repository exists to coordinate messaging, facilitate consistent translation updates, or ensure quality control. The Ontario Council of Agencies Serving Immigrants (OCASI) has emphasized the importance of consistent, simplified language and the use of video or narrative storytelling. The Canadian Council of Muslim Women has called for translated materials explaining legal rights in Canada in ways that do not presume cultural familiarity with Canadian law.

Public-facing education is a prevention tool. When women understand that violence is not tolerated under Canadian law, that seeking help will not necessarily lead to deportation or family dissolution, and that their safety is prioritized under the Charter of Rights and Freedoms, the pathway to disclosure becomes more viable. Without this knowledge, many women remain in unsafe environments, either believing abuse is legally permitted or fearing worse consequences if they seek help.

At present, Ontario has no structured mechanism for funding, producing, distributing, or evaluating these materials at scale. While the Neighbours, Friends and Families campaign was developed in part to address these gaps, due to resource constraints its current footprint is limited and its materials have not been substantially updated, digitized, or translated in recent years. There is no active coordination between this platform and Ontario’s school boards, shelters, or settlement agencies, nor any provincial mandate to integrate IPV/SV/HT education into newcomer-facing programming.

Given this infrastructure gap, the province may wish to consider supporting a centralized multilingual education platform—potentially housed within or adjacent to the proposed regional hubs—to coordinate messaging, approve translations, and make culturally vetted public education resources broadly accessible. This would not require a prescriptive curriculum or ideological framework. Rather, it would provide practical tools that community and institutional actors could deploy flexibly, including:

• Posters, brochures, and digital graphics,
• Rights-based scripts for police, teachers, and front-line workers,
• Translated disclosure cards and referral summaries,
• Simple legal information videos or audio files.

Such infrastructure would allow Ontario to deliver consistent prevention messaging across cultural communities without creating new enforcement risks. It would also signal a provincial commitment to accessibility, equity, and upstream intervention.

5.4 Neighbours, Friends and Families: Legacy Infrastructure and System Gaps

5.4.1 Overview and Origins

Neighbours, Friends and Families (NFF) is a public education campaign launched in Ontario in 2005 to raise awareness about IPV and encourage bystander recognition and response.⁵⁰⁰ Funded initially by the Ontario Women’s Directorate and developed through academic partnerships with researchers at the Centre for Research and Education on Violence Against Women and Children (CREVAWC), the campaign aimed to engage informal networks—neighbours, coworkers, community members—in identifying warning signs and supporting victims.⁵⁰¹

CREVAWC, housed at the University of Western Ontario, is a nationally and internationally recognized centre specializing in violence prevention research, professional training, and public education. Its initiatives span cross-sectoral knowledge translation, trauma-informed practice development, and the creation of empirically supported models for gender-based violence (GBV) workforce capability.

NFF materials were designed to be accessible, non-institutional, and rights-based. The campaign focused on helping community members recognize abusive behaviours, understand the risk of escalation, and refer victims to support services. Delivery relied heavily on community organizations, social service providers, and localized champions, with a limited centralized infrastructure and no mandated institutional integration.

5.4.2 Adaptations and Limited Persistence

Over time, several tailored variants of NFF were developed, including campaigns on elder abuse, workplace disclosure, and immigrant and refugee communities (IRC). The IRC variant, delivered by the Ontario Council of Agencies Serving Immigrants (OCASI), remains one of the few NFF adaptations still in active use. OCASI coordinates a “peer champion” model in which multilingual outreach is conducted by trained community members from diverse cultural and religious backgrounds.⁵⁰² These outreach efforts have included translated videos, simplified rights education, and culturally responsive training materials. Other NFF initiatives include COSTI, the Ontario Federation of Indigenous Friendship Centres, and Action ontarienne contre la violence faite aux femmes (AOcVF).

The campaign’s digital and content footprint is now maintained by the VAW Learning Network (VAWLN), a government-funded public education initiative hosted by CREVAWC.⁵⁰³ The Learning Network (LN), established in 2011, produces and disseminates high-quality, accessible educational materials on GBV, including webinars, podcasts, reports, and multilingual resources. In 2023–24, LN’s programming reached over 2.6 million individuals, with more than 325,000 unique website visits, 9,600 live webinar attendees, and 4,600 individuals receiving formal certificates of participation.⁵⁰⁴ Evaluations show that over 95% of surveyed users report increased understanding of GBV after engaging with LN resources.

Despite limited formal reinvestment, LN has continued to disseminate NFF-linked resources, including translated tools, factsheets, and training content. These efforts reflect the continuing relevance of NFF’s foundational model, but the campaign currently lacks an institutional delivery mechanism, integration into Ontario’s broader prevention infrastructure, or formal links with education, health, justice, or immigration systems.⁵⁰⁵

Both the Learning Network and the NFF campaign are scheduled to lose core MCCSS funding as of March 2026, following the non-renewal of CREVAWC’s application under Ontario STANDS’ National Action Plan program. In the absence of alternative support, the shutdown will eliminate Ontario’s only centralized hub for evidence-based public education on GBV, as well as the province’s most widely recognized platform for multilingual, rights-based IPV prevention messaging.

5.4.3 Implications for Infrastructure Renewal

NFF illustrates both the magnitude of Ontario’s past public investment in IPV prevention messaging and the fragility of that investment in the absence of sustained infrastructure. Its original framing—a non-institutional, rights-based campaign focused on early recognition and community response—remains aligned with provincial prevention goals, particularly in settings where formal service engagement may be delayed or avoided.

CREVAWC and the LN have, to date, served as Ontario’s only consistent platform for developing and disseminating this kind of tailored prevention infrastructure at scale. Without a stable funding and governance model, these tools risk being lost, leaving a substantial void in the province’s public-facing violence prevention capabilities. Additional partners—across community, cultural, health, and education sectors—could be integrated into a revitalized framework but would struggle to rebuild the backbone infrastructure that NFF and the Learning Network currently provide.

The October 2024 application submitted by CREVAWC proposed the continuation ($1,269,393) and expansion ($1,473,671) of this infrastructure at a combined cost of $2,743,000 over three years. The proposal outlined a multi-strand public education platform focused on two new campaign themes, updated training content, and expanded engagement with rural and underserved communities. Additional components included centralized multilingual resource development, website and content redesign, and co-development of materials with community-based actors. Maintenance without expansion would be $420,000/year for the Learning Network and $430,000 per year in support of NFF.⁵⁰⁶

Additional funding beyond the proposed envelope could support increased public education across sectors, including centralized access to multilingual prevention materials; modernized visual and digital design, including usability improvements and rebranding; scalable rights-based content suitable for shelters, schools, health care, and settlement settings; and outreach strategies developed in partnership with community-based organizations. The platform could also incorporate licensed or adapted content from established evidence-based campaigns, including those produced by White Ribbon, MentorAction, Futures Without Violence, or the Moose Hide Campaign, enabling consistent content standards and expanded distribution. All materials would be developed with expert input and made publicly accessible for flexible use by institutions and service providers across the province. This approach could reduce duplication and promote standardization across public education investments in the violence prevention sector.

5.5 Professional Sectors Named by the DVDRC: Training, Oversight, and Opportunities for Sector-Led Engagement

Ontario’s Domestic Violence Death Review Committee (DVDRC), established in 2003 under the Office of the Chief Coroner, reviews domestic homicides involving current or former intimate partners, as well as related child and collateral deaths. Drawing on police, coroner, and service records, the DVDRC identifies known risk factors, missed intervention opportunities, and common system weaknesses across cases. It does not assign blame but produces retrospective analyses to support prevention and policy development. Over two decades of reviews, the DVDRC has repeatedly named specific professions, institutions, and sectors that had prior contact with either the victim or perpetrator and may have had opportunities to recognize risk or intervene. These contacts span a wide range of roles—including health care, education, law enforcement, and legal professionals—each governed by different oversight structures and regulatory tools. The sectors below are not grouped by type or function, but by the fact that they have been named in DVDRC reports in connection with missed risk, disclosure, or intervention opportunities.⁵⁰⁷ Each is governed differently, and the province has varying degrees of leverage to support training, coordination, or policy alignment.

5.5.1 Physicians and Primary Care Providers

Physicians have been named in multiple DVDRC cases involving missed documentation of injuries, failure to recognize escalating risk, or lack of referral to appropriate supports. The College of Physicians and Surgeons of Ontario (CPSO) regulates physicians under the Regulated Health Professions Act, 1991. While partner abuse is listed in the Medical Expert competency domain, the CPSO does not mandate training on intimate partner violence (IPV), coercive control, or trauma-informed care.⁵⁰⁸

5.5.2 Teachers and Educators

Educators have been named in DVDRC reports involving children exposed to violence in the home, where concerning behaviours were observed but not reported to child protection. The Ontario College of Teachers (OCT) regulates the profession under the Ontario College of Teachers Act, 1996. Educators are mandatory reporters under the Child, Youth and Family Services Act, 2017, but the OCT does not currently require IPV or SV-related training as part of certification or ongoing development. The DVDRC has emphasized the importance of educator awareness in households where children are witnessing coercive control, particularly when the child is withdrawn, hypervigilant, or displays trauma indicators.

5.5.3 Police Services

Police have been named in nearly every DVDRC report, often with reference to prior calls for service, lack of risk escalation recognition, or inadequate safety planning. The Community Safety and Policing Act, 2019 governs policing in Ontario; the Ministry of the Solicitor General may issue policing standards under this authority. As of 2024, the last domestic violence policing standard (LE-024) remains unchanged since 2013.⁵⁰⁹ Officers are not uniformly trained in coercive control, DVDRC risk factors, or structured risk assessment tools unless individual services adopt them locally.

5.5.4 Lawyers and Legal Professionals

The Law Society of Ontario (LSO) regulates lawyers under the Law Society Act. While the LSO provides some optional training on representing survivors of family violence, there is no mandatory requirement for family, criminal, or immigration lawyers to receive IPV or SV-specific education. The DVDRC has named the legal profession in multiple cases where adversarial legal processes—especially in family court—intensified coercive control or contributed to risk escalation. Lawyers were also named in cases where child custody negotiations failed to account for prior abuse or threats. The province has no authority over LSO training standards but may influence Legal Aid Ontario or procedural reforms in family court settings.

5.5.5 Veterinarians

Veterinarians have been named in DVDRC reports where companion animals were injured or killed in connection with coercive control. The College of Veterinarians of Ontario (CVO) regulates the profession under the Veterinarians Act. Humane Canada has developed a series of recommendations and recourses to support survivors of GBV and their animals,⁵¹⁰ though the Ministry of Agriculture, Food and Rural Affairs does not currently fund or endorse any cross-reporting frameworks between veterinarians and protection agencies.

5.5.6 Real Estate and Property Professionals

The real estate sector has appeared in DVDRC reviews involving cohabitation disputes, financial coercion, or evictions during periods of risk escalation. This sector is not regulated for violence prevention. The Real Estate Council of Ontario (RECO) licenses agents under the Real Estate and Business Brokers Act, 2002, but there is no IPV or SV-related content in mandatory education. No DVDRC recommendation has been issued specific to the real estate profession, but its inclusion in fatality timelines has raised questions about housing transitions and disclosure. The province has no direct lever in this sector aside from indirect engagement with associations such as OREA.

5.5.7 Office of the Children’s Lawyer (OCL)

The OCL, housed within the Ministry of the Attorney General, has been named in DVDRC reports concerning child custody proceedings. The OCL is not a regulatory college, and there is no legislated requirement for its assessors or counsel to receive specialized IPV or coercive control training. The DVDRC regularly recommends specialized education for all professionals involved in the family law system to promote better recognition, assessment, and response to IPV.

5.5.8 Probation and Community Corrections Officers

DVDRC reports have identified supervision gaps in cases where the perpetrator was on probation or under community corrections oversight. Ontario probation officers fall under the Ministry of the Solicitor General. While general training includes risk management principles, there is no known requirement for ongoing education in DVDRC risk factors, coercive control, or structured case planning in IPV contexts.

5.5.9 Obstetrical and Perinatal Health Providers

Perinatal care providers were named in a DVDRC case involving the homicide of a pregnant woman. The review called for broader awareness in the obstetrical and nursing community that pregnancy may represent a high-risk period for IPV escalation. Physicians are regulated under CPSO, and nurses under the College of Nurses of Ontario (CNO). As of 2024, there is no training module in either college’s mandatory education pathway that addresses family violence risk in pregnancy.

5.5.10 Correctional Services Canada (CSC)

The DVDRC regularly identifies failures of sharing risk information across organizations including CSC, CAS and police, and the absence of follow-up with the survivor following release. CSC operates under federal jurisdiction; the province does not have authority to mandate training or process changes. However, the DVDRC Roadmap calls for enhanced communication protocols and risk planning in federal-to-provincial supervision transitions.

5.5.11 Voluntary Sector Action: Hospitality and Human Trafficking Prevention

While most sectors named in DVDRC reports have not launched sustained, voluntary training initiatives related to intimate partner violence (IPV), the hospitality sector has emerged as a notable example of industry-led engagement in the prevention of human trafficking. Since 2019, the Ontario Restaurant Hotel & Motel Association (ORHMA), in partnership with community-based anti-trafficking organizations and police services, has supported a province-wide rollout of awareness training for hotel staff.⁵¹¹ These efforts include digital training modules, in-person sessions, staff protocol templates, and signage placed in guest-accessible areas. National hotel brands have also implemented internal reporting tools and partnered with survivor-led agencies to improve frontline recognition of human trafficking indicators.⁵¹² These initiatives were developed proactively and without regulatory requirement. While focused on trafficking, the model demonstrates the potential for sector-based leadership in violence prevention, even in the absence of legislative or regulatory mandates.

5.6 Recommendations

5.6.1 Recommendation 1: Standardize Child Welfare Risk Assessment and Case Management in IPV/Coercive Control Cases

Context and Purpose: Children’s Aid Societies (CASs) in Ontario are not currently required to use standardized approaches for identifying and responding to intimate partner violence (IPV) and coercive control in households with children. As a result, child welfare investigations involving IPV often vary in scope, structure, and focus. A 2022–2023 cross-sector steering committee reviewed over a decade of Domestic Violence Death Review Committee (DVDRC) findings and emphasized the need for consistent guidance on risk identification, safety planning, and case decision-making.

Jurisdiction: The Ministry of Children, Community, and Social Services has the authority to issue policy directives and practice expectations to designated societies under the Child, Youth and Family Services Act, 2017 (CYFSA).

Recommendation: The Government of Ontario should direct MCCSS to develop and issue standardized practice guidance for CASs to support risk identification, assessment, and case planning in files involving IPV or coercive control. Practice guidance should:

• Be developed in consultation with child welfare stakeholders, VAW sector experts, and representatives from child development, clinical, academic (CREVAWC), and legal fields;
• Align with existing tools such as the Eligibility Spectrum, Child Protection Standards, and Clinical Assessment of Family Functioning;
• Include structured documentation templates to support consistent case recording and referral planning;
• Address identification of coercive and controlling behaviour patterns, including lethality risk indicators;
• Guide recognition and documentation of protective efforts by non-offending caregivers;
• Support structured identification of the emotional, developmental, and behavioural needs of children exposed to IPV;
• Provide planning strategies to prevent further harm and reduce risk of escalation;
• Facilitate service access for children and caregivers affected by IPV;
• Outline documentation and referral expectations related to the abusive parent, including consideration of intervention services, supervised visitation, and court-ordered compliance monitoring; and
• Reference validated IPV risk assessment tools (e.g., ODARA, Danger Assessment, B-SAFER) to support alignment across sectors.

Practice guidance once developed should also be shared with Indigenous Child and Family Well-Being Agencies for their information and use, recognizing that these agencies are not subject to provincial direction under the CYFSA.

Implementation Considerations: MCCSS may wish to consider whether agency-level implementation tracking, referral documentation rates, or integration with existing information systems should be required as part of quality assurance. Additional consultation may be needed to determine the best approach for integrating IPV-specific guidance within broader policy and training structures.

Rationale: Risk identification and case planning in IPV cases remains inconsistent across Ontario CASs. Repeated recommendations from the DVDRC have emphasized the need for structured assessment approaches in cases involving coercive control, risk to non-offending caregivers, and harm to children. Development of standardized practice guidance would clarify expectations, support implementation of prior recommendations, and improve service consistency and safety planning in high-risk child welfare cases. Aligning case management approaches with existing IPV risk frameworks and ensuring cross-sector coordination will strengthen Ontario’s capacity to support child and caregiver safety in IPV-exposed households.

5.6.2 Recommendation 2: Mandate and Standardize IPV/Coercive Control Training for Child Welfare Workers

Context and Purpose: Despite longstanding recommendations from the Domestic Violence Death Review Committee (DVDRC), there is currently no mandatory requirement for child welfare workers in Ontario to receive training on IPV, coercive control, or related risk factors. A 2022–2023 cross-sector steering committee identified the absence of standardized, mandatory IPV training as a core deficit in Ontario’s child welfare response. Although the Ontario Association of Children’s Aid Societies (OACAS) offers a two-day IPV training program, access and uptake vary widely between agencies. Mandatory, evidence-based training is required to ensure consistent risk recognition, safe case planning, and effective engagement with all members of the family.

Jurisdiction: Ministry of Children, Community and Social Services (MCCSS), under s. 42 of the Child, Youth and Family Services Act, 2017.

Recommendation: The Government of Ontario should direct MCCSS to establish province-wide training requirements on IPV and coercive control for all child welfare staff with case-carrying or supervisory responsibilities. Training requirements should include:

• A minimum of 20 hours of mandatory IPV-specific training for all newly hired case-carrying child welfare workers;
• Six hours of mandatory refresher training every three years for all case-carrying workers;
• Six hours of IPV-specific training for new supervisors and managers upon assuming supervisory responsibilities;
• Six hours of ongoing IPV refresher training for all supervisors and managers every three years.

Training content should be standardized across the province and should address:

• Identification and assessment of coercive control and psychological abuse;
• Use of validated risk assessment frameworks;
• Survivor-centred safety planning, including technology safety and economic dependency;
• Engagement with abusive parents, including referral to perpetrator intervention services, supervision protocols, and monitoring of court-ordered interventions;
• Collaboration with police, courts, and VAW service providers;
• Trauma- and violence-informed practice, including cultural responsiveness and support for diverse families.

As with all child welfare directives, training requirements will not apply to Indigenous Child and Family Well-Being Agencies; however, training materials should be made available for their voluntary use.

Implementation Considerations: MCCSS may need to fund the development or adaptation of standardized training materials and establish a province-wide training approval or oversight mechanism. Metrics for compliance and evaluation may include pre- and post-training assessments, periodic reviews of case planning quality, and reporting on training completion rates. CAS agencies may require transitional support to bring existing staff into compliance within a defined period.

Rationale: The DVDRC has issued at least ten separate recommendations since 2013 calling for mandatory IPV training for child welfare professionals. Lack of training on coercive control, risk assessment, and perpetrator accountability undermines the safety of children and non-offending caregivers and contributes to inconsistent case outcomes. A province-wide mandate with minimum hour requirements and standardized content will help ensure that all caseworkers and supervisors are equipped to manage the complex dynamics of IPV in child protection contexts. Ensuring consistent training is a foundational step in aligning Ontario’s child welfare system with best practices in violence prevention, family safety, and trauma-informed care.

5.6.3 Recommendation 3: Establish a Centralized Mechanism to Track and Report CAS Implementation of IPV-Related Expectations

Context and Purpose: There is currently no standardized provincial mechanism for monitoring how Children’s Aid Societies (CASs) implement IPV-related expectations, including those stemming from directives, DVDRC recommendations, or internal policy guidance. While CASs submit compliance and service data through various MCCSS frameworks, no structure exists for tracking specific practices related to coercive control identification, safety planning with non-offending caregivers, or referral of abusive parents to intervention services. Without consistent metrics, the province cannot assess uptake, alignment, or progress in addressing DVDRC-identified practice gaps.

Jurisdiction: This recommendation falls under the authority of the Ministry of Children, Community and Social Services, which is responsible for issuing directives to Children’s Aid Societies and overseeing accountability mechanisms under the Child, Youth and Family Services Act, 2017.

Recommendation: The Government of Ontario should direct MCCSS to establish a centralized mechanism for tracking CAS implementation of IPV-related case management expectations. The tracking framework should:

• Identify specific practices to be monitored (e.g., coercive control identification, safety planning documentation, perpetrator service referral);
• Define consistent data collection methods, including quantitative and qualitative inputs;
• Integrate reporting into existing accountability or quality assurance processes where possible;
• Enable identification of implementation patterns, system gaps, and areas requiring further support or clarification.

Implementation Considerations: The development of a new tracking mechanism will require alignment with existing MCCSS performance frameworks and case management systems (e.g., CPIN). Some IPV-related practices may not currently be coded or extractable from routine data fields, and changes to documentation guidance may be needed. Clarity will be required around the purpose of data collection—whether for internal planning, evaluation, or public reporting—to guide system design and communication with CASs. Any tracking system should respect the legal and operational autonomy of Indigenous Child and Family Well-Being Agencies, which are not subject to MCCSS directives.

Rationale: Consistent tracking of IPV-related case management practices is essential for implementation fidelity and system improvement. Without data, the province cannot assess whether CASs are adopting recommended practices or identify areas where training or guidance is needed. A centralized reporting mechanism will allow MCCSS to monitor uptake of standardized IPV interventions, support agency-level planning, and respond to DVDRC and inquest recommendations calling for improved accountability in child protection responses to IPV.

5.6.4 Recommendation 4: Improve Data Collection on Child Welfare Involvement in IPV Cases to Support Evaluation and System Planning

Context and Purpose: Ontario does not currently collect or publish comprehensive data on child protection involvement in cases of IPV. Although IPV is one of the most common reasons for referral to Children’s Aid Societies (CASs), provincial data systems do not distinguish between cases where IPV is the primary concern, a co-occurring risk factor, or an unaddressed background condition. Without disaggregated and structured data, the province cannot evaluate outcomes for children exposed to IPV, assess the effectiveness of current child welfare interventions, or support evidence-informed policy development.

Jurisdiction: This recommendation falls under the authority of the Ministry of Children, Community and Social Services (MCCSS), which oversees child protection data systems and provincial outcome evaluation frameworks.

Recommendation: The Government of Ontario should direct MCCSS to improve data collection related to child welfare involvement in IPV cases. This should include:

• Establishing a consistent coding structure to identify IPV as a case characteristic at intake, investigation, and ongoing service stages;
• Distinguishing between cases where IPV is the primary reason for service and those where it is a secondary or co-occurring concern;
• Supporting the collection of outcome data specific to children exposed to IPV, including indicators related to safety, stability, and recurrence of service involvement; and
• Ensuring that IPV-related variables are included in any province-wide child welfare outcomes framework.

Implementation Considerations: Current data systems such as CPIN may not fully support the capture of IPV-related variables without modification to existing fields or reporting protocols. Additional training may be required to ensure consistent coding across CASs. Data collection frameworks should be aligned with broader MCCSS accountability efforts and may require consultation with CASs to ensure feasibility and accuracy. Indigenous Child and Family Well-Being Agencies are not subject to provincial reporting requirements but may be invited to participate voluntarily in shared learning and outcome tracking initiatives.

Rationale: Improved data collection on child protection involvement in IPV cases is essential to understanding whether services are producing meaningful safety outcomes for children and families. Current systems do not support structured evaluation of case trajectories, risk mitigation strategies, or recurrence patterns in IPV-exposed households. A more precise data framework will support continuous improvement, help identify service gaps and enable MCCSS to respond to DVDRC and inquest recommendations with evidence-informed planning and resource allocation.

5.6.5 Recommendation 5: Require Evidence-Based Sexual Violence Prevention Programming at Colleges and Universities

Context and Purpose: The Enhanced Assess, Acknowledge, Act (EAAA) program is the only SV prevention program for post-secondary students in North America with randomized controlled trial (RCT) evidence demonstrating reductions in attempted and completed sexual assault. Despite its evaluation history and successful implementation in Ontario institutions, most colleges and universities do not currently offer EAAA or any equivalent evidence-based prevention program. Public institutions are required by legislation to maintain a sexual violence policy but are not held to any standard regarding prevention program delivery, fidelity, or outcome measurement.

Jurisdiction: The Ministry of Colleges and Universities (MCU), under s. 15.1 of the Ministry of Training, Colleges and Universities Act.

Recommendation: The Government of Ontario should require all publicly assisted colleges and universities to deliver a validated, evidence-based sexual violence prevention program to post-secondary students. Minimum standards should be established by the Ministry and should:

• Specify that qualifying programs must demonstrate statistically significant reductions in sexual assault perpetration and/or victimization through peer-reviewed evaluation;
• Identify EAAA as the only program currently meeting this standard for women students;
• Require that institutions delivering EAAA adhere to fidelity protocols established by the program’s licensor;
• Permit institutions to propose alternative programs only if they demonstrate equivalent evidence and fidelity safeguards; and
• Require public reporting by institutions on implementation status, program delivery volumes, and student reach.

Implementation Considerations: The Ministry may wish to issue implementation guidance outlining expectations for initial delivery timelines, minimum student reach, and reporting formats. Smaller institutions or satellite campuses may need to explore joint delivery models or shared access to trained facilitators. Private institutions and career colleges are not subject to legislative requirements under the Ministry of Training, Colleges and Universities Act. These institutions may be encouraged to voluntarily adopt evidence-based prevention programs or to participate in Ministry-supported training and implementation initiatives where appropriate.

Rationale: Evidence-based prevention is a critical component of Ontario’s SV response. Programs such as EAAA have demonstrated statistically significant reductions in sexual assault in post-secondary populations and represent a measurable, cost-effective intervention strategy. Requiring institutions to implement such programs ensures that students receive prevention education that is grounded in evidence and delivered with fidelity. Setting a clear standard also supports system accountability, equity of access, and alignment with provincial policy commitments on student safety and campus violence prevention.

5.6.6 Recommendation 6: Establish Minimum Standards for Sexual Violence Policy Implementation, Intake, and Reporting at Post-Secondary Institutions

Context and Purpose: Ontario’s publicly assisted colleges and universities are required by law to maintain standalone SV policies, but there are currently no province-wide standards governing how those policies are implemented. Institutions are not required to ensure that staff responsible for intake or support receive trauma-informed training, nor are they required to report publicly on disclosure patterns, case resolution processes, or student satisfaction. A lack of implementation standards and accountability measures undermines the effectiveness of campus sexual violence responses and contributes to low disclosure rates.

Jurisdiction: The Ministry of Colleges and Universities (MCU), under s. 15.1 of the Ministry of Training, Colleges and Universities Act.

Recommendation: The Government of Ontario should establish minimum implementation and reporting standards for post-secondary sexual violence policies. These should apply to all publicly assisted colleges and universities and should include:

• Mandatory trauma-informed training for all staff responsible for sexual violence intake or case coordination;
• Clear institutional documentation of reporting pathways, available accommodations, and survivor rights;
• Annual public reporting by institutions on the number and type of disclosures received, how disclosures were handled, and outcome categories; and
• Standardized templates or reporting structures to support comparability across institutions.

Implementation Considerations: The Ministry may wish to consult with student associations, sexual violence prevention experts, and institutional equity offices to determine appropriate thresholds and delivery formats. Institutions vary in size, structure, and resources; implementation timelines or reporting mechanisms may need to account for institutional differences. Where institutions have existing trauma-informed training protocols, the Ministry may consider recognition of equivalent programs. Private institutions are not subject to these requirements but may be encouraged to voluntarily adopt similar practices.

Rationale: Clear, consistent, and trauma-informed implementation of sexual violence policies is essential to building student trust and ensuring that survivors receive appropriate support. Minimum provincial standards would improve clarity, comparability, and accountability across institutions and help ensure that sexual violence policies are not only maintained but meaningfully implemented. Public reporting also enables monitoring of disclosure trends and service needs while reinforcing transparency and institutional responsibility.

5.6.7 Recommendation 7: Support Sectoral Engagement in Violence Prevention Through Professional Consultation and Shared Training Resources

Context and Purpose: Ontario’s Domestic Violence Death Review Committee (DVDRC) has repeatedly identified missed intervention opportunities across a wide range of regulated professions and public-facing sectors, including education, health care, law enforcement, veterinary services, real estate, law, and corrections. While some regulatory colleges and associations have developed sector-specific IPV or SV guidance, there is no provincial structure for coordinated outreach, consultation, or voluntary training uptake. The province cannot impose mandatory training on all regulated professions, but it can facilitate sector engagement and offer consistent, evidence-informed resources.

Jurisdiction: The Ministry of Children, Community and Social Services would likely take the lead, but this recommendation implicates nearly all provincial ministries. Effective implementation will require coordinated inter-ministerial planning to ensure appropriate outreach, sectoral alignment, and accountability across the full range of affected professional domains.

Recommendation: The Government of Ontario should initiate a structured consultation process with regulatory colleges, sectoral associations, and federations representing professions named in DVDRC reports. This process should:

• Invite professional regulators to identify opportunities for improving IPV, SV, and HT training in their respective sectors;
• Provide model content, short modules, and reference materials aligned with current research and trauma-informed practice;
• Support integration of optional IPV/SV/HT training into continuing professional development (CPD) frameworks, where applicable;
• Encourage voluntary adoption of shared content, hosted through Ontario’s public education infrastructure (see Recommendation 5).

Implementation Considerations: Consultation design should reflect the diversity of professional governance structures across Ontario. Some professions (e.g., physicians, teachers, social workers) are regulated by formal colleges under provincial statute; others (e.g., realtors, lawyers) operate under separate governance or licensing frameworks. Not all sectors are bound by CPD requirements. Implementation should avoid prescriptive measures and focus on identifying interest, promoting uptake, and building sector readiness. Where professions are already delivering IPV- or SV-specific training, the Ministry may consider formal recognition or integration of that work into broader prevention infrastructure.

Rationale: DVDRC reports consistently identify missed risk detection or response opportunities across multiple professions. While the province cannot mandate training for all sectors, it can lead a coordinated engagement strategy and provide reliable, high-quality training content that supports voluntary adoption. Shared infrastructure and cross-sector alignment will improve consistency, support early disclosure, and expand violence prevention capacity across Ontario’s professional landscape. In sectors with frequent public contact, this may include bystander response principles aligned with broader public education strategies on IPV and SV prevention.

5.6.8 Recommendation 8: Reinvest in and Modernize Ontario’s Public Education Infrastructure on IPV

Context and Purpose: Ontario does not currently maintain a centralized public education infrastructure to support violence prevention efforts across community, education, settlement, health, or justice sectors. Legacy campaigns such as Neighbours, Friends and Families (NFF) and the Learning Network (LN), hosted by CREVAWC at Western University, have formed the core of the province’s multilingual, rights-based education strategy on intimate partner violence. However, both platforms are scheduled to lose MCCSS funding in 2026, and no replacement infrastructure has been identified. In the absence of provincial coordination, materials used across schools, shelters, police services, and newcomer-serving agencies remain inconsistent, inaccessible, and duplicative.

Jurisdiction: Ministry of Children, Community and Social Services, in collaboration with the Ministry of Education, Ministry of Citizenship and Multiculturalism, the Ministry of the Solicitor General, and the Ministry of the Attorney General.

Recommendation: The Government of Ontario should reinvest in and modernize its public education infrastructure on IPV, SV, and HT through the development of a centralized platform capable of producing, hosting, and distributing multilingual, evidence-informed prevention content. The platform should:

• Provide open-access prevention resources for use across schools, shelters, community agencies, and service sectors;
• Update and digitize existing content developed under NFF and LN, with usability improvements and modernization of visual materials;
• Support the development of new campaign themes and culturally tailored content through partnerships with trusted community-based organizations;
• Explore the licensing or collaborative incorporation of evidence-based content from aligned public education initiatives (e.g., White Ribbon, Moose Hide Campaign, MentorAction, Futures Without Violence);
• Enable translation and distribution of content across newcomer, francophone, rural, and culturally specific service settings.

Implementation Considerations: The Ministry may need to determine how to maintain continuity of access if current platforms are discontinued. Options for hosting, governance, and content maintenance should be assessed to ensure the long-term stability and availability of prevention resources. Private and independent institutions, while not subject to direction, may be encouraged to use the platform’s resources for internal training, outreach, and public education.

Rationale: Ontario’s current prevention landscape lacks a centralized mechanism to ensure quality, consistency, and accessibility of public-facing educational materials on IPV, SV, and HT. Reinvestment in this infrastructure would support cross-sector alignment, reduce duplication, and allow government, community, and institutional partners to deliver evidence-informed content using common, accessible tools. The foundational work of NFF and LN provides a cost-efficient basis for renewal, and their scheduled funding expiry in 2026 creates both an opportunity and an imperative for modernization.

5.6.9 Recommendation 9: Develop and Disseminate Culturally and Linguistically Tailored Public Education Tools on IPV, SV, and HT

Context and Purpose: Ontario does not currently maintain a coordinated system for developing and distributing culturally and linguistically tailored public education materials on IPV, SV, or HT. While past initiatives such as Neighbours, Friends and Families (NFF), the Learning Network (LN), and OCASI’s immigrant and refugee community (IRC) variant have produced widely used multilingual tools, existing content cannot fully reflect the breadth of cultural, religious, and linguistic contexts present in Ontario today. Institutions across education, health, shelter, and newcomer service sectors often require additional support to access, adapt, or apply public education content in ways that resonate with diverse communities.

Jurisdiction: Ministry of Children, Community and Social Services, in collaboration with the Ministry of Citizenship and Multiculturalism, Ministry of Health, Ministry of Education, and other relevant partners.

Recommendation: The Government of Ontario should partner with sector leaders to relaunch what is currently known as Neighbours, Friends and Families (NFF) as a fully resourced, standalone public education platform with dedicated staffing and cross-sector delivery infrastructure. This expanded initiative should be developed and delivered through a broad partnership model, with the Centre for Research & Education on Violence Against Women & Children (CREVAWC) serving as a lead partner and evaluator, and multiple cultural, faith-based, newcomer-serving, and Indigenous organizations contributing to content development, translation, and community outreach.

Part 3: Justice Reform

Part 3 addresses mandatory charging and early intervention programming, court and compliance reform, compliance monitoring, risk assessments, civil legal remedies for victims, the role of family court, animal cruelty and the link to IPV, and firearms and intimate partner violence in Ontario.

Section 1: Mandatory Charging & Early Intervention Programming

1.1 Mandatory Charging in Ontario

1.1.1. Background and Policy Framework

Mandatory charging policies in Ontario were introduced in the 1980s and 1990s as part of a broader national shift toward standardizing police responses to intimate partner violence (IPV). At the time, under-enforcement of domestic violence offences was widely identified as a systemic problem across Canada. In response, provinces began adopting policies requiring police to lay charges in IPV cases where reasonable grounds existed, regardless of whether the victim wished to proceed.

Ontario’s current framework continues to reflect this approach. Under the Ministry of the Solicitor General’s Policing Standards Manual – LE-024, police officers are instructed to lay charges in all domestic violence occurrences where there are reasonable grounds to believe an offence has been committed. LE-024 specifies that the officer’s duty to lay a charge is not affected by:

• The victim’s unwillingness to attend court,
• The officer’s belief that the victim will not cooperate,
• Verbal assurances that the violence will stop,
• The parties’ relationship status or past history,
• The likelihood of conviction.⁵¹³

Mandatory charging policies are supported by many victim advocacy organizations, particularly where consistent enforcement is viewed as a protective measure for victims who may be under duress or facing retaliation. Some have continued to endorse mandatory charging as a necessary safety mechanism, particularly where risk of harm remains high and victim cooperation is limited. At the same time, the policy has been the subject of sustained critique—particularly in cases involving verbal-only incidents, mutual accusations, or situations where the victim is later arrested as the primary aggressor.⁵¹⁴

The current policy landscape reflects a tension between consistency and complexity. While mandatory charging ensures a baseline response across jurisdictions, it does so in a legal and operational environment that remains highly variable.

1.1.2. Documented Consequences of Mandatory Charging in Practice

Ontario’s mandatory charging policy applies uniformly to all domestic violence occurrences where officers have reasonable grounds to believe an offence has been committed. While intended to ensure consistent enforcement, this uniformity has produced several operational consequences that have been documented in academic research, policy evaluations, and expert submissions.

Multiple sources confirm that dual charging—where both parties in an IPV incident are charged—is a known outcome of mandatory charging policies. This may occur in situations involving defensive self-protection, verbal-only disputes, or mutual accusations where the primary aggressor is not clearly identified. When officers are not trained to recognize coercive control or contextual dynamics, victims may be misidentified as aggressors and charged in error.⁵¹⁵

Victim accounts and longitudinal research have further identified concerns with how mandatory charging is experienced in practice. In jurisdictions where mandatory charge and prosecution policies have been in place for decades, some victims report that criminal justice involvement may feel disempowering or punitive, particularly when they did not seek intervention or have specific goals unrelated to prosecution.

Empirical studies further suggest that mandatory charging may contribute to re-traumatization in low-severity cases. Victims may experience arrest or legal involvement as punitive, especially when they did not seek police intervention or do not wish to proceed with charges.⁵¹⁶ Racialized victims of intimate partner violence describe stigma, cultural isolation, and hesitation to seek support from formal systems due to institutional mistrust and fear of escalated consequences.⁵¹⁷

Studies of police practice in Ontario and elsewhere indicate that application of the mandatory charging framework is not always consistent. A 2020 Ontario-based field study of police use of the ODARA found that the tool was used in only 60.3% of reviewed IPV cases, and that officers were more likely to use it when there was physical violence (70.6%) or evidence of weapon use (84.2%).⁵¹⁸

1.1.3. Documented Limits of Mandatory Criminalization – Victim Hesitancy and Alternative Pathways

Mandatory charging and no-drop prosecution policies were introduced to address the historic under-enforcement of IPV and ensure that responsibility for legal action did not fall solely on the victim. While these policies were intended to provide a consistent and protective response, a substantial body of research and victim testimony has identified systemic concerns that extend beyond individual misapplication.

1.1.3.1. Documented Concerns About Mandatory Criminalization from Victims

Academic and policy literature has consistently documented victim concerns about the practical and emotional impacts of mandatory charging and prosecution policies. Leigh Goodmark has written that prioritizing safety and accountability through mandatory prosecution policies can be disempowering in depriving “individual women of the self-determination and self-direction that are essential for autonomy and empowerment.”⁵¹⁹

Victims may decline to proceed with charges, withhold statements, or attempt to de-escalate situations—only to become targets of police action themselves when dual charges are laid or when officers lack clear protocols for distinguishing primary aggressors.⁵²⁰

1.1.3.2. Alternative Models of Response: Restorative, Community-Based, and Diversionary

Over the past two decades, researchers, community agencies, and some legal scholars have proposed and, in limited cases, piloted alternative models for responding to IPV. These include restorative justice forums, police-to-service referral pathways, second responder programs, and early intervention frameworks rooted in risk mitigation rather than criminal prosecution.

Restorative justice models, often facilitated in community-based or culturally specific settings, aim to create space for victims to name harm, identify safety goals, and determine accountability measures in a manner that reflects their values.⁵²¹ Second responder models operate at an earlier stage in the intervention continuum, involving follow-up by a social worker, counsellor, or domestic violence advocate shortly after a police-reported incident.⁵²²

1.1.3.3. Evaluative Evidence: Benefits and Limitations

The evidence base for these models is mixed but growing. While there is insufficient evidence to show a clear impact on long-term recidivism, second responder and referral models were designed to help victims improve perceptions of safety and increase the likelihood that services and safety planning are accessed.⁵²⁴

1.1.4. Ontario’s Current Position: No Scalable Alternatives in Place

At present, Ontario does not have a provincial infrastructure to support any of these alternative models at scale. While some police services—such as Waterloo Regional Police Service and Windsor Police—have participated in early intervention or counselling referral pilots⁵²⁵, these programs are not available province-wide, are not mandated or tracked, and have no dedicated funding stream.

1.1.5. Officer Discretion Without Structure – Gaps in Current Capacity

In the absence of a mandatory charging policy, frontline police officers would be expected to exercise discretion in real time, including: determining who the primary aggressor is in complex or dual-accusation incidents; conducting risk assessments at the scene; and making appropriate referrals to external support services or diversionary programs. These functions require a foundation of structured policy, consistent training, and operational infrastructure that is not currently in place across Ontario.

The LE-024 provincial policing standard does not mandate any specific methodology or tool for primary aggressor identification.⁵²⁶ Structured risk assessment tools—such as the ODARA, the Domestic Violence Risk Management (DVRM) tool, and the Brief Spousal Assault Form for the Evaluation of Risk (B-SAFER)—have been developed to support more standardized police response in IPV cases, but tool usage varies widely across jurisdictions.

1.1.6. Police Training on Intimate Partner Violence – Scope and Gaps

Ontario does not currently mandate standardized or recurrent training on IPV for police officers after initial certification. While some instruction is provided during intake at the Ontario Police College (OPC), there is no provincial directive requiring post-certification updates, in-service refreshers, or service-level alignment in how IPV content is delivered. As a result, the depth, frequency, and scope of training vary widely across police services.

1.2 Early Intervention and Second Responder Models

1.2.1. Context and Rationale

Ontario’s criminal justice system routinely absorbs repeat contact with individuals involved in IPV cases that do not result in criminal charges. These cases account for a significant proportion of police workload but are functionally invisible within the formal legal process. In the absence of structured intervention, this cycle often continues until a serious offence occurs—or until the individuals disengage entirely from services, despite ongoing risk.

1.2.2. Program Archetypes: Clarifying Terminology

Across Ontario, several police services have implemented programs intended to interrupt this cycle of uncharged but escalating IPV risk. Early intervention programs (EIPs) are typically data-driven, identifying individuals or couples with repeated police-involved IPV calls over a defined period.⁵²⁷ Second responder models are event-based, typically involving a scheduled follow-up visit by a police officer and a support worker within 24 to 72 hours of an IPV-related call.⁵²⁸

1.2.3. The Waterloo EIP (WRPS & WCSWR): A Structured, Scalable Model

Waterloo Region currently operates the most structurally mature early intervention model in Ontario. The Early Intervention Program (EIP), launched in 2022 as a partnership between the Waterloo Regional Police Service (WRPS) and Women’s Crisis Services of Waterloo Region (WCSWR), targets couples with two or more police-involved IPV calls within 60 days, regardless of whether charges were laid.⁵²⁹

In 2023, WRPS identified over 430 successful connections and recorded an 87.6% reduction in IPV-related police calls within two months, and a 71.3% reduction at six months following the intervention.⁵³⁰

1.2.4. The Windsor/FSWE Pilot: Early Referral with Less Structure

A limited early intervention pilot has also been reported in Windsor, operated by local police in partnership with Family Services Windsor-Essex. The initiative is described as a referral-based model without embedded data tracking or integration infrastructure. No published outcome data is available currently.

1.2.5. Provincial Fragmentation and the Infrastructure Gap

There is currently no central authority in Ontario responsible for tracking or supporting second responder or early intervention programs.

1.2.6. Economic Value and System Relief Potential

Early intervention and second responder programs offer the potential to reduce downstream costs associated with repeated police response, emergency services, court processing, and crisis-level service engagement.

1.2.7. Implementation Requirements and System Design Implications

Effective early intervention requires more than program design. It depends on infrastructure including data integration between police records and community agencies, standardized risk assessment tools, and structured referral pathways with accountable follow-up mechanisms.

1.3 Provincial Standards and the LE-024 Directive on Domestic Violence Occurrences

1.3.1. Ontario’s Current Standard on Police Response to Domestic Violence

Ontario’s policing standards for domestic violence occurrences are set out in the Ministry of the Solicitor General’s Policing Standards Manual, specifically LE-024. The directive establishes core expectations for how police services respond to domestic violence calls, including mandatory charging where reasonable grounds exist.

1.3.2. Content of the Directive

LE-024 outlines protocols for evidence gathering, scene separation, risk factor documentation, and victim assistance. It recommends that Domestic Violence Investigators have Ministry-accredited training.

1.3.3. Absence of Monitoring and Evaluation Mechanisms

The directive does not establish a mechanism for provincial oversight, nor does it prescribe mandatory risk tools or inter-agency data integration. Implementation varies across services, and there is no central tracking of compliance or outcomes.

1.4 Ontario’s Current System Gaps – No Alternative Infrastructure Yet Exists

1.4.1. Inconsistent Police Training on Domestic Violence and Coercive Control

Training on IPV, coercive control, and trauma-informed response varies significantly across Ontario’s police services. No standardized recurrent training curriculum exists at the provincial level.

1.4.2. Absence of a Primary Aggressor Protocol

Ontario lacks a province-wide mandatory protocol for primary aggressor identification, contributing to dual-charging situations and victim misidentification.

1.4.3. Lack of Referral Pathways for Second Responder or Early Intervention Programs

No provincial framework exists for police referrals to early intervention or second responder programs.

1.4.4. Absence of Integrated Data Systems Between Police, Crown, and Victim Services

Police, Crown attorneys, and victim services operate on separate, non-integrated data systems, limiting risk visibility and coordinated response.

1.4.5. Structural Consequences of Discretion Without Infrastructure

Without supporting infrastructure, officer discretion in IPV cases remains constrained. The binary choice between laying charges and taking no action leaves a significant gap in the province’s response capacity.

1.5 Alternative Models Exist, But Cannot Yet Be Safely Implemented

1.5.1. Defining the Landscape – What Counts as an “Alternative Model”

Alternative models for responding to IPV include restorative justice forums, second responder programs, early intervention referral pathways, and community-based diversionary programs. These models share common features: voluntary participation, victim consent, harm reduction focus, and integration of social service supports.

1.5.2. Early Intervention and Second Responder Models – Promise and Limits

Early intervention models such as the Waterloo EIP have shown promising initial results but remain localized. Province-wide scaling requires standardized protocols, dedicated funding, and integration with existing justice and community infrastructure.

1.5.3. Restorative Justice in IPV/SV – Theory and Practice

Restorative justice approaches in IPV cases remain controversial due to concerns about power imbalance and minimization of harm. However, some jurisdictions have piloted their use in low-severity, early-stage incidents under strict procedural safeguards.

1.5.4. Legal and Operational Barriers to Implementation

Current legal frameworks in Ontario do not include provisions for domestic violence diversion. No legislative authority exists to divert IPV cases from the criminal justice system in a structured or accountable manner.

1.6 Recommendations

1.6.1. Recommendation 1: Retain Ontario’s Mandatory Charging Policy for IPV, with a Structured Five-Year Review Timeline

Context and Purpose: Ontario’s mandatory charging policy for IPV was introduced to address decades of underenforcement, systemic minimization, and police reluctance to intervene in domestic violence cases. The policy directs officers to lay charges where reasonable grounds exist, regardless of victim cooperation or willingness to proceed. This baseline enforcement standard has been supported by many victims’ organizations and public safety advocates.

At the same time, sustained concerns have been raised—both through academic research and victim testimony—about how mandatory charging operates in practice. These include dual charging, victim misidentification, re-traumatization, and loss of agency. Many of these concerns stem not from the principle of mandatory enforcement itself, but from the absence of structured supports: consistent risk tools, primary aggressor protocols, community referral infrastructure, and officer training on coercive control.

Ontario does not currently have the infrastructure necessary to support safe, consistent, and risk-informed discretion. In the absence of that foundation, removing or weakening the mandatory charge requirement would increase the risk of both under-enforcement and inconsistent outcomes. This recommendation affirms the retention of the mandatory charging policy while setting out a five-year timeline for review, contingent on implementation of the broader recommendations outlined in this report.

Jurisdiction: The mandatory charging policy is reflected in LE-024: Policing Standards Manual – Domestic Violence Occurrences, issued by the Ministry of the Solicitor General. While it is not a statute or regulation, it is a directive that all police services in Ontario are expected to follow. Any formal review of the policy should be conducted by the Ministry of the Solicitor General, in consultation with the Ministry of the Attorney General, MCCSS, and relevant community and justice system stakeholders. This review should be supported by outcome data collected through hub-level tracking, Crown referral practices, and program participation records.

Recommendation:

The Government of Ontario should retain its current mandatory charging policy for intimate partner violence under LE-024 and commit to a formal policy review in five years. The review should:

• Be contingent on the implementation of key supporting infrastructure, including:
  • Mandatory risk assessment tools in all IPV occurrences (Recommendation 3);
  • A standardized provincial police training curriculum (Recommendation 4);
  • Province-wide early intervention programming (Recommendation 5);
  • Primary aggressor protocols and enhanced LE-024 standards (Recommendation 2);
• Include consultation with justice system actors, victims’ groups, and frontline police services;
• Be informed by province-wide data on dual charging, program referral patterns, and risk tool usage.

This review would not pre-commit to repeal or modification of the policy, but would assess whether Ontario has reached a point where structured discretion can safely replace mandatory charge requirements.

Implementation Considerations:

• Any review timeline must be linked to real infrastructure benchmarks. If the necessary supports are not in place within five years, the review timeline should be adjusted accordingly.
• Victim-serving organizations and Indigenous justice bodies must be meaningfully consulted during the review process, including those who support the continuation of mandatory charging.
• The Ministry of the Solicitor General will require outcome data from OIVPRN hubs, police services, and program tracking systems in order to support evidence-informed review.
• Retaining the current policy does not preclude further modernization of LE-024 (see Recommendation 2), which should be updated immediately to reflect training, risk tool, and referral protocol expectations.

Rationale: Mandatory charging has created a consistent enforcement baseline across Ontario, but it is not a perfect policy. In the absence of structured alternatives, however, it remains necessary. This recommendation affirms that Ontario must not dismantle the only province-wide protective mechanism in place without first building the infrastructure required to support safe and consistent discretion. By committing to a five-year review contingent on the implementation of these foundational supports, the province can address longstanding concerns about the policy while maintaining its core public safety function in the interim.

1.6.2. Recommendation 2: Modernize and Enforce Directive LE-024 on Domestic Violence Occurrences

Context and Purpose: Directive LE-024, Ontario’s provincial policing standard on domestic violence occurrences, was last substantively updated in 2013. It remains the central policy instrument governing police response to IPV, including mandatory charging, evidence collection, coordination with victim services, and documentation. While the directive reflects many evidence-informed practices, it has not kept pace with current knowledge, and its implementation is not monitored or enforced.

LE-024 does not currently require the use of structured risk assessment tools. It makes no reference to coercive control, primary aggressor identification, or animal harm. It does not establish minimum training standards or refresher expectations. And it contains no requirement that police services designate a Domestic Violence Coordinator. Without these core structural elements, implementation varies across jurisdictions—contributing to inconsistent enforcement, missed risk identification, and uneven access to intervention and referral pathways.

This recommendation proposes an immediate modernization of LE-024 to reflect current evidence-informed practice. It does not propose removing the mandatory charging provision (see Recommendation 1) but does require the directive be updated to include risk tools, training, documentation standards, and a basic compliance mechanism.

Jurisdiction: LE-024 is issued under the authority of the Ministry of the Solicitor General. The Ministry is responsible for updating the directive and determining its scope of application. The directive applies to all municipal and First Nations police services in Ontario.

Recommendation:

The Government of Ontario should immediately modernize Directive LE-024 to reflect current evidence-informed standards in domestic violence policing. The revised directive should:

• Mandate the use of the ODARA risk assessment tool in all IPV-flagged occurrences, with recommended use of DVRM in complex or high-risk cases;
• Require documentation of coercive control indicators and animal-related risk signals in occurrence reports;
• Mandate adoption of a province-wide primary aggressor identification protocol;
• Require that all officers responding to domestic violence calls have completed standardized IPV-specific training (see Recommendation 4), including training on risk tools, coercive control, animal harm, and referral logic;
• Mandate that every police service designate a Domestic Violence Coordinator, responsible for file continuity, system navigation, and internal case flagging;
• Establish clear expectations for referrals to second responder or early intervention programming, where available;
• Include a monitoring mechanism consisting of:
  • Internal service-level tracking of ODARA use and primary aggressor determinations;
  • Documentation fields for confirming directive compliance;
  • Basic audit or review expectations at the service level;
• As referenced in other recommendations, the updated LE-024 should also incorporate a mandatory charging requirement for specified Criminal Code animal cruelty offenses. This recommendation is made elsewhere in the report based on similar logic: early identification of escalating behaviour and risk mitigation through consistent enforcement.

Implementation Considerations:

• Police services may require time to revise internal protocols, train officers, and adjust case tracking systems. The Ministry of the Solicitor General must develop clear implementation tools and timelines.
• The monitoring mechanism is intended to support fidelity and internal accountability—not external sanction.
• Any modernization must include clear language, prescriptive obligations, and accompanying documentation templates or checklists to support adoption.
• Services that have already implemented some components of the revised directive may require minimal transition; others will require more substantial support.

Rationale: LE-024 is no longer sufficient to guide or standardize police response to intimate partner violence in Ontario. The absence of a requirement for core risk tools, case documentation standards, training protocols, or structural supports has contributed to system-wide inconsistency. Modernizing LE-024 is essential not only to supporting the existing mandatory charging framework, but also to ensuring that risk is identified earlier, referrals are used appropriately, and officers are equipped to respond to the complexity of IPV cases. This recommendation is a foundational precondition to safe system reform.

1.6.3. Recommendation 3: Mandate Use of Structured Risk Assessment Tools in All IPV-Flagged Occurrences

Context and Purpose: Validated risk assessment tools such as the Ontario Domestic Assault Risk Assessment (ODARA) and the Domestic Violence Risk Management (DVRM) tool are foundational to modern, risk-informed responses to IPV. ODARA is an actuarial tool that predicts the likelihood of reoffending, while DVRM is a structured professional judgment tool that supports deeper case analysis, safety planning, and supervision decisions in complex or high-risk situations.

Despite their availability, use of these tools in Ontario remains inconsistent. Studies have shown that ODARA is completed in only a portion of eligible cases, with usage skewed toward incidents involving visible injury or weapons. DVRM is used sporadically and typically only where a designated officer has the time, training, and role clarity to apply it. In many jurisdictions, neither tool is mandated, and officers are left to rely on subjective assessments that vary widely across services and individuals.

This recommendation mandates the use of ODARA in all IPV-flagged occurrences and establishes DVRM as the standard follow-up tool in complex or high-risk cases. These requirements will be implemented directly through the modernization of LE-024 (see Recommendation 2) and embedded in police occurrence documentation, officer training, and case review processes.

Jurisdiction: The Ministry of the Solicitor General holds the authority to update LE-024 and to require the use of specific investigative tools under its provisions.

Recommendation:

The Government of Ontario should amend Directive LE-024 to require the consistent use of structured risk assessment tools in all IPV-flagged police occurrences. The revised directive should:

• Require that ODARA be completed and scored in all IPV-flagged occurrences, regardless of whether charges are laid;
• Recommend that DVRM be completed in cases flagged as moderate- or high-risk by ODARA, or where case complexity warrants additional assessment;
• Assign DVRM responsibility to designated personnel, such as Domestic Violence Coordinators or supervisory officers—not to frontline patrol staff during initial response;
• Require that all officers responsible for completing ODARA or DVRM receive appropriate training and certification;
• Mandate inclusion of risk tool outcomes in occurrence documentation, Crown briefs, safety planning referrals, and hub-level coordination;
• Build compliance tracking into LE-024’s monitoring structure, including documentation fields and internal service-level review protocols.

Implementation Considerations:

• Smaller services may require transitional support to train designated staff and integrate tool usage into local practice;
• Electronic report templates will need to be updated to include ODARA and DVRM data fields, and to flag missing or incomplete entries;
• Ministry guidance should clearly delineate when DVRM is expected, and which roles are authorized to complete it;
• Consistent tracking of tool usage must be part of LE-024’s service-level monitoring framework.

Rationale: Structured risk assessment is essential to identifying lethality risk, prioritizing interventions, and ensuring that police responses to IPV are grounded in evidence—not assumption. ODARA provides standardized risk triage across all occurrences. DVRM adds contextual depth when required. Without these tools, Ontario cannot build a coherent early intervention, safety planning, or accountability infrastructure. Embedding both tools directly into LE-024 ensures that their use becomes a core feature of every IPV response—not a discretionary add-on.

1.6.4. Recommendation 4: Implement a Core Provincial IPV Training Curriculum for Police, with Recurrent Requirements

Context and Purpose: Ontario does not currently require police services to deliver standardized or recurrent training on intimate partner violence (IPV). Initial exposure is provided at the Ontario Police College (OPC), but the content is foundational only. There is no provincial curriculum for post-certification training, no refresher interval, and no mandate for officers to receive education on coercive control, non-physical abuse, primary aggressor identification, or risk assessment tools.

This gap has operational consequences. Officers may go years—or entire careers—without updated instruction on IPV dynamics, despite responding to hundreds of domestic calls annually. Without training, officers are less likely to identify psychological abuse, animal harm, or escalating coercive control. They are also less likely to use validated risk tools correctly, document contextual factors, or recognize self-defensive violence.

This recommendation establishes a mandatory, standardized IPV training curriculum for all police services, supported by recurring certification intervals and directly tied to LE-024 compliance. The goal is to ensure that all officers who respond to domestic violence calls have the skills, knowledge, and judgment to do so effectively.

Jurisdiction: The Ministry of the Solicitor General holds authority over police training directives and LE-024.

Recommendation:

The Government of Ontario should implement a mandatory provincial training curriculum on intimate partner violence for all police services, with recurrent requirements. The training framework should:

• Be required for all officers who respond to domestic violence calls;
• Include post-certification onboarding for new recruits and refresher training at least once every three years;
• Cover the following core areas:
  • Coercive control and non-physical abuse
  • Primary aggressor identification
  • Animal harm as a risk indicator
  • ODARA and DVRM scoring and interpretation
  • Risk-informed documentation and referral protocols
• Be delivered by accredited instructors using approved content, with flexibility for regional adaptation where necessary;
• Be integrated into the LE-024 directive as a mandatory component of directive compliance;
• Require services to track completion internally and provide verification on request.

Implementation Considerations:

• Some services may need funding to support training officer capacity or contract with external providers;
• OPC may require additional instructors, course development time, and partnership arrangements to deliver the curriculum across the province;
• Existing training content developed by police services, DV coordinators, or external trainers should be reviewed for consistency with the provincial standard;
• Training completion should be logged in a format that allows service-level tracking and future provincial verification.

Rationale: Police response to IPV requires ongoing, structured training—not one-time exposure. Without a core curriculum, officers remain unequipped to recognize coercive control, apply risk tools, or distinguish primary aggressors in complex incidents. Without refreshers, skills atrophy. This recommendation ensures that all officers who respond to IPV calls have a shared foundation of knowledge, consistent with modern risk models, trauma-informed practice, and Ontario’s legal obligations. It is not an optional professional development activity—it is a core public safety requirement.

1.6.5. Recommendation 5: Establish a Province-Wide Early Intervention Program (EIP) Funding Stream Based on the Waterloo Model

Context and Purpose: Ontario’s criminal justice system frequently encounters repeat IPV-related police calls involving the same individuals or couples—often without charges being laid. These cases occupy significant policing and system resources, but without charges, they fall into an operational gap: no mandated response, no case management, no structured accountability or support.

The Early Intervention Program (EIP) operated by Waterloo Regional Police Service (WRPS) and Women’s Crisis Services of Waterloo Region (WCSWR) offers a scalable model to address this gap. It identifies couples with two or more IPV-related police calls in a short period (e.g., 60 days) and initiates voluntary outreach, case management, and connection to supports. Administrative data from WRPS shows an 87.6% reduction in IPV-related calls at two months post-intervention, and a 71.3% reduction at six months—outcomes based on system data, not self-report.

At present, no province-wide funding stream or standard exists for EIP implementation. Local pilots depend on temporary grants or informal agreements. This recommendation establishes a provincial funding framework for police services and community agencies that adopt the core features of the Waterloo model and commit to standardized outcome tracking.

Jurisdiction: The funding stream should be administered by MCCSS in partnership with the Ministry of the Solicitor General.

Recommendation:

The Government of Ontario should establish a province-wide funding stream for Early Intervention Programs (EIPs) based on the Waterloo model. To qualify for funding, jurisdictions must:

• Use a pattern-based threshold for identification (e.g., two or more IPV-related police calls in 60 days), rather than case-by-case discretion;
• Assign police and a community partner agency to deliver voluntary, structured outreach to both parties;
• Offer referrals to appropriate supports, including victim services and, where available, programming for men who use harm;
• Partner with their OIVPRN hub to support coordination, case flagging, and ongoing service alignment;
• Agree to collect and report standardized data on referral, uptake, and subsequent police contact using shared outcome templates.

Co-funding will be required from participating police services and municipalities. Provincial funds will prioritize regions with limited capacity to absorb new costs.

Implementation Considerations:

• Not all jurisdictions will have access to men’s programming or community partners capable of supporting EIP delivery. In these areas, early intervention may be limited to victim outreach and police flagging until additional infrastructure is in place.
• Standardized data collection will require development of shared forms, coding conventions, and reporting templates to allow province-wide analysis of effectiveness.
• Hubs will require administrative funding to support service mapping, EIP coordination, and data verification.
• While participation is voluntary, funded programs must implement the model faithfully. This is not a discretionary service design exercise or one-time pilot.

Rationale: EIP models offer one of the only proven, measurable interventions for pre-charge IPV cases involving repeated police contact. The Waterloo program provides a template that is structured, non-adversarial, and trackable—and that shows meaningful reductions in future harm and system contact. A province-wide rollout of this model, backed by structured funding and standardized data collection, represents a high-ROI prevention strategy. It addresses the grey area between victim support and criminal enforcement—helping systems intervene before charges are laid, victims disengage, or harm escalates.

1.6.6. Recommendation 6: Designate Second Responder Programs as a Provincially Supported Best Practice

Context and Purpose: Second responder programs offer a structured follow-up to IPV incidents shortly after police have responded to a call—regardless of whether charges were laid. These programs are event-based: they are activated by a specific incident, not by a pattern of repeated calls. Typically, a police officer and a community-based partner conduct a scheduled follow-up visit within 24 to 72 hours, a window associated with increased victim engagement, service uptake, and early-stage risk reduction.

Second responder programs are distinct from early intervention programs (EIPs). While EIPs are pattern-based and often involve proactive outreach to both parties in repeated-call situations, second responder programs focus primarily on victims and are activated by a single incident. Both models are valuable, but they serve different purposes and are structured differently. In Ontario, second responder models are inconsistently implemented and poorly supported. This recommendation recognizes them as a provincially supported best practice and outlines a framework for sustainable expansion.

Jurisdiction: Primary responsibility rests with the Ministry of the Solicitor General, in collaboration with the Ministry of Children, Community and Social Services, to develop standardized guidance and fund service partnerships through local police services and community-based agencies.

Recommendation:

The Government of Ontario should designate second responder programs as a provincially supported best practice and encourage their expansion through standardized guidance and targeted financial support. Provincial support should include:

• Standard model guidance, including:
  • A structured response window of 24 to 72 hours post-incident
  • A two-person team model involving one police officer and one community partner (e.g., shelter or VAW agency staff)
  • Standard occurrence coding or flagging to enable timely follow-up
  • Shared documentation tools, referral protocols, and safety planning resources
• Targeted provincial incentive funding to support service establishment and early implementation, especially in low-capacity jurisdictions;
• A co-funding model, with municipalities and police services contributing to program delivery;
• Hub-level coordination or support to ensure program fidelity, service mapping, and shared learning.

Implementation Considerations:

• Not all jurisdictions will have immediate access to qualified community partners. In these cases, regional hub agencies or mobile response teams may be required.
• OIVPRN hubs will require administrative support to assist with startup planning, documentation standardization, and inter-agency coordination.
• Police services will require guidance on budgeting, role clarity, and partnership development.
• Second responder programs should be treated as emerging core services, not short-term pilots. Their impact should be tracked and incorporated into future system planning.

Rationale: Second responder programs offer a low-barrier way to reach victims early—before disengagement, escalation, or repeat calls occur. They are not diversionary or rehabilitative tools, and they are not substitutes for enforcement. They are an early safety intervention that complements broader system reforms, including early intervention programs and standardized risk assessment. By recognizing these models as a provincial best practice, supporting their structure, and enabling cost-shared implementation, Ontario can strengthen its early response to IPV without creating new legislative complexity or program duplication.

Section 2: Court and Compliance Reform

2.1 The Role of the Crown and Structural Limits on Justice System Performance

2.1.1 Prosecutorial Discretion and the Architecture of Criminal Law

Crown attorneys in Ontario occupy a distinct constitutional role. They are not advocates for the victim or the police, but ministers of justice whose primary obligation is to the fair administration of the criminal law. This principle, affirmed by the Supreme Court of Canada in Boucher v The Queen (1955) and reiterated in R v Regan (2002), shapes every stage of the prosecution process—from screening charges to making bail submissions to presenting evidence at trial.

In practice, this means Crown attorneys must assess each case not only on the strength of the evidence, but through the lens of public interest. When deciding whether to proceed with a charge, a Crown must consider the likelihood of conviction, the gravity of the offence, the impact on the victim, and the broader implications for the justice system. In bail proceedings, the Crown’s role is not simply to oppose release but to present the court with a fair and complete picture of the risk posed by the accused, drawing on the information available at the time.

This role is constrained by structural realities. Crown attorneys do not investigate offences. They rely on the quality of information provided by police. If an occurrence report lacks detail, if a risk assessment was not completed, or if prior history is unavailable through CPIC or local records, the Crown’s ability to make informed submissions is diminished. The quality of the prosecution at every stage—bail, trial, and sentencing—is ultimately shaped by the quality of the upstream information it receives.

2.1.2 Bail Hearings and Evidentiary Constraints in Risk-Based Detention

Bail hearings in Ontario are governed by section 515 of the Criminal Code. The default position under Canadian law is that an accused person is entitled to release unless the Crown can demonstrate, on a balance of probabilities, that detention is justified on one or more of three grounds: risk of non-attendance (primary), risk to public safety (secondary), or the need to maintain public confidence in the administration of justice (tertiary).

Crown attorneys seeking detention must build their case from the information available at the time of the hearing. In most cases, this consists of a police synopsis, the accused’s criminal record (if any), and any conditions associated with prior releases. Unlike trial proceedings, bail hearings operate on compressed timelines and rely on a lower evidentiary threshold—but they are not unconstrained. The evidence presented must be credible, relevant, and sufficient to support the requested outcome.

2.1.2.1 Limited Access to Contextual Risk Information

One of the most significant barriers to effective bail submissions is the limited availability of contextual risk information. Prior police occurrence reports, withdrawn charges, peace bond histories, and risk assessment outcomes are frequently unavailable to the Crown at the time of the bail hearing. These records may exist in different police services’ databases, may not be linked to the current file, or may be excluded from the information package provided by investigating officers.

2.1.2.2 Evidentiary Limitations on Pattern Evidence

Even where contextual information exists, its admissibility at a bail hearing is not guaranteed. While section 518(1)(e) of the Criminal Code allows the court to receive “credible or trustworthy” evidence, the application of this standard varies by jurisdiction and presiding justice. Some justices of the peace and judges strictly limit the types of evidence that may be considered, excluding prior allegations, uncharged conduct, or third-party reports that have not been tested through cross-examination.

2.1.2.3 Impact on Risk-Based Detention Arguments

The cumulative effect of these evidentiary constraints is that Crown attorneys may be unable to present a full picture of risk. In IPV cases, this is particularly significant. The nature of intimate partner violence—escalating patterns of control, repeated breaches, and the involvement of vulnerable victims—often requires contextual evidence to establish the true level of danger. Without this evidence, bail decisions may be made on the basis of the current charge alone, without reference to the broader pattern of behaviour.

2.1.2.4 Structural Constraints on Crown Advocacy

Crown attorneys also face structural constraints on their ability to advocate effectively at bail. In high-volume jurisdictions, bail courts may process dozens of matters in a single day. Crown counsel may receive files with limited preparation time, incomplete documentation, or last-minute disclosure. In these circumstances, even well-intentioned prosecutors may be unable to present the strongest possible case for detention.

2.1.2.5 The Role of Police Information in Shaping Bail Outcomes

The quality of the police information package is a critical determinant of bail outcomes. If the investigating officer provides a detailed, risk-informed synopsis that addresses the accused’s history, the dynamics of the relationship, and the specific risk factors present in the case, the Crown is better positioned to make effective submissions. Conversely, a thin or formulaic synopsis may leave the Crown without the factual foundation necessary to oppose release.

2.2 Reverse Onus and Bail Reform: Legislative Form vs Operational Impact

Reverse onus provisions shift the burden of proof at bail from the Crown to the accused. In these cases, the accused must demonstrate why their detention is not justified, rather than the Crown demonstrating why it is. The Criminal Code identifies several categories of offences and circumstances that trigger a reverse onus, including offences involving firearms, offences committed while on release for another indictable offence, and certain drug trafficking offences.

In IPV cases, reverse onus most commonly arises when the accused is already on release for another offence, is subject to an existing bail order, or has been charged with a new offence while bound by a recognizance. The Criminal Code requires written reasons where release is granted in a reverse onus case, reinforcing the expectation of detention but not mandating it.

Legal and procedural constraints also shape how reverse onus provisions operate in practice. Crown counsel must still lead sufficient evidence to allow the court to assess risk under the applicable grounds. If the evidentiary record is limited—for example, if prior occurrences are excluded or transcripts are unavailable—reverse onus may have little practical effect.

2.2.1 The Ladder Principle and Doctrinal Ambiguity

Section 515(3) of the Criminal Code requires that justices consider the “least onerous form of release” appropriate to the circumstances, a principle affirmed and expanded by the Supreme Court of Canada in R v Antic.⁵⁶⁷ Known as the “ladder principle,” it obliges courts to begin at the least restrictive form of release and move upward only if less restrictive conditions are shown to be inadequate.

The application of the ladder principle in reverse onus cases—where the accused must show cause for release—has historically been doctrinally uncertain. The structural difference prompted questions about whether a justice is still required to climb each rung of the ladder sequentially. The Public Prosecution Service of Canada has taken the position that the ladder principle does not apply in reverse onus cases, though the broader principle of restraint still governs the reasonableness of any release conditions imposed.

2.2.2 The Limits of Expansion: Reverse Onus, Judicial Discretion, and the Role of the Crown

In the aftermath of several high-profile violent incidents involving accused persons on bail, public and institutional calls to expand reverse onus provisions intensified. These calls were grounded in the assumption that shifting the burden of proof would meaningfully increase rates of detention in serious cases. In response, the federal government introduced Bill C-48 in 2023, which expanded reverse onus to include certain repeat violent offences involving weapons.

However, from a courtroom operations perspective, many of the accused persons captured by the new provisions were already subject to reverse onus under existing law. This includes any person charged with an indictable offence committed while on release for another indictable offence (s. 515(6)(a)(i)), or any person charged with breaching a condition of a previous release order (s. 515(6)(c)). In Ontario bail courts, it is common for serious accused to appear with multiple reverse onus triggers—being on release, having a prior conviction, facing new violent charges—yet still be released. The Criminal Code does not assign cumulative weight to multiple reverse onus triggers; once the burden has shifted, additional triggers do not enhance the presumption of detention.

Moreover, reverse onus designations do not obviate the need for substantive advocacy. Crown counsel must still establish the evidentiary foundation on which a JP or judge can assess risk. In the absence of reliable occurrence reports, conviction details, or witness availability, even a reverse onus may fail to support detention. These realities raise serious questions about whether reverse onus expansions meaningfully alter outcomes, or whether they operate primarily as symbolic legislative gestures.

2.2.3 Observations for Future Reform

The expansion of reverse onus provisions may serve a signalling function in the public discourse on bail. But in the day-to-day realities of Ontario bail courts, their impact is constrained by systemic factors—among them the availability of prosecutorial resources, the timing and content of disclosure, the limits of police-Crown information sharing, and the structure of bail hearings themselves. While reverse onus cases appear procedurally more rigorous, experienced Crowns are aware that these provisions often replicate pre-existing grounds for detention or formalize what courts were already doing.

Even in serious high-risk cases, if the accused is not in a reverse onus posture—such as where they have no prior record, were not on release, and are facing their first charge—the burden remains with the Crown to establish why detention is necessary under one or more of the s. 515(10) grounds. These cases can be particularly challenging, especially where the offence alleged is severe (e.g., child exploitation or sexual assault) but the accused appears, on paper, to be a first-time offender. Without access to detailed prior history, prior breach data, or third-party evidence, the Crown may struggle to establish sufficient risk to justify detention.

In this context, any presumption that additional reverse onus provisions will, on their own, increase public safety may overstate the practical value of such reforms. Structural investments—in Crown capacity, bail review resources, risk evidence admissibility, and surety monitoring—are more likely to enhance the system’s ability to detain high-risk accused effectively and lawfully. Legislative efforts focused solely on shifting the burden of proof, without addressing these foundational factors, risk diverting attention from more impactful interventions.

2.2.4 Impacts of Recent Federal Reforms and the Limits of Reverse Onus Expansion

Much of the public discourse surrounding bail reform has been directed at the federal government, urging the creation of additional reverse onus provisions as a way to address repeat offending. This focus is politically resonant and often amplified by stakeholders without formal legal training or direct involvement in the courtroom decision-making process. While the expansion of reverse onus categories may appear to strengthen the bail framework, its operational impact is limited in the absence of supporting evidence, real-time information sharing, and prosecutorial capacity. From a legal perspective, shifting the burden of proof does not guarantee detention—particularly in high-risk cases where the evidentiary record remains incomplete or fragmented.

While reverse onus provisions can assist in securing detention in high-risk cases, their recent expansion through federal legislation may have limited operational impact. Many of the accused now subject to reverse onus under provisions such as s. 515(6)(b.2) were already facing detention arguments under existing grounds.

That said, the formalization of these expectations has some value. Codifying repeat-violence triggers into the Criminal Code sends a public message about the seriousness of certain offence profiles and may deter some borderline offenders. It also places the burden of justification clearly on the defence, which can streamline submissions and reinforce public confidence. These changes also align with Ontario’s broader emphasis on strengthening bail enforcement and ensuring accountability for repeat violent behaviour.

However, recent expansions to reverse onus do not resolve the underlying structural challenges of the bail system. Even in reverse onus cases, courts cannot order detention without an evidentiary foundation. If occurrence reports are excluded, if supervision plans are unclear, or if key information is delayed, detention may remain out of reach—regardless of where the onus lies. For this reason, public safety outcomes depend less on whether Parliament adds new reverse onus categories, and more on whether Crown counsel have the tools, information, and capacity to make effective use of the provisions already in place.

2.3 The Tertiary Ground: Systemic Constraints and Justice of the Peace Training

In Ontario, the vast majority of bail hearings are heard by Justices of the Peace (JPs) in the Ontario Court of Justice. JPs are judicial officers appointed by the province, and unlike judges, they are not required to be lawyers (many have backgrounds in public service, policing, social work, etc., and receive legal training upon appointment). Several observers—including police leaders and Crown attorneys—have expressed concern that expecting JPs to handle complex violent crime bail hearings places a great deal of pressure on officials who may lack extensive legal training or specialized knowledge in certain crime dynamics.⁵⁷¹

2.3.1 Understanding Coercive Control and Patterns of Abuse

One area where this concern materializes is in cases of domestic violence and coercive control. Coercive control refers to a pattern of behavior by which an abuser subjugates their partner through intimidation, isolation, psychological manipulation, financial control, and other non-violent tactics, potentially punctuated by episodic physical abuse. It is a well-recognized precursor to severe violence; many domestic homicides are preceded by histories of coercive control rather than frequent physical assaults.

However, Canadian criminal law does not explicitly criminalize coercive control (unlike some other jurisdictions), so an accused might come before a bail court on a relatively “minor” charge (e.g. mischief, or a single assault causing no lasting injury) that belies the true danger they pose. A JP without robust training might see a first-time charge with sureties offering to supervise, and conclude detention is unnecessary. The Crown and police, armed with information from the victim or family, might know that this incident is the tip of the iceberg of terror.

Ontario has recognized this gap to some extent. In addition to educational programs and training materials developed for Justices of the Peace on domestic violence and sexual violence, both the federal and provincial governments have enacted legislative changes requiring judicial education on intimate partner violence and coercive control. Often referred to as “Keira’s Law,” these amendments reflect a broader consensus that adjudicators must be equipped to recognize and respond to the dynamics of coercive abuse. While implementation is ongoing, anecdotal reports suggest that levels of understanding among bail adjudicators remain uneven.

2.3.2 The Tertiary Ground and JPs’ Dual Role

The tertiary ground (s. 515(10)(c)) permits detention to maintain confidence in the administration of justice, taking into account factors like the gravity of the offence, the circumstances surrounding its commission (e.g. whether a weapon was used or it was particularly heinous), the apparent strength of the prosecution’s case, and the potential for a lengthy prison term on conviction. This ground is often invoked by Crowns in serious cases—for example, a brutal sexual assault, home invasion, or robbery with a firearm—even when primary and secondary grounds might not strictly require detention.

The “reasonable member of the public” test was clarified by the Supreme Court in R v St-Cloud (2015), which emphasized that the test is not based on public outrage or emotional reaction. The relevant perspective is that of a thoughtful, informed member of the public—someone aware of the presumption of innocence and the right to reasonable bail, but also attentive to the seriousness of the allegations and the justice system’s obligation to maintain legitimacy.

For JPs, the tertiary ground can be challenging to apply. It explicitly requires an assessment of the strength of the evidence against the accused and the seriousness of the offence. In effect, the bail court must engage in a preliminary evaluation of the case—something akin to a truncated weighing of the prosecution’s case. The Supreme Court in R v St-Cloud (2015) clarified that the tertiary ground is a fully independent basis for detention, not a mere afterthought, and it can apply in non-exceptional cases—essentially wherever the statutory criteria are met.

Despite this clear direction, applying tertiary ground correctly requires sound judgment and legal knowledge. JPs must be careful not to treat it as a tool to detain whenever the charge is serious; they must consider all circumstances, including any mitigating factors, and remember that the accused is still presumed innocent.

2.4 Structural Analysis of Section 493.2 and Its Practical Limitations

2.4.1 Vulnerable Accused vs. Vulnerable Victims: Section 493.2 of the Criminal Code

Section 493.2 of the Criminal Code, introduced through Bill C-75, directs courts to give particular attention to the circumstances of Indigenous accused and those from other overrepresented or disadvantaged populations in the criminal justice system. The stated intent of this provision is to address the documented overrepresentation of certain groups in pre-trial detention by requiring that courts engage with the broader structural context of the accused’s circumstances.

Crown policy in Ontario reflects this directive. Prosecutors are instructed to consider whether disadvantage—such as lack of housing, employment, community support, or systemic discrimination—may be limiting an accused’s ability to meet conventional bail requirements. Crowns are also reminded that pre-trial detention is not to be used as a proxy for social services or mental health intervention.

However, the provision does not include a corresponding requirement to assess the structural or personal vulnerability of the complainant. In cases where both parties may experience comparable forms of marginalization—such as in intimate partner violence or intra-community violence—the legislative structure instructs the court to give affirmative weight to the accused’s background, while any consideration of the complainant’s circumstances remains discretionary. This asymmetry introduces complexity into the Crown’s role and influences how risk is framed, argued, and received.

2.4.2 Operational Constraints and Infrastructure Gaps

While section 493.2 was introduced to support the use of pre-trial release for individuals from overrepresented or marginalized populations, its practical application often depends on the availability of community-based supports and infrastructure. In cases where the accused presents with complex needs—such as untreated mental illness, substance use disorders, or unstable housing—effective supervision typically requires access to bail programs, treatment beds, or structured residential settings.

Crown counsel may attempt to negotiate a release plan that includes residential supervision or access to supports, but in the absence of appropriate facilities or guaranteed placements, the options are constrained. Community shelters, while often accommodating, may not have the capacity or mandate to supervise individuals with complex risk profiles. In such cases, courts are often required to choose between detention—despite an accused’s eligibility for release under section 493.2—or an unstructured release with elevated risk of non-compliance.

2.4.3 Balancing Risk and Identity in Bail Submissions

Section 493.2 of the Criminal Code requires courts to give particular attention to the personal circumstances of Indigenous accused and other individuals from populations that are overrepresented in the justice system and face systemic disadvantage in securing pre-trial release. This provision, introduced as part of Bill C-75, does not alter the legal grounds for detention under section 515, but it imposes a new expectation regarding how courts evaluate and articulate the broader context in which bail decisions are made.

In practice, this expectation introduces a shift in emphasis. Crown attorneys must now anticipate that social context—including housing instability, lack of surety, or prior systemic disadvantage—may be treated as mitigating factors even where public safety risks are otherwise present. The effect is to require a heightened justification for detention where the accused meets the criteria of section 493.2, particularly in cases involving secondary ground arguments.

2.4.4 Victim Vulnerability and the Absence of a Parallel Statutory Directive

Section 493.2 of the Criminal Code provides a clear and affirmative instruction to consider the individual circumstances of marginalized or overrepresented accused. However, no equivalent statutory provision requires courts to give structured attention to the personal circumstances of complainants who may also be members of vulnerable or historically disadvantaged groups. While courts are mandated under section 515(13) to consider the safety and security of the victim, the Criminal Code does not prescribe how that analysis should be weighted, nor does it provide any framework for evaluating structural or contextual vulnerabilities specific to the complainant.

A significant proportion of victims in intimate partner violence, sexual violence, and human trafficking cases are themselves Indigenous, racialized, economically marginalized, or living with intersecting forms of disadvantage. Complainants may be financially dependent on the accused, residing in shelters, or managing trauma, coercion, and isolation. These realities are routinely raised in Crown submissions under the secondary ground, but their consideration depends on the court’s receptivity rather than on any statutory requirement to assign them structured weight.

From a policy perspective, several legal observers and Ontario stakeholders have proposed that Parliament consider amending the Criminal Code to include a statutory directive requiring courts to give particular attention to victim vulnerability—particularly in offences involving violence, coercion, or repeat targeting. Such a provision could mirror section 493.2 and allow courts to explicitly consider whether the complainant is Indigenous or racialized, has a history of abuse by the accused, is financially or physically dependent on the accused, or resides in a remote or under-resourced location.

Section 2.6: Plea Bargaining Pressures and the Impact of the “Catch-and-Release” Cycle

Across Ontario, although Bill C-75 came into force in December 2019, its implementation was almost immediately overtaken by the system-wide disruptions of March 2020, when in-person court operations were suspended. The resulting shift in policy, procedure, and discretionary practice continues to inform how bail is argued and adjudicated.

During the pandemic, custodial remand was significantly reduced due to public health considerations and the operational constraints associated with in-person hearings and detention facility management. Crown consent to release became more common, and detention was reserved for a narrower set of high-risk cases. Many of these decisions were shaped by guidance issued at the time and reflected an institutional effort to balance legal obligations with public health imperatives. While these adaptations were introduced as temporary, the jurisprudence developed during this period continues to inform release decisions today.

Pandemic-era case law and risk assessments are now frequently cited in ongoing bail proceedings, even though the public health rationale that originally supported them may no longer apply. The shift in reasoning that occurred between 2020 and 2022 has contributed to a recalibration of what is considered sufficient risk to justify detention. This remains relevant in discussions about repeat offending, bail breaches, and public safety concerns. One case that received considerable public attention was Darnell Reid, in which the accused—who had been released on bail during the pandemic while facing multiple IPV-related charges—was later involved in the fatal shooting of Darian Henderson-Bellman.⁵⁷⁵ Cases of this nature continue to shape public discourse around bail and illustrate the long-term consequences of release decisions made under emergency conditions.

While some public statements have suggested that COVID-19 should no longer influence bail outcomes, the issue is not whether it remains an explicit factor—it is that legal reasoning developed during that period continues to structure how decisions are made. The current bail environment reflects a convergence of federal legislative changes, evolving appellate guidance, and institutional adaptations made during a period of unprecedented disruption. Understanding how those elements interact remains essential to evaluating how pre-trial release is approached in Ontario today.

2.6.1 System Pressures and Global Resolutions

Bail decisions have a significant influence on the eventual resolution of criminal cases. In Ontario’s high-volume jurisdictions, systemic constraints on trial availability shape how Crown and defence counsel approach case resolution. The cumulative effect of repeated releases, overlapping dockets, and delayed trial access is the widespread use of global resolutions—plea agreements that dispose of multiple charges or occurrences through a single sentencing outcome.

Global pleas are particularly common where an accused has accumulated charges across separate incidents while subject to prior forms of release. In such cases, the accused may ultimately be detained on a subsequent offence, at which point the incentive to resolve all outstanding matters increases. Crown and defence may negotiate a global resolution in which the accused pleads guilty to key charges across multiple dockets in exchange for the withdrawal of others and a joint sentencing submission that reflects overall criminality. These resolutions are often necessary to manage caseload volume and avoid delay-based dismissals.

The principle of totality in sentencing, as set out in R v M(CA), 1996 CanLII 230 (SCC), [1996] 1 SCR 500 further shapes how these resolutions are structured. This principle directs that the total sentence for multiple offences reflect the overall criminality, not a mechanical accumulation of individual penalties. A Crown attorney preparing a global resolution must weigh aggravating and mitigating factors across files, ensure that the final sentence is proportionate, and account for pre-trial custody credit—often calculated at 1.5-to-1. These factors place natural limits on how much additional sentencing weight can be attached to offences committed while on bail, even where such conduct would otherwise be viewed as aggravating under section 718.2(a) of the Criminal Code.

From a system efficiency standpoint, global pleas allow cases to be resolved expeditiously, sometimes in a single hearing. Ontario’s Crown attorneys operate within finite trial capacity and under the jurisprudential ceilings imposed by the Supreme Court’s decision in R v Jordan, 2016 SCC 27, which requires that trials occur within 18 months in the Ontario Court of Justice (without a preliminary inquiry) or 30 months in Superior Court, unless exceptional circumstances are demonstrated. Where trial dates are unavailable within those timeframes, the risk of proceedings being stayed increases. As a result, the practical capacity to hold multiple trials for an accused with several outstanding matters may be limited. This dynamic incentivizes early plea discussions—particularly in cases where in-custody accused are accruing enhanced credit for pre-sentence detention.

Trial stacking further compounds these pressures. As described by the Ontario Crown Attorney’s Association, in many high-volume jurisdictions Crown counsel are assigned multiple trials on the same day—more than could ever be heard in one day—with only one courtroom realistically available. This requires real-time triage based not on the legal merits of the case, but on factors such as witness availability, complainant participation, or whether the accused is in custody. It also requires the Crown to prepare multiple trials, most of which will then not be able to proceed. Matters that cannot proceed are typically adjourned, resolved through a plea agreement, or withdrawn—not as a reflection of evidentiary weakness, but as a function of capacity. Over time, this reinforces a system dynamic in which trial threats become less credible, plea leverage is reduced, and decisions are driven by docket management rather than legal strategy.

2.6.2 Implications for Public Confidence and Crown Discretion

While procedurally sound, global resolutions can present challenges in how accountability is perceived. When multiple offences are resolved simultaneously, and one or more charges are withdrawn to streamline proceedings, victims may feel that their experiences have been subsumed into a broader resolution with no discrete consequence. Bail breaches, in particular, may be addressed only in aggregate, rather than as distinct violations of court orders. Crown counsel consistently raise these breaches as aggravating factors and seek sentencing outcomes that reflect their seriousness. However, under current conditions, sentencing must also account for systemic pressures and proportionality limits—factors which may result in outcomes that appear lenient relative to the number or pattern of offences.

Trial scarcity also shapes discretionary decisions at the pre-plea stage. In some jurisdictions, trial dates are unavailable for 12 to 18 months. Crown counsel may assess whether prolonged pre-trial detention is proportionate to the expected sentence. If an accused is facing a potential sentence of one year, but the earliest trial date is 18 months away, continued detention may exceed what is ultimately justifiable. In these cases, Crown may consent to release on stricter conditions, even where they might otherwise have sought detention in a different trial environment. Defence counsel may use this dynamic strategically, indicating readiness to proceed to trial to increase leverage in plea discussions or bail hearings.

Conversely, once an accused is detained, the incentive to resolve outstanding matters increases. Defence counsel may propose a global resolution across multiple files, often involving unrelated charges from different jurisdictions. These proposals are frequently accepted to avoid further delay, avoid strain on victims and witnesses, and preserve trial time for the most serious matters. However, this pattern also reinforces the perception that repeat offending while on release does not result in proportionate consequences. The system’s structural limitations mean that some matters are resolved through compromise rather than full adjudication.

Crown policy in Ontario emphasizes that serious violent offences, particularly in intimate partner violence, sexual violence, and human trafficking cases, should not be bargained away for expedience. Nonetheless, in multi-case scenarios, some charges may be withdrawn as part of a larger resolution that secures a conviction and appropriate sentence on the most serious files. These decisions are made with reference to the public interest, trial feasibility, evidentiary strength, and victim consultation obligations under the Ontario Victims’ Bill of Rights. Where possible, Crowns seek to ensure that the resolution reflects the seriousness of the conduct and the risk posed by the accused. However, in practice, these objectives are sometimes constrained by broader systemic conditions.

2.6.3 Structural Interdependence Between Bail and Plea Outcomes

The relationship between bail decisions and case resolution practices reflects the structural interdependence of different stages of the criminal justice process. Where individuals are released and subsequently accrue additional charges, the number and complexity of pending matters often increase until resolution becomes a logistical necessity. These cases are frequently addressed through global plea resolutions, which aim to manage cumulative risk and system pressures rather than adjudicate each incident independently. The resulting sentences may reflect practical compromise across files, particularly in cases involving overlapping jurisdictions or protracted timelines.

Trial scarcity and pre-trial release conditions directly shape how and when resolution occurs. Where detention is not pursued or cannot be sustained, new offences may occur during release periods, creating additional files for eventual resolution. Once detained, these matters may be resolved in bulk, often under compressed timelines and with limited trial availability. The overall result is that sentence outcomes for individuals with multiple charges—some committed while on bail—may reflect the procedural constraints of the system as much as the facts of any single offence. In this context, plea bargaining remains central to case resolution, but its outcomes are inextricably linked to earlier bail determinations and broader resource conditions across the system.

2.6.4 Complexity of Consolidating Multiple Proceedings Involving a Single Accused

It is a common procedural misconception that multiple charges involving the same accused can be easily combined into a single trial. In practice, unless the defence consents and the requirements of section 591 of the Criminal Code are satisfied—namely, that the charges are of the same or similar character or arise from a common factual nexus—separate charges must proceed independently. This reflects both statutory design and judicial practice.

For example, where an accused is charged sequentially with assault, breach of a release order, theft, and a subsequent breach, each incident typically requires a distinct proceeding. Even where individual trials are brief, the cumulative scheduling impact on court resources can be substantial. This is particularly pronounced in cases involving chronic or repeat offending—such as in intimate partner violence, sexual violence, human trafficking, or child abuse contexts—where charges may span multiple jurisdictions or involve multiple complainants. These cases often present complex fact patterns and require the coordination of multiple witnesses and police services.

In such cases, Crown attorneys must assess how to allocate limited trial resources. Where consolidation is not available and parallel proceedings cannot be efficiently aligned, Crown counsel must determine which matters to advance, which to prioritize for resolution, and which may warrant withdrawal or stay. These decisions are informed by evidentiary strength, complainant availability, public interest considerations, and systemic scheduling pressures. In Ontario’s highest-volume jurisdictions, including Toronto, Ottawa, and Brampton, trial calendars are often fully booked many months in advance, limiting flexibility.

These procedural constraints also affect plea resolution practices. Accused persons may delay resolution until they are detained, at which point defence counsel may seek a global resolution encompassing all outstanding matters. These discussions require Crown counsel to reassess multiple files in detail, often involving unrelated charges, breaches, and complainants. Where charges span jurisdictions or court levels, coordination across Crown offices may be required to facilitate resolution or sentencing.

The administrative demands of global coordination are significant. High-volume intake screening is often necessarily limited in scope. Re-engaging with files months after intake—particularly where there are multiple incidents, overlapping court streams, and cross-jurisdictional implications—requires time, information sharing, and careful legal review. In the absence of centralized case management systems or dedicated coordination resources, global resolution of multi-incident cases remains a complex and labour-intensive process.

2.6.5 Managing Fragmented Proceedings and the Challenges of Cross-Jurisdictional Resolution

The challenges associated with resolving multiple charges are compounded by the procedural limitations on consolidating matters for hearing or sentencing. Even when a global resolution is contemplated, structural barriers—such as jurisdictional fragmentation, separate court levels, or consent requirements—can complicate efforts to streamline proceedings. These limitations affect not only plea bargaining but also the day-to-day administration of pre-trial custody, supervision, and scheduling.

2.6.6 Legal Limits on Consolidation

When an accused faces multiple charges arising from different incidents, the ability to consolidate those matters into a single proceeding is often limited by statutory requirements and procedural constraints. Under section 591 of the Criminal Code, offences may be joined if they are of the same or similar character, or if they form part of a single transaction. Where this threshold is not met, and where the accused does not consent, separate trials are generally required. As a result, multiple charges arising out of different events—such as an assault, a breach of a release order, a theft, and a subsequent breach—must proceed independently. Each matter requires separate court appearances, which may involve different witnesses, judicial officers, and timelines.

2.6.7 Operational Impacts of Procedural Fragmentation

This procedural fragmentation can significantly strain court capacity, particularly in high-volume jurisdictions. It may also contribute to delays, increase witness fatigue, and prolong uncertainty for complainants. In cases involving repeat or chronic offending—such as those involving intimate partner violence, sexual violence, human trafficking, or child abuse—the number of separate matters requiring individualized adjudication can grow quickly. Crown attorneys must then determine how to allocate limited trial resources, assess which matters to advance, and decide where a resolution is appropriate or where charges should be stayed.

2.6.8 Cross-Jurisdictional Challenges

Where offences are pending in different jurisdictions—such as an assault in Toronto and a breach in Peel Region—coordination becomes more complex. Consolidation is not automatic, and procedural tools such as direct indictments (which permit joinder of unrelated matters) are used sparingly and require approval from the Attorney General. Charges arising in different courts may proceed on different tracks unless the accused consents to bringing them together. Even within a single jurisdiction, matters may be split between Ontario Court of Justice and Superior Court proceedings, depending on the offence classification and election. Consolidating these proceedings for resolution may require consent from the accused, cooperation across Crown offices, and alignment of court schedules.

2.6.9 Administrative Burden on Crown Counsel

The operational implications of this fragmentation are significant. Defence counsel often delay resolution discussions until their client is in custody, at which point a global resolution is proposed. These resolutions require Crown counsel to revisit multiple files, reassess the evidence, coordinate with complainants and police, and prepare a sentencing position that accounts for all matters. This is further complicated when charges cross jurisdictions, particularly in the absence of centralized case tracking systems. Coordination across regions often relies on informal communication between Crown offices, with no dedicated administrative infrastructure for multi-jurisdictional resolution.

2.6.10 Legal Regime Constraints and Case Management Complexities

There are also structural limits to consolidation based on legal regime. For example, where an accused faces charges both as a youth and as an adult in close succession, the Youth Criminal Justice Act prohibits merging the matters into a single proceeding—even if the conduct overlaps. In these cases, separate court streams and sentencing regimes must be maintained.

The inability to consolidate cases also has implications for pre-trial custody, bail supervision, and overall case management. An accused may be on bail for one set of charges when new charges are laid. If bail is granted on both, multiple sets of conditions may apply, potentially conflicting or becoming difficult to supervise. If the accused is detained on one matter and not the other, the second may be deprioritized until the first resolves. This can delay access to meaningful resolution and create inefficiencies across the system.

Section 2.7: Systemic Drift, Stalled Trials, and the Real Consequences of Delay

The cumulative effect of resource constraints, trial scarcity, and evidentiary limitations is not just delay—it is distortion. Accused persons are released on bail due to triage pressures or underdeveloped evidentiary records. Some reoffend while on release, are arrested again, and—absent a change in risk factors—are released again. This cycle often repeats until the individual is eventually detained, either due to escalation or because detention becomes legally or practically unavoidable.

At that point, the incentive to resolve increases. Crown counsel, now faced with multiple overlapping dockets, must prepare a global resolution. This requires time to review each file, consult with complainants, and coordinate across jurisdictions. Ideally, these resolutions reflect the full scope of the accused’s conduct. In practice, the leverage to secure such outcomes depends on the ability to proceed to trial if necessary.

When trial dates are unavailable, the Crown’s ability to uphold sentencing expectations is constrained. Defence counsel may reasonably infer that the matter cannot proceed to trial within a constitutionally acceptable timeframe. This weakens plea leverage, narrows the range of acceptable dispositions, and shifts negotiating power toward the accused. In this environment, resolution outcomes reflect not only legal assessment, but institutional capacity. The result is that contested matters are increasingly resolved not because trial is inappropriate, but because trial is inaccessible.

This dynamic is especially acute in cases involving intimate partner violence, sexual violence, human trafficking, and child abuse—cases where complainants may be reluctant to testify, where delay compounds trauma, and where procedural fatigue can lead to disengagement. In these matters, systemic delay functions not only as a fairness issue, but as a barrier to meaningful accountability.

Over time, when cases are resolved under constrained conditions, the resulting outcomes become reference points. Sentences agreed to under duress or resource scarcity may be cited in future as indicators of proportionality. The common law shifts not only through appellate decisions, but through volume. Patterns of unreviewed plea agreements and untested trial positions accumulate, gradually shaping expectations around what is typical, acceptable, or fit. In this way, the justice system may appear to drift toward leniency—not because of policy or intention, but because of the structural pressures under which it must operate.

This is not unique to Ontario. Across Canada, provinces are responsible for administering a justice system that is increasingly defined by federally imposed standards—standards that govern delay, pre-trial release, sentencing, and post-conviction supervision. These legal expectations are shaped by Charter jurisprudence and national legislation, but they are implemented by provincial prosecutors, judges, and court staff. The 2016 decision in R v Jordan redefined the meaning of unreasonable delay, but did not include any transitional provisions to support system readiness. Parliament took no steps to phase in the new standard, to postpone its application, or to provide funding for provinces tasked with enforcing it.

Since that time, Charter-based jurisprudence and federal legislative amendments have continued to expand procedural obligations without reference to provincial resourcing. Recent Supreme Court decisions—such as Ndhlovu, Bissonnette, and Ewert—have revised or struck down provisions related to sex offender registration, cumulative sentencing, and risk-based post-conviction management. Each decision has operational consequences, but those consequences are absorbed not by federal actors, but by the provinces. No mechanism exists to quantify the cumulative impact of these changes, nor to coordinate federal legal design with the resource realities of trial-level justice.

At the same time, structural correction mechanisms remain limited. When bail decisions are problematic—due to evidentiary constraints or underdeveloped risk records—the only available mechanism for review is an application to a federally appointed Superior Court judge. These judges are also the only officials who can hear estreatment applications. Where judicial appointments are delayed or judicial shortages persist, the ability to revisit release decisions or enforce surety obligations is narrowed.

Against this backdrop, structural critiques of court performance must be approached with care. The 2019 Auditor General report on Ontario’s criminal courts emphasized age-of-file statistics. However, it did not examine the staffing and scheduling requirements of criminal trial courts, nor did it reflect the legal constraints under which prosecutors, judges, and trial coordinators operate.⁵⁷⁶ A courtroom without a judge, clerk, and Crown is not unused—it is unschedulable. A case that is withdrawn on the eve of trial is not evidence of over-caution; it is the product of a scheduling system that may have offered only one viable trial date across multiple dockets.

Section 2.8: The Absence of a System-Wide Operational Model

2.8.1 Acknowledging the Scope of Systemic Delay

Delays in Ontario’s criminal courts are significant and well documented. In many jurisdictions, trials are unavailable for over a year. Bail hearings are routinely double- or triple-booked. Victims wait extended periods for resolution. Crown attorneys must triage which cases proceed and which are resolved by compromise. These pressures are not anecdotal. They are structural.

The following analysis does not dispute the reality of delay. It addresses the frameworks used to measure it, the legal structures that drive it, and the operational gaps that prevent a coordinated response.

2.8.2 Limitations of the Auditor General’s Approach

The 2019 Auditor General report on Ontario’s criminal courts focused on courtroom occupancy, file duration, and scheduling trends. While these are relevant indicators, the report applied an audit framework that is not well suited to criminal justice.⁵⁷⁷ It treated physical courtrooms as static assets and delay as evidence of administrative inefficiency, without accounting for the legal, procedural, and constitutional conditions that shape courtroom usage.

Courtrooms are not idle because they are physically unoccupied. They may be dark due to the unavailability of a judge, a Crown, a clerk, a coordinator, or an interpreter. They may be in recess for plea negotiations, reasons drafting, victim consultation, or trial collapse. These are not discretionary inefficiencies. They are operational features of a system structured to uphold due process.

The audit did not examine how many courtrooms are staffed daily by per diem or contract Crown attorneys. It did not assess how many open files are managed by each full-time prosecutor. It did not track how often trials are stacked into the same courtroom block. These are basic indicators of system strain. Their absence limits the ability to distinguish between prosecutorial discretion and structural constraint.

The AG’s office also faced limitations in gathering information from the judiciary. Many judges declined to participate, in part due to concerns about the audit’s framing. Questions focused on volume and courtroom occupancy were interpreted as attempts to evaluate individual judicial performance—by counting how many matters were heard or how many decisions were written. These concerns reflect the principle of judicial independence. Judges are not accountable for productivity metrics. They cannot be ranked, rated, or evaluated by external audit. As a result, the AG report was developed without access to the internal context required to interpret courtroom non-use.

This does not mean the system should avoid measurement. It means measurement must reflect how the system works. A more meaningful approach would ask how many courtrooms were scheduled to operate each day, how many actually did, and what staffing element was unavailable. It would ask how many trial matters were deferred because of trial stacking. It would compare the number of open files to the number of available prosecutors. It would track the proportion of high-risk matters resolved by resolution rather than trial. These metrics do not compromise independence. They provide structural visibility.

2.8.3 Structural Pressure from Federal Law and Constitutional Doctrine

Ontario’s justice system operates within a legal framework largely shaped by federal legislation and Charter-based jurisprudence. While the province administers criminal law, it does so within a structure defined by Parliament and interpreted by the Supreme Court of Canada. In R v Jordan, the Court imposed presumptive ceilings of 18 and 30 months for the time from charge to trial.⁵⁷⁸ No legislative steps were taken by the federal government to delay implementation or support the provinces in meeting this new standard.

Since that time, federal decisions and legislative changes have continued to expand procedural obligations. Bail law emphasizes restraint and individualization. Risk assessment tools remain largely inadmissible. Prior uncharged conduct is incredibly difficult to raise at hearing. There is no statutory instruction to consider victim vulnerability or the impact of release on the specific community into which an accused will return.

The Supreme Court’s decisions in Ndhlovu (striking down mandatory sex offender registration) and Bissonnette (prohibiting consecutive life sentences) are consistent with this direction. They emphasize proportionality, restraint, and reviewability. They also shift risk management responsibilities onto provincial systems that lack a corresponding increase in capacity. No funding or structural plan was provided to support implementation.

Bail reviews and estreatment hearings may only be conducted by federally appointed Superior Court judges. Persistent judicial vacancies further limit the system’s ability to revisit risky release decisions or enforce surety compliance. These constraints apply even in high-severity matters.

Ontario has modernized its courts and adapted its policies. But it is doing so within a framework it did not design. The province is expected to comply with legal standards imposed at the federal level—but without the resources, tools, or operational visibility needed to meet them.

2.8.4 Operational Visibility and the Impact of Limited Data on Future Planning

Despite significant reforms, Ontario does not currently have a coordinated model to determine what full operational capacity would look like. There is no province-wide methodology to assess how many prosecutors, judges, clerks, and trial coordinators are needed to run every courtroom every day. There is no tracking system to quantify how often Crown offices are forced to prioritize one matter over another, or how often bail hearings are conducted without continuity of counsel. There is no metric for how many cases are resolved under pressure due to lack of trial time.

The solution is not only to increase staffing. It is to define what “enough” looks like. A province-wide operational model—grounded in courtroom scheduling data, file volume, trial stacking patterns, and staffing ratios—would allow Ontario to measure its system not against ideal conditions, but against legal obligations. It would provide a planning baseline for resource allocation. It would allow the province to demonstrate, transparently and consistently, that delay is not the result of inaction, but of structural misalignment.

Without that model, system planning remains reactive. Public concern about delay cannot be addressed. And Crown counsel, court staff, and judiciary remain tasked with delivering constitutional outcomes in an environment that has never been resourced to meet them.

Section 2.9: Recommendations

2.9.1 Recommendation 1: Call on the Federal Government to Amend the Criminal Code to Permit Admission of Risk-Relevant Evidence at Bail and Sentencing

Context and Purpose: Crown counsel in Ontario are frequently restricted from introducing contextual risk evidence at bail hearings and sentencing proceedings due to evidentiary conventions and judicial hesitancy, despite permissive statutory language in some contexts. At bail, section 518(1)(e) of the Criminal Code allows the court to receive “credible or trustworthy” evidence, but this provision is often underutilized. At sentencing, while judges are afforded broad discretion, structural norms and procedural expectations may still exclude relevant contextual material—particularly in cases where the accused has pled guilty and no contested facts are entered. In both settings, courts are often limited to narrow or incomplete records that exclude prior police occurrence reports, the factual basis of convictions, breach histories, and other indicators of escalating risk.

These limitations are particularly acute in cases involving intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), and child abuse, where conviction rates are low and much risk-relevant information never proceeds to trial. Without access to this evidence, courts may be unable to craft appropriate bail conditions or sentencing orders, including probation terms, supervision conditions, and contact prohibitions.

Jurisdiction: Federal (Criminal Code of Canada); Province of Ontario (advocacy through the Ministry of the Attorney General).

Recommendation: The Government of Ontario should formally request that the Government of Canada amend the Criminal Code to explicitly authorize the admission of credible and trustworthy risk-relevant evidence in both bail and sentencing proceedings. Specifically:

• Amend section 518(1)(e) to enumerate categories of admissible evidence at bail, including:
  • Prior police occurrence reports, including uncharged incidents of violence or coercive control;
  • The factual context underlying prior convictions, including aggravating elements not visible on CPIC summaries;
  • Sworn third-party statements or Crown proffers related to risk, victim vulnerability, or pattern of behaviour;
  • Breach patterns, peace bond history, and credible reports of past non-compliance;
  • Records of withdrawn or stayed charges where the Crown attests they were not withdrawn for lack of merit.
• Introduce a corresponding provision applicable to sentencing hearings, clarifying that:
  • Courts may receive and consider credible, non-conviction-based risk evidence when crafting probation orders, supervision terms, and other ancillary conditions;
  • Such evidence is admissible for the limited purpose of contextualizing the offence and protecting victim and community safety;
  • Weight and reliability remain subject to judicial discretion and the rules of procedural fairness.

Implementation Considerations:

• May trigger opposition from defence associations and civil liberties groups concerned about fairness and reliance on unproven allegations;
• Legislative language should affirm that such evidence is not determinative, and should preserve the court’s discretion to assign weight;
• Ontario may wish to coordinate its advocacy with other provinces and legal organizations to increase federal uptake;
• Crown offices should continue to refine evidentiary proffers and provide training on appropriate, Charter-consistent presentation of non-conviction material.

Rationale: While current law provides some flexibility, it remains inconsistently applied. Bail courts often decline to admit prior police occurrence reports or the factual basis of convictions without transcripts. Sentencing judges may similarly feel constrained when no contested facts are led, even in cases where risk to a specific victim or community remains high. These procedural norms create systemic blind spots that undermine both public safety and the integrity of release and sentencing decisions.

Explicit amendments to the Criminal Code would clarify Parliament’s intent, reinforce judicial discretion, and reduce jurisdictional inconsistency. These changes would enable courts to make better-informed bail and sentencing decisions in high-risk cases, improve victim and community protection, and align evidentiary practice with the realities of violence-related offending.

2.9.2 Recommendation 2: Call on the Federal Government to Amend Section 493.2 to Address Victim and Community Vulnerability

Context and Purpose: Section 493.2 of the Criminal Code instructs courts to give particular attention to the circumstances of accused persons who are Indigenous or members of overrepresented or disadvantaged populations. However, it imposes no corresponding duty to consider the vulnerability of the victim, or the risk posed to the specific community into which the accused is proposed to be released. This structural asymmetry results in a risk assessment framework that privileges the identity and circumstances of the accused without any parallel statutory requirement to examine or weigh the social, structural, or geographic vulnerability of victims or affected communities.

This omission is particularly consequential in cases involving intimate partner violence, sexual violence, and human trafficking, where complainants often experience overlapping forms of marginalization, including poverty, racialization, disability, and geographic isolation. These vulnerabilities may significantly affect the victim’s ability to remain safe in the event of the accused’s release but are currently considered only at the discretion of the presiding justice.

Jurisdiction: Federal (Criminal Code of Canada); Province of Ontario (advocacy through the Ministry of the Attorney General).

Recommendation: The Government of Ontario should formally request that the Government of Canada amend section 493.2 of the Criminal Code to ensure that courts are expressly required to consider the vulnerability of victims and affected communities in bail decision-making. The amended provision should:

• Require courts to give particular attention to the personal circumstances of any identified victim, including their safety, housing situation, geographic proximity to the accused, and degree of reliance on protection systems;
• Where no individual victim is named, require consideration of risks to the broader community—particularly communities that are remote, under-resourced, or known to be targeted by specific forms of violence (e.g., HT, coercive control);
• Clarify that this obligation applies in parallel with the directive to consider the circumstances of accused persons under s. 493.2, and is not subordinate to it;
• Preserve judicial discretion while structuring the expectation that vulnerability is analyzed on both sides of the risk equation.

Implementation Considerations:

• Legislative language must balance recognition of systemic disadvantage faced by accused persons with the need for a structurally neutral risk framework;
• Federal consultation processes may be required, particularly with Indigenous legal organizations, to ensure alignment with reconciliation principles;
• Ontario may wish to propose model language and engage with partner provinces to coordinate a federal request that maintains Charter integrity and avoids politicized backlash.

Rationale: Section 493.2 currently creates an asymmetry in how risk is conceptualized at bail. While the provision reflects legitimate concerns about overrepresentation of certain accused populations, it does so by assigning structured weight to one side of the equation only. In doing so, it obscures the parallel vulnerabilities experienced by many complainants—particularly in IPV/SV/HT matters—and fails to provide a legislative mechanism for their risk profile to be fully and predictably considered.

Amending section 493.2 to create a co-equal statutory duty to consider victim and community vulnerability would ensure that public safety assessments are grounded in a balanced, holistic understanding of risk. It would align with broader government priorities around violence prevention, judicial education, and equity-informed policymaking, while respecting judicial independence and discretion.

2.9.3 Recommendation 3: Establish a Dedicated Provincial Unit to Pursue Bail Reviews and Support Balanced Appellate Development

Context and Purpose: In Ontario, the legal architecture for bail review is set out in sections 520 and 521 of the Criminal Code, which allow either party to seek review of a release or detention order in the Superior Court of Justice. In practice, however, the ability of Crown counsel to pursue s. 521 reviews is sharply constrained by resource limitations, evidentiary burdens, and procedural timelines. Most bail reviews are initiated by defence counsel. Crown-initiated reviews, even where risk is evident or legal error has occurred, are rare due to transcript delays, lack of litigation support, and the high internal threshold for pursuing review.

This imbalance distorts the development of bail jurisprudence. Key appellate decisions—such as Antic, Myers, and Zora—have largely arisen from defence appeals, reinforcing a liberty-first interpretive direction. Without parallel Crown-driven appellate development, critical questions around the tertiary ground, breach patterns, or community risk remain under-litigated.

Jurisdiction: Ministry of the Attorney General.

Recommendation: The Government of Ontario should establish a dedicated bail review and appellate support unit within the Criminal Law Division of the Ministry of the Attorney General, with the following responsibilities:

• Prepare and pursue section 521 reviews in cases where release decisions pose demonstrable risk to public or victim safety or involve exclusion of critical risk evidence;
• Monitor regional patterns in bail decision-making and identify candidates for principled appellate intervention;
• Provide litigation support to Crown counsel seeking to clarify procedural standards around evidence admissibility, tertiary ground use, or repeat-offender detention;
• Coordinate knowledge-sharing and training on evolving bail jurisprudence, including emerging Charter-based defences and threshold interpretations.

Implementation Considerations:

• May require recruitment of litigation counsel with appellate expertise and support staff familiar with fast-track transcript and affidavit preparation;
• Should be equipped to liaise with regional offices to ensure timely identification of cases where review may be warranted;
• Unit must maintain a narrow and strategic focus to avoid overwhelming the court system or generating adversarial escalation;
• Where appropriate, interventions should be coordinated to generate jurisprudence that clarifies systemic ambiguities and reinforces public safety considerations.

Rationale: Crown-initiated bail reviews are currently underused—not because of legal inapplicability, but due to structural constraints that make them procedurally prohibitive. This has allowed an unbalanced body of jurisprudence to evolve, shaped largely by defence appeals and reinforced by systemic undercapacity on the Crown side. A dedicated provincial unit would correct this imbalance by identifying and pursuing reviews where appellate clarification is needed, particularly in matters involving repeat offending, coercive control, or inadmissible surety approvals.

Such a unit would enhance the development of principled, balanced common law in the bail context; reduce reliance on informal precedent driven by trial-level inconsistencies; and signal Ontario’s commitment to ensuring that bail law reflects the operational realities of public safety, not just procedural minimalism.

2.9.4 Recommendation 4: Establish a Provincial Framework for Operational Data Collection on Bail and Court Capacity

Context and Purpose: Ontario currently lacks a standardized, province-wide system for collecting and analyzing operational data related to courtroom staffing, bail hearings, trial scheduling, and system delay. As a result, decision-makers have limited visibility into how often courtrooms sit dark due to understaffing, how frequently trials are adjourned due to lack of Crown or defence availability, or how many accused persons reoffend while on release. These gaps undermine the province’s ability to model courtroom capacity, identify bottlenecks, justify resource allocations, and support risk-based detention decisions.

Trial coordinators, Crown Attorneys, and court operations managers all hold key fragments of this data, but no system exists to aggregate it in a structured, policy-relevant format. In the absence of a coordinated reporting framework, funding decisions must rely on anecdotal or retrospective justifications, rather than real-time indicators of systemic strain. This recommendation aims to establish an operational data collection structure capable of informing future strategic planning processes and enabling evidence-based justice system investment.

Jurisdiction: Ministry of the Attorney General; Ministry of the Solicitor General.

Recommendation: The Government of Ontario and the Ministry of the Attorney General should establish an operational data framework to collect, analyze, and report standardized metrics related to bail court, trial scheduling, and courtroom resource availability. The framework should include:

• Daily tracking of courtroom availability by site, including the number of staffed vs. unstaffed courtrooms, and the reason for any closures;
• Monthly collection of trial stacking data, including the number of trials scheduled per day per courtroom and how many were reached vs. adjourned;
• Regional data on bail hearing volumes, detention vs. consent release rates, and repeat offences committed while on release;
• Adjournment causes categorized by source (e.g., Crown unavailability, defence unavailability, interpreter/staffing shortage, disclosure outstanding);
• Crown office-level data on bail hearings conducted, estreatment applications filed, and cases involving accused persons already on release;
• Quarterly trend reports shared with MAG senior leadership to inform funding submissions, performance measurement, and regional resource planning.

Implementation Considerations:

• Data collection from trial coordinators will require cooperation with the judiciary and must avoid any inference of judicial performance evaluation;
• Many regions may lack standardized tools for tracking this data—pilot sites and phased implementation may be necessary to build capacity;
• Crown data can be gathered through structured All-Crowns Memos and integrated with existing case management systems.

Rationale: Without operational data, it is impossible to assess whether Ontario’s courts are adequately staffed or how system bottlenecks are influencing public safety outcomes. Structural reforms—such as bail modernization, Crown resourcing, or regional trial capacity planning—cannot be implemented effectively without a baseline understanding of current performance. A provincial framework would create the visibility necessary to align resource planning with public expectations, constitutional timelines, and Treasury Board priorities. It would also enable proactive intervention in high-strain regions and support the development of key performance indicators that reflect justice system realities rather than abstract policy goals.

2.9.5 Recommendation 5: Develop a Provincial Justice System Operational Capacity Model

Context and Purpose: Ontario currently lacks a coordinated framework to define what a fully resourced, legally compliant criminal court system requires in terms of human resources, infrastructure, and regional workload distribution. While the province collects some data on case volume, courtroom usage, and Crown staffing, this information is fragmented and not integrated into a formal capacity model that can be used to guide strategic investment, justify FTE allocations, or assess compliance with constitutional standards such as Jordan timelines.

In the absence of such a model, court operations rely on historical baselines and reactive resourcing. Trial backlogs, Crown burnout, and courtroom underutilization persist—not due to a lack of urgency, but because the system lacks a measurable definition of what “enough” looks like. This recommendation proposes the development of a provincial operational capacity model to align court system planning with public safety obligations, fiscal stewardship, and Charter-compliant performance.

Jurisdiction: Ministry of the Attorney General; Treasury Board Secretariat.

Recommendation: The Government of Ontario should develop a justice system operational capacity model that defines the baseline resource requirements for a fully staffed and legally compliant criminal court system. The model should include:

• Regional benchmarks for the number of Assistant Crown Attorneys, judges, trial coordinators, clerks, and courtrooms required to meet projected trial demand;
• Assumptions tied to offence volume, charging rates, trial election patterns, bail hearing loads, and case disposition types (e.g., plea vs. contested);
• Integration of data from the operational data framework (see Recommendation 4) to reflect courtroom usage patterns, dark court rates, and adjournment trends;
• Forecasting tools to assess the downstream impact of policing investments or legislative changes (e.g., new reverse onus categories);
• Scenario planning features to model the effects of staffing shortages, surges in high-risk offences, or new legal standards (e.g., mandatory disclosure timelines, probation oversight expectations).

Implementation Considerations:

• Development of the model should involve MAG, Treasury Board Secretariat, and frontline operational leads (including senior Crown management and court services staff);
• May require engagement of external policy consultants or use of Treasury Board’s internal analytics teams for technical design and validation;
• Initial model development should focus on criminal law system inputs, but should be designed with potential for future expansion into youth justice or integrated offender management domains;
• Care must be taken to preserve judicial independence by limiting the model’s scope to operational capacity rather than adjudicative output or performance.

Rationale: Resource planning in Ontario’s justice system is currently backward-facing—based on legacy patterns, constrained budgets, and crisis-driven negotiation. Without a standardized operational capacity model, it is not possible to meaningfully assess whether regional Crown offices, courthouses, or supervisory programs are sufficiently resourced to meet public safety obligations and constitutional timelines.

Developing this model would enable transparent, data-driven planning and help future-proof the justice system against further delay-related collapse. It would also support evidence-based submissions to Treasury Board and allow the province to track whether recent or proposed investments are likely to result in measurable improvement in access to justice and prosecutorial sustainability.

Section 3: Compliance Monitoring

3.1 Structural Scope Limitations of the Existing Bail Dashboard

3.1.1. Landmark Advance in Technologically-Enabled Policing

Ontario’s Bail Dashboard represents a significant advancement in technology-enabled policing. Originally developed by the Toronto Police Service in collaboration with Esri Canada, and later adopted by Durham Regional Police, the dashboard marked a foundational shift toward real-time, geospatial bail condition monitoring. Its interactive design allows officers to visualize the locations of individuals on bail for firearm-related offences, including their court-mandated residences, curfew zones, and geographic restrictions.⁵⁷⁹

This model has since been adopted provincially under the leadership of the Ontario Provincial Police, establishing a standardized, interactive compliance tool that supports both officer situational awareness and broader public safety coordination. The Bail Dashboard is widely recognized by police services as a leap forward in operational efficiency, offering a level of geospatial precision and integration that was previously unavailable through legacy platforms such as CPIC or standard RMS queries.

By embedding GIS mapping, real-time data visualization, and customizable filtering into a single dashboard, the system has laid the groundwork for a modernized approach to bail enforcement. In jurisdictions where the dashboard is active, it supports early identification of breaches, facilitates targeted compliance checks, and improves information-sharing between frontline officers and intelligence units. As a platform, it is widely regarded as a best-in-class example of how digital infrastructure can support enforcement without requiring additional front-line staffing or resource-intensive oversight.

3.1.2. Current Operational Boundaries

Despite its capabilities, the Bail Dashboard’s current deployment remains narrowly scoped. As of 2025, Toronto Police Service usage is limited to firearm and gang-related bail cases. Individuals released on bail for intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), or other high-risk interpersonal offences may not be included in the dashboard’s visualized dataset. Durham Police Service allegedly uses the tool more widely, but the Committee did not hear testimony as to specifics. In all jurisdictions, non-criminal peace bonds (section 810, Criminal Code), family court restraining orders, and probation orders are excluded. These categories represent a substantial portion of Ontario’s high-risk population under community-based supervision, but they remain structurally invisible within the dashboard environment.

This limited scope was a deliberate design feature of the dashboard’s initial phase, which prioritized firearm-related supervision as part of Ontario’s broader strategy to address gun violence. However, as the system expands provincially, its exclusion of IPV/SV/HT and related court orders creates a structural gap in risk monitoring and coordinated enforcement.

3.1.3. Exclusion of Certain Offenders and Orders

The exclusion of non-firearm-related offences has direct operational consequences. Offenders on bail for IPV or SV are often subject to conditions that mirror those imposed in firearm cases—house arrest, curfews, geographic restrictions, no-contact clauses—yet they are not visualized or tracked through the dashboard. Officers conducting patrols, compliance checks, or emergency responses may be unaware of an accused person’s conditions unless they manually search for that individual in non-integrated systems.

In cases involving family court restraining orders, section 810 peace bonds, or probation conditions, the enforcement gap is even more pronounced. These orders are often relied upon in high-risk safety planning but are not incorporated into any real-time visualization tool. Without centralized access or geospatial integration, officers have no systematic way to confirm conditions, detect proximity breaches, or coordinate enforcement across jurisdictions.

3.1.4. Data Entry and Visualization Constraints

The dashboard’s scope is further constrained by limitations in upstream data entry. Bail conditions are entered manually into police RMS systems from court-generated PDF documents. These PDFs are unstructured, often contain inconsistent address formatting, and do not support direct geocoding or structured extraction. RMS platforms such as Niche and Versaterm allow for only a single address per occurrence and rely on text-based fields that must be populated manually.

As a result, even firearm-related bail cases—where dashboard coverage is intended to be comprehensive—may be entered incompletely or inaccurately. Offenders with multiple permitted addresses, frequent curfew exemptions, or layered conditions may be partially represented or missed altogether. In the absence of a standardized interface for court-to-dashboard data transfer, these visualization gaps persist despite the underlying capabilities of the Esri platform.

3.1.5. Operational Consequences for Risk Management and Victim Safety

The current limitations in dashboard scope and data capture result in fragmented visibility for police and incomplete protection for victims. High-risk individuals released on bail for IPV, SV, or HT—many of whom present escalatory or repeat offending patterns—are not tracked in real time. Geographic exclusion zones are not mapped, proximity alerts are not triggered, and victims are left reliant on self-reporting and intermittent police presence for protection.

Similarly, officers responding to calls for service may have no way of knowing that a particular address is subject to a family court restraining order or that an individual on the premises is breaching a non-criminal peace bond. These orders are held in disconnected systems and are not visualized within patrol tools. In practice, this means that Ontario’s most advanced tool for risk-based enforcement is not currently operational in the very categories of violence where systemic non-compliance is most common and dangerous.

3.2 Structural Deficiencies of Probation-Based Monitoring

3.2.1. The Distinctive Role and Value of Probation Services

Ontario’s probation system plays an essential role in supporting rehabilitation, reintegration, and community safety. Probation officers supervise tens of thousands of individuals each year, assisting them in fulfilling court-imposed conditions, participating in rehabilitative programming, and reducing the likelihood of reoffending. Through the use of validated tools such as the Level of Service Inventory (LSI), probation officers assess criminogenic needs and tailor case management plans to support long-term desistance from crime. The Ministry of the Solicitor General’s stated goal for community corrections is clear: to help offenders not reoffend and to reduce risk to the public.⁵⁸⁰

This rehabilitative mandate distinguishes probation from other forms of supervision. Probation officers are trained professionals with expertise in case planning, program referral, and behavioural change. Their work is particularly critical in supporting individuals with mental health needs, substance use issues, or complex personal histories. The Ministry has taken steps in recent years to increase access to relevant programming for medium- to high-risk individuals, including the deployment of program delivery officers, training initiatives, and accreditation reforms.

However, while the value of probation lies in long-term support and structured accountability, the current infrastructure does not enable active, field-based enforcement of court-imposed conditions such as curfews, house arrest, or geographic restrictions. Probation officers are unarmed peace officers who work standard weekday hours from office-based settings. They are not authorized to arrest or detain, and they do not conduct routine compliance checks in the community.

3.2.2. Limitations in Monitoring and Enforcement Capacity

Ontario’s probation services are not structurally equipped to verify real-time compliance with supervision conditions. While probation officers are expected to develop offender management plans and track progress, their ability to enforce non-compliance is limited to initiating breach proceedings under the Criminal Code. These expectations exist despite the sometimes lack of reliable and timely information on offenders who breached conditions of their release and the absence of strong measures to ensure enforcement of more stringent conditions imposed by courts such as curfews and house arrest.

This limitation is not a reflection of inadequate effort but of structural design. Probation in Ontario was never intended to function as a surveillance model. The system relies on scheduled office visits, telephone check-ins, and voluntary compliance. When breaches occur, officers may issue warrants, but follow-up is generally dependent on local police capacity or judicial direction.

3.2.3. Persistent Gaps in Enforcement and Visibility

In testimony before the Standing Committee on Justice Policy, Scott McIntyre, a senior bargaining representative for Ontario’s probation and parole officers, confirmed that the system does not provide a mechanism to ensure that individuals are complying with supervision conditions such as house arrest, curfews, or non-association clauses. He noted that neither probation nor bail supervision “has a system in place that ensures compliance monitoring of such conditions,” and emphasized that the lack of enforcement is widely recognized by offenders themselves.⁵⁸¹

In 2017, more than 4,500 warrants were issued by probation and parole officers for individuals in breach whose whereabouts were unknown. These warrants were entered into CPIC, but were not routinely acted upon unless secondary events—such as re-arrest or new charges—brought the individual back into the system.⁵⁸² Ontario’s Repeat Offender Parole Enforcement (ROPE) unit focuses primarily on federal parolees and does not conduct routine warrant enforcement for individuals under provincial probation.

This operational vacuum leaves victims and community members vulnerable to breaches that are unlikely to be detected unless reported directly.

Operational Consequences

Ontario’s current model leaves the enforcement of court-ordered supervision conditions in a structurally ambiguous zone. Probation officers focus on rehabilitation and reintegration. Police services do not maintain operational mandates to conduct routine compliance checks. No dedicated compliance body exists to fill this gap. The effect is that many conditions—especially those imposed for IPV, SV, or HT—are enforced only when breached visibly or egregiously.

Victims may believe that conditions are being monitored in real time, when in practice, verification occurs only after a suspected breach has occurred. In the absence of structural reform, responsibility for ensuring compliance continues to fall—implicitly or explicitly—on the victim.

3.3 Building a Dashboard Capable of Systemic Compliance Enforcement

3.3.1. Design Objectives for a Modern Compliance Platform

A modern compliance monitoring system must extend beyond visualization of bail conditions for a narrow subset of offences. To meet Ontario’s enforcement and victim safety needs, any province-wide dashboard must support real-time, structured tracking of all individuals under community-based legal conditions—regardless of offence type, court of origin, or supervising authority.

Specifically, the dashboard must be capable of displaying active conditions associated with:

• Bail orders, including all charges flagged as intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), and animal cruelty;
• Probation orders, including stand-alone community sentences and orders arising from intermittent custody;
• Section 810 peace bonds and common law recognizances;
• Family court restraining orders and child protection–related no-contact or access prohibitions;
• Active conditions imposed under conditional sentence orders (CSOs) and provincial parole.

The dashboard must also integrate victim safety overlays—such as exclusion zones, buffer radii, and opt-in GPS proximity alerting—into the same interface used for offender tracking. These functions are already supported by existing GIS tools used by Ontario police services and can be adapted for provincial scale with appropriate data input structures.⁵⁸³

3.3.2. Core Functional Capabilities

The envisioned platform must allow authorized users—such as police officers, probation personnel, and designated victim services staff—to:

• View active supervision conditions tied to any individual in their jurisdiction, regardless of the originating court or supervising ministry;
• Search, sort, and filter offenders by risk tier, supervision type, geographic restrictions, or violation history;
• Visualize all current and historical addresses, including residence requirements, exclusion zones, and identified victim locations;
• Receive real-time breach notifications or patrol alerts based on geofencing rules, GPS tracking data, or manually logged incidents.

In addition, the platform should support direct integration with third-party technologies already in use by police services, including:

• Recovery Science ankle monitoring systems (GPS-enabled);
• Mobile panic buttons issued to high-risk victims via victim services or police;
• Records management systems (RMS) such as Niche and Versaterm;
• National-level databases such as CPIC, where technically feasible.

Ontario’s existing Esri-based Bail Dashboard already offers a functional prototype for this level of integration. Although its current deployment is largely limited to firearm-related bail cases, the platform supports geospatial visualization, address flagging, and multi-jurisdictional coordination. The underlying infrastructure is capable of scaling to include a wider range of offences and condition types, subject to structured data entry at the point of judicial release.⁵⁸⁴

3.3.3. Visualization of Supervision Conditions

At present, most legal conditions are recorded in unstructured formats and are not geocoded. Offenders released on bail or probation may be restricted from attending certain addresses or areas, but these conditions are not visualized within patrol systems. Officers responding to calls or conducting compliance checks must rely on memory, paper records, or static CPIC entries. This creates a disconnect between judicially imposed risk controls and operational enforcement.

In contrast, a GIS-enabled compliance dashboard would allow conditions to be mapped dynamically. Officers could view exclusion zones, curfews, or address restrictions alongside real-time location data. For example, if an individual is subject to a condition not to come within 500 metres of a specific address, the dashboard could automatically generate a buffer zone and trigger a patrol alert when the zone is breached.

These features are already in use through internal police mapping tools developed under the Esri platform. In Toronto and Durham, for example, the “Pushpin” system allows officers to receive live alerts when driving into exclusion zones associated with high-risk individuals. A fully integrated provincial system would apply the same logic to supervision orders originating in any jurisdiction.⁵⁸⁵

3.3.4. Integration with Victim Safety Infrastructure

A comprehensive dashboard must also be capable of incorporating victim-held safety tools. Victims who have received mobile panic buttons should be able to opt into GPS-linked protection protocols, allowing their location to be mapped privately within the platform. In this model, if an offender under a no-contact or geographic restriction condition comes within a specified range of the victim, both the victim and the nearest patrol unit can be notified automatically.

Such a system would also allow case managers and police personnel to log attempted compliance checks, track failed contacts, and view longitudinal patterns of engagement. Repeated avoidance of compliance verification—such as failing to answer the door during curfew hours—could be flagged as an enforcement priority, even where no explicit breach has yet been confirmed.

3.3.5. Operational Alignment with Risk Assessment Tools

The dashboard should also support the integration of validated risk assessment scores—such as the Ontario Domestic Assault Risk Assessment (ODARA), Static-99R, or the Level of Service Inventory (LSI-CMI)—into the interface. These scores should not be used for prediction or labelling, but rather as an additional triage layer to assist in resource prioritization.

For example, officers tasked with conducting curfew checks or surveillance patrols could filter the dashboard by risk level, ensuring that high-risk cases receive proportionate enforcement attention. Crown attorneys, probation officers, and case managers could similarly use this information to coordinate supervision intensity across multiple agencies.

Risk scores would not need to be publicly displayed or attached to the individual’s profile in perpetuity. Rather, they could be integrated into the dashboard via tiered access controls, aligned with role-specific permissions and subject to audit protocols. This aligns with current practices in systems such as SCOPE, where certain types of sensitive data are available only to designated users under defined conditions.

3.4 Court Data Entry as the Critical Bottleneck

3.4.1. Structural Dependency on Paper-Based Judicial Outputs

Ontario’s current compliance monitoring infrastructure is constrained not by technology, but by upstream data capture processes that remain functionally analogue. When an individual is released on bail or probation, their legal conditions are entered by courtroom staff into a form-based system that generates a flat PDF. This document, typically printed and signed by the justice of the peace and the accused, serves as the authoritative record of conditions. The PDF is then scanned, emailed, or manually distributed to Crown attorneys, police services, and probation officers.

These documents are not automatically uploaded to any centralized database, nor do they contain structured data fields that would allow for easy parsing, mapping, or automated integration. The result is a persistent and system-wide reliance on manually transcribed conditions—each one copied from a static document into multiple uncoordinated systems by different actors, often under time pressure and without standardized verification protocols.

3.4.2. Limitations in Police and Crown Data Systems

Once the flat PDF is distributed, its content must be re-entered into police Records Management Systems (RMS) such as Niche or Versaterm. These systems do not accept structured imports from the court. Instead, staff must manually create an “occurrence” entry, assign it to a known subject, and transcribe the bail or probation conditions into a text field. Character limits often require conditions to be shortened or paraphrased, increasing the risk of omission or misinterpretation.

Only one address can be entered into most RMS platforms per subject record. Conditions involving multiple approved residences—or complex restrictions such as school zones, daycare centres, or employer locations—must be noted informally in officer notes or ancillary fields, if at all.

Crown attorneys rely on separate systems such as SCOPE, which may or may not receive timely updates from the courts, probation, or police. Conditions that have been varied orally in court—through JP-approved amendments or negotiated modifications—are often not captured in any real-time database, particularly if the variation occurs without a new signed recognizance.

3.4.3. Risk of Mismatched or Outdated Data

This fragmented entry process introduces multiple opportunities for delay, distortion, or outright error. Address entries may be misspelled, unverified, or inconsistently formatted, preventing effective geolocation. Conditions that restrict proximity to specific individuals or institutions (e.g., “not to attend within 100 metres of [victim’s child’s school]”) are rarely entered in a way that enables mapping or real-time alerting. Court staff are not required to geocode addresses or verify that the written condition corresponds to a mappable location. Police staff entering these records may be unfamiliar with the context or unable to identify the intended location without clarification from the Crown.

Variations to bail or probation conditions—whether granted formally by a judge or informally amended in courtroom discussion—often take days or weeks to be updated across systems. In some instances, the accused may have a signed copy of a variance before the relevant enforcement body is even aware that the conditions have changed. Officers conducting curfew checks, patrols, or compliance monitoring may rely on outdated information, unknowingly enforcing superseded conditions or overlooking active restrictions.

Victims and service providers are similarly affected. A victim relying on a no-contact order may believe they are protected from contact at home, work, or school, when the actual condition has been narrowed—or never formally recorded in a way that can be cross-referenced. Because court-issued orders are not stored in a searchable, real-time provincial system, there is no way to confirm the current version of a recognizance or restraining order across agencies.

3.4.4. Implications for Compliance Dashboards and Risk Monitoring

The value of any compliance dashboard is directly linked to the quality and reliability of the data it receives. If underlying records are delayed, incomplete, or inaccurate, the dashboard cannot function as an effective tool for enforcement or public safety. Its visualizations will reflect a partial or outdated picture of offender conditions, and its automated alerts—such as geofence breaches or curfew violations—will be tied to baseline assumptions that may no longer hold.

As the volume of community supervision orders increases, and as Ontario considers expanding monitoring systems to include IPV, SV, and HT offenders, the limitations of the current data entry system become more consequential. The bottleneck is not merely technical—it is procedural, rooted in the structure of courtroom documentation and the absence of real-time, structured data integration at the point of judicial decision.

Without reform at this foundational level, even the most advanced GIS-enabled compliance system will remain dependent on static documents, informal workarounds, and reactive enforcement.

3.5 Direct Entry Systems as the Foundation for Modernization

3.5.1. The Need for Structural Data Reform

Ontario’s current compliance monitoring infrastructure lacks a mechanism to capture judicial decisions in structured, real-time formats. Conditions imposed at bail, sentencing, or during probation intake must be entered manually from static documents, often by individuals far removed from the original proceeding. This introduces systemic delays and errors in enforcement visibility, undermining the potential of modernized tools such as the Bail Dashboard or geofencing-based patrol alerts.

To address this, Ontario will require the implementation of direct-entry systems within courtrooms and probation offices that allow data to be captured once—at the source—and automatically transmitted to all relevant agencies, including police, Crown, probation, victim services, and centralized compliance dashboards. This is not an information technology upgrade; it is a foundational redesign of how supervision conditions are recorded, shared, and enforced across systems.

Feasibility and Precedents

Functionally, direct entry systems already exist in other domains. Ontario’s SCOPE platform, used by Crown attorneys, offers a role-based access model with multi-tier visibility. Data entered into SCOPE is structured, timestamped, and viewable according to user permissions.

The technical infrastructure for such a model already exists within Esri’s enterprise platform, which is used across Ontario municipalities and ministries. What is required is not new software, but integration: a structured, court-facing interface for condition entry; back-end systems capable of transmitting these conditions to linked platforms; and standardized protocols for data format, role-based access, and update verification.

3.5.2. Proposed System Design

A direct-entry system would allow clerks, justices of the peace, or court registrars to enter conditions into a structured form—similar in appearance to current recognizances, but fully digital. Once the form is approved and finalized, the conditions would be automatically:

• Transmitted to police RMS systems and CPIC (where applicable);
• Shared with the Crown’s case management system (e.g., SCOPE);
• Made available to probation and parole officers (if relevant);
• Integrated into the provincial compliance dashboard for real-time monitoring;
• Flagged to victim services where notification protocols apply.

The interface could include dropdown menus for common conditions, structured address fields (with integrated postal code verification), and geocoding of restricted zones. Jurisdictions could configure access levels to protect sensitive data while ensuring operational users receive timely updates. Variations to conditions could be logged directly by court staff and flagged to enforcement bodies as high-priority changes.

Critically, this system would retain the ability to print a paper copy of the recognizance or order for the accused or for court record-keeping purposes. The existence of a digital database does not eliminate the need for physical documentation but ensures that the system no longer relies exclusively upon it.

3.5.3. Anticipated Benefits

A centralized, structured direct-entry system would eliminate the most error-prone and resource-intensive component of Ontario’s current enforcement infrastructure: manual re-entry of legal conditions across multiple disconnected systems. It would ensure that all supervision conditions—bail, probation, 810s, family court—are recorded once, by the individual authorized to impose them, and are available to all parties with a legal or operational need to know.

For law enforcement, this means officers conducting compliance checks would have access to accurate, real-time information about current conditions, including verified addresses, curfews, and exclusion zones. For victims, it means that violations could be detected and acted upon without requiring the victim to report a breach or verify the terms of an order themselves. For probation officers and Crowns, it provides a reliable, current record of all relevant conditions, reducing administrative burden and improving coordination across cases.

Over time, the same infrastructure could support real-time data analytics to track patterns of breach, identify geographic hotspots of supervision non-compliance, and support the development of evidence-based enforcement strategies. These improvements are not contingent on new legislation but require coordinated inter-ministerial implementation and structured operational design.

3.6 Recommendations

3.6.1. Recommendation 1: Establish a Direct-Entry System for Court-Imposed Supervision Conditions

Context and Purpose: Ontario’s current method of documenting and transmitting court-imposed supervision conditions relies on the generation of static PDF documents by courtroom clerks. These documents must then be manually transcribed into multiple disconnected systems—police records management systems, probation databases, Crown case management files, and compliance dashboards. This fragmented process introduces delays, transcription errors, and inconsistent enforcement visibility across jurisdictions.

A centralized direct-entry system would allow supervision conditions—such as curfews, no-contact orders, and geographic restrictions—to be entered once, at the time of imposition, into a structured, searchable database. This information could then be automatically distributed to all relevant system partners, including police, probation, Crown attorneys, and compliance dashboards. Eliminating redundant entry would ensure consistency and enable real-time enforcement visibility across supervision types.

Jurisdiction: Lead responsibility: Ministry of the Attorney General (MAG). Supporting roles: Ministry of the Solicitor General (SolGen), Ministry of Children, Community and Social Services (MCCSS), and any ministry responsible for digital service delivery.

Recommendation: The Government of Ontario should develop and implement a structured, courtroom-integrated direct-entry system to replace static PDF-based documentation of supervision conditions. This system should:

• Enable authorized court personnel to input supervision conditions into a structured digital interface at the time they are imposed;
• Include all supervision types: bail conditions, probation orders, conditional sentence orders, section 810 peace bonds, common law recognizances, and family court protection orders;
• Format entries using validated address fields, condition templates, and geocoding to support visualization and system interoperability;
• Automatically transmit finalized conditions to police RMS platforms, Crown case management systems (e.g., SCOPE), probation files, CPIC (where applicable), and provincial compliance dashboards;
• Support real-time updates for condition variations, cancellations, and enforcement status changes;
• Retain the ability to generate printed copies of orders or recognizances for use by the accused, counsel, and the court.

Implementation Considerations: Courtroom technology and staffing capacity vary across jurisdictions, and some locations may require equipment upgrades or training support. Stakeholder engagement with court administrators and judiciary representatives may be necessary to ensure that the interface aligns with current workflows. Integration with multiple downstream systems—including RMS platforms, SCOPE, probation records, and the Bail Dashboard—will require coordinated development and governance. Special care will be required to manage disclosure rules, access controls, and audit protocols. A phased implementation may be necessary to accommodate jurisdictional differences and reduce rollout risk.

Rationale: Supervision conditions imposed by Ontario courts—including bail terms, probation orders, peace bonds, and restraining orders—are currently captured through static documents that must be transcribed manually into separate enforcement systems. This redundant and error-prone process impairs real-time enforcement, delays breach detection, and undermines coordinated supervision. A structured direct-entry system would allow these conditions to be recorded once and transmitted instantly to all relevant partners. This foundational upgrade is essential to enabling modern, risk-informed, cross-jurisdictional enforcement in cases involving intimate partner violence, sexual violence, human trafficking, and related offences.

3.6.2. Recommendation 2: Expand the Compliance Dashboard to Include All High-Risk Supervision Categories

Context and Purpose: Ontario’s provincial Bail Dashboard was initially developed to support real-time monitoring of individuals on bail for firearm- and gang-related offences. The dashboard, built on the Esri Canada platform, allows police officers to view geospatial representations of active conditions—such as mandated residence, curfews, and exclusion zones—and to track compliance across jurisdictions. However, the dashboard’s current deployment scope is limited. It is not required to include individuals on bail for intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), or animal cruelty, despite these offences frequently involving repeat patterns of harm, victim targeting, and escalatory risk.

The dashboard also excludes section 810 peace bonds, common law peace bonds, family court restraining orders, and probation orders—even when those orders contain curfews, geographic restrictions, or no-contact conditions. As a result, many of the individuals posing the highest risk to victims or the public are not visible in Ontario’s primary enforcement interface for community supervision.

Jurisdiction: Lead responsibility: Ministry of the Solicitor General (SolGen). Supporting roles: Ministry of the Attorney General (MAG), Ministry of Children, Community and Social Services (MCCSS), Ontario Provincial Police (OPP).

Recommendation: The Government of Ontario should expand the scope of its provincial compliance dashboard to include all high-risk supervision categories. Specifically, the dashboard should:

• Include all individuals on bail for offences flagged as IPV, SV, HT, or animal cruelty;
• Incorporate section 810 peace bonds, common law recognizances, and family court restraining orders, where conditions include geographic, contact, or behavioural restrictions;
• Include probation orders, conditional sentence orders, and provincial parole conditions, where those orders contain terms that affect spatial movement, curfews, associations, or contact with specific persons or locations;
• Allow enforcement users to visualize supervision conditions across these categories through a single, integrated interface;
• Ensure that integration of each supervision type follows standardized data formatting and includes role-based access, with appropriate protections for sensitive case information.

Implementation Considerations: Expanding the dashboard’s scope will require system upgrades, data pipeline development, and technical integration across multiple ministries and court systems. Court-imposed conditions not currently digitized in structured formats—such as restraining orders or common law recognizances—will require upstream reforms, as addressed in Recommendation 1. Role-specific visibility rules will be necessary to limit access to sensitive information, particularly where non-criminal orders are involved. Police and probation services may require updated training on dashboard use and data interpretation. Data consistency and address standardization will be essential to support reliable geospatial mapping.

Rationale: Ontario’s most serious forms of interpersonal violence often involve supervision conditions that mirror those already tracked in firearm-related bail cases. However, these cases remain invisible within the province’s primary compliance dashboard due to categorical exclusions. By expanding the dashboard’s scope to include all high-risk supervision types—including IPV, SV, HT, animal cruelty, probation, peace bonds, and family court orders—Ontario can ensure that enforcement personnel have a complete and real-time picture of offender obligations. This visibility is foundational to effective, coordinated, and risk-informed community supervision.

3.6.3. Recommendation 3: Integrate Validated Risk Assessment Tiers into Dashboard Functionality

Context and Purpose: Ontario uses a range of validated risk assessment tools across justice and correctional systems, including the Ontario Domestic Assault Risk Assessment (ODARA), Static-99R, STABLE/ACUTE, the Level of Service Inventory (LSI/LSI-CMI), and the Domestic Violence Risk Management (DVRM) tool. These tools support supervision planning and safety decision-making by classifying individuals according to risk of recidivism or escalation.

Currently, risk assessment results are not operationalized within Ontario’s compliance dashboard. Police officers conducting curfew checks or responding to breach calls do not have access to risk-tier indicators unless separately communicated. Likewise, enforcement resources cannot be allocated based on structured risk levels, despite the fact that supervision conditions may be identical across individuals with very different profiles of predicted harm.

Integrating risk tiers into the dashboard—subject to role-based access controls—would allow agencies to prioritize high-risk cases for compliance checks, enforcement follow-up, or geofence monitoring, while protecting the confidentiality of underlying scores.

Jurisdiction: Lead responsibility: Ministry of the Solicitor General (SolGen). Supporting roles: Ontario Provincial Police (OPP), municipal police services, Ministry of the Attorney General (MAG), probation services.

Recommendation: The Government of Ontario should enable the integration of validated risk assessment tiers into its provincial compliance dashboard to support enforcement triage and prioritization. Specifically, the system should:

• Permit risk scores from tools such as ODARA, Static-99R, STABLE/ACUTE, LSI-CMI, and DVRM to be uploaded into the dashboard interface, with linkage to individual profiles under supervision;
• Display simplified tier indicators (e.g., low, moderate, high, very high) to authorized users only, with no disclosure of raw scores, tool types, or scoring details;
• Restrict access to risk tier data to defined personnel, such as police, designated Domestic Violence Risk Coordinators (DVRCs), and probation officers;
• Use tier indicators to support filtering, mapping, and prioritization functions within the dashboard, allowing enforcement activities to be proportionate to assessed risk;
• Ensure that all access is logged, auditable, and compliant with existing privacy legislation and professional standards.

Implementation Considerations: Not all supervising bodies currently enter risk scores into shared systems, and some tools (e.g., DVRM, LSI-CMI) are not centrally stored in machine-readable formats. Standardizing intake, storage, and tier conversion will require technical coordination with probation, police, and Crown IT platforms. Role-based access controls must be strictly defined and may require updates to user account permissions across partner systems. Score visibility rules must be aligned with the evidentiary limitations of each tool to prevent misinterpretation or misuse in non-expert settings. Appropriate safeguards will be required to avoid unauthorized use of sensitive risk indicators in frontline interactions.

Rationale: Validated risk assessments are widely used across Ontario’s justice and supervision systems, but their operational utility remains limited by lack of integration. Enabling enforcement personnel to prioritize cases based on risk—without disclosing sensitive or evidentiary data—supports efficient resource allocation and targeted community protection. By embedding tier indicators within the compliance dashboard, Ontario can align enforcement visibility with empirical risk, reduce arbitrary prioritization, and enhance coordination across police, Crown, and supervision partners.

3.6.4. Recommendation 4: Consolidate Bail, Probation, and Protection Order Monitoring into a Unified Compliance Dashboard

Context and Purpose: Ontario currently lacks a unified system for monitoring individuals subject to supervision conditions in the community. Bail conditions are entered into police records management systems (RMS) and visualized selectively through the dashboard. Probation conditions are retained within the Ministry of the Solicitor General and accessible to police but not proactively monitored. Section 810 peace bonds and family court restraining orders are stored in yet other systems, often in formats that are not searchable or mappable.

At the same time, probation officers—while critical to offender rehabilitation and reintegration—are not operationally positioned to enforce curfews, geographic restrictions, or other conditions requiring field verification. Police services are equipped for community-based enforcement but lack access to the full range of supervision data needed to monitor compliance across domains.

To close this gap, Ontario requires a unified, GIS-enabled compliance dashboard accessible to police and authorized partners. This platform must consolidate bail, probation, and protection order conditions into a single interface. Responsibility for field-based compliance monitoring and breach enforcement—particularly for conditions involving time, geography, or movement—should be downloaded to police services as the only actors positioned to provide real-time enforcement capacity.

Jurisdiction: Lead responsibility: Ministry of the Solicitor General (SolGen). Supporting roles: Ontario Provincial Police (OPP), municipal police services, Ministry of the Attorney General (MAG), Ministry of Children, Community and Social Services (MCCSS), probation services.

Recommendation: The Government of Ontario should consolidate all active supervision conditions into a single, integrated compliance dashboard accessible to police and other authorized enforcement users. As part of this consolidation, operational responsibility for field-based compliance monitoring and breach enforcement should be assigned to police services. Specifically, the dashboard should:

• Consolidate and display conditions imposed through bail, probation, conditional sentence orders, section 810 peace bonds, common law recognizances, and family court restraining orders;
• Present these conditions in a unified geospatial interface that allows police to view, filter, and act on current supervision obligations across all supervision types;
• Enable role-based access for other authorized users (e.g., Crown attorneys, DVRCs, probation officers), with tiered visibility based on supervision authority;
• Provide real-time alerts for curfew breaches, geographic violations, or other flagged conditions;
• Assign responsibility for compliance verification, breach laying, and field-based enforcement to police services, relieving probation officers of these operational tasks.

Implementation Considerations: Integrating data from multiple supervision types will require harmonization of condition formats, address verification, and standardization of breach definitions across ministries. Role-based access policies must be carefully designed to respect privacy, particularly in family law and non-criminal contexts. Police services may require additional staffing or technology supports to absorb new enforcement responsibilities, particularly in rural jurisdictions. Clear coordination protocols will be needed to ensure that probation officers remain informed of breaches and can adjust supervision strategies accordingly.

Rationale: Ontario’s current supervision infrastructure is fragmented, with different conditions tracked in disconnected systems and enforced inconsistently across actors. Police officers conducting compliance work are unable to view probation or family court conditions; probation officers cannot monitor conditions requiring real-time response. Victims are left navigating a system in which enforcement varies by supervision type. By consolidating all conditions into a unified compliance dashboard—and assigning enforcement responsibility to police—Ontario can ensure that high-risk conditions are monitored consistently, breaches are detected promptly, and public safety responses are coordinated across ministries.

3.6.5. Recommendation 5: Enable Optional Victim-Integrated Safety Features Within the Compliance Dashboard

Context and Purpose: Victims of intimate partner violence (IPV), sexual violence (SV), and human trafficking (HT) are frequently subject to ongoing risk from individuals who have been released under supervision conditions—often with geographic restrictions or no-contact orders in place. While these conditions may be enforceable in principle, real-time breach detection typically depends on the victim recognizing the violation and contacting police. This model places a disproportionate burden on victims and often results in delayed or reactive enforcement.

Esri Canada’s GIS-enabled models demonstrate that it is technically feasible to link offender movement data to exclusion zones and alert systems. GPS-based panic buttons and mobile safety apps are already in limited use in Ontario, but they are not integrated into enforcement dashboards. Creating a secure, opt-in mechanism for linking victim-identified exclusion zones to dashboard alerts could materially improve response times and enforcement coordination, particularly in high-risk cases.

Jurisdiction: Lead responsibility: Ministry of the Solicitor General (SolGen). Supporting roles: Ministry of Children, Community and Social Services (MCCSS), Ontario Provincial Police (OPP), municipal police services, and funded victim services agencies.

Recommendation: The Government of Ontario should support the development of optional, consent-based safety features within the provincial compliance dashboard to enable victim-integrated enforcement visibility. These features should:

• Allow victims, with appropriate consent and support, to designate specific exclusion zones (e.g., home, workplace, school) that are monitored for breaches in real time;
• Enable integration with GPS-enabled offender monitoring devices (e.g., Recovery Science ankle bracelets) to generate automatic alerts to police when an offender enters a restricted area;
• Support integration with mobile panic button applications used by victim services or police services, allowing alert activation to trigger enforcement response and flag case status in the dashboard;
• Restrict access to victim location data to defined personnel under role-based permissions, with audit trails and anonymization features where required;
• Be fully voluntary, with victims able to withdraw or modify participation at any time without affecting eligibility for other safety supports.

Implementation Considerations: Any integration of victim data into compliance dashboards must be governed by strict privacy, consent, and security protocols. Role-based access controls must be clearly defined, and participation must remain entirely optional. Not all jurisdictions currently have access to panic button technology or GPS monitoring capacity; functionality may need to be phased in over time. Victim services agencies will require clear guidance on informed consent procedures, data handling, and technical troubleshooting. Alert fatigue and false positives must be addressed through appropriate threshold settings and officer training.

Rationale: Victims of high-risk interpersonal violence should not bear the responsibility for monitoring compliance with their own protection orders. By enabling structured, opt-in integration between victim-designated zones and existing compliance dashboards, Ontario can materially improve the speed and effectiveness of enforcement responses. These features build on existing technology, align with victim consent models already in use, and support a proactive rather than reactive approach to community safety.

Section 4: Risk Assessments

4.1. Introduction to Risk Assessments

Risk assessment is a foundational element of Ontario’s institutional response to intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), and child abuse. These assessments are used to estimate the likelihood that an individual will reoffend or escalate in harm, and to inform decisions about supervision, protection, intervention, and system prioritization. Risk assessments are also used to flag individuals for internal tracking, to determine the intensity of community supervision, and to allocate public safety and victim support resources. They are distinct from protocols/measures/tools/guides used, or that should be used, across a range of systems to identify IPV, SV, HT and/or family violence such as the Department of Justice HELP guide (for family law professionals), the MASIC (for mediators), screeners designed for use by the health system, and those designed to capture risks specific to Ontario’s diverse populations.

In Ontario, risk assessments are administered by a range of actors across multiple systems. Police services use actuarial or structured tools to score risk at the point of arrest or investigation. Probation officers use general risk/needs instruments to inform supervision strategies. Shelters and victim services conduct victim-centred risk assessments to inform safety planning. Children’s Aid Societies use child-focused frameworks to determine whether exposure to violence constitutes a risk of harm. Federal institutions use specialized risk assessments to manage sexual and violent offenders under federal supervision.

These assessments vary widely in purpose, design, and methodology. Some rely on historical offence data to produce a static risk score. Others require professional judgment or clinical interpretation. Still others are dynamic in nature, tracking change over time to guide case management. While these tools are validated within their own domains, Ontario does not have a province-wide risk assessment framework or standard. There is no consistent mandate governing which tools should be used, by whom, or how results should be shared or interpreted.

The absence of a coordinated strategy means that similar cases may be assessed differently depending on which agency is involved. This makes sense, as different agencies have access to different information relevant to risk and rely on risk assessment measures for guiding different decisions. Problematic though is that results may be recorded in isolated systems and not shared across sectors. Police may not see probation risk scores; probation may not have access to police assessments or bail conditions; child protection may be unaware of recent convictions or court orders. In many cases, multiple risk assessments are conducted independently, using different tools and frameworks, with no mechanism for comparison or consolidation.

This section of the report outlines the core risk assessment tools currently used in Ontario, the systems in which they operate, and the structural barriers that prevent risk data from being shared or coordinated. It also describes related mechanisms—such as offender flagging systems, Situation Tables, and the role of Domestic Violence leads within policing that are intended to support early identification and ongoing management of high-risk individuals. Taken together, these tools and systems form the backbone of Ontario’s violence prevention infrastructure. However, they remain siloed, inconsistently implemented, and under-leveraged in their current form.

4.2. Overview of Risk Assessment Tools Currently Used in Ontario

Ontario’s intimate partner violence (IPV), sexual violence (SV), and child protection systems rely on a range of risk assessment tools to identify, predict, and manage the likelihood of future harm. These tools fall into three general categories:

• Actuarial tools, which assign risk scores based on static historical factors (e.g., ODARA, Static-99R);
• Structured Professional Judgment (SPJ) tools, which guide evaluators through evidence-based factors but leave final judgement to professional interpretation (e.g., SARA, B-SAFER, DVRM, SVR-20);
• Dynamic tools, which track short- and long-term changeable factors over time (e.g., STABLE-2007, ACUTE-2007, LSI-CMI).

These instruments are used across various systems, including:

• Police (ODARA, B-SAFER);
• Shelters and victim services (Danger Assessment);
• Probation and community supervision (LSI-CMI, B-SAFER, Static-99R/STABLE/ACUTE in some cases);
• Child protection services (Eligibility Spectrum, Comprehensive Family Risk Assessment);
• CSC and forensic evaluators (for federally sentenced or high-risk sexual offenders).

Each tool has different objectives, methodologies, and scopes of use. Some, like ODARA and LSI-CMI, are used at intake for supervision planning. Others, like SARA, are reserved for complex, high-risk cases requiring psychological evaluation. Still others, such as the Eligibility Spectrum used by Children’s Aid Societies (CAS), are designed for screening and triaging risk to children rather than criminal violence.

Although many of these risk assessment systems are standardized within the services they are administered, Ontario does not currently have a standardized or integrated approach to sharing information about risk assessment across its justice, child protection, or victim service sectors. Each agency is responsible for selecting its own tools, determining when and how they are used, and storing the results in sector-specific systems. In practice, this means that risk assessments are conducted independently using different frameworks and criteria, with no requirement that results be shared, compared, or even acknowledged across institutions.

This structural disconnection reduces Ontario’s overall capacity to identify and respond to escalating risk in a coordinated manner. It also limits the utility of risk assessment tools themselves. The predictive value of a validated instrument depends on the assumption that results will inform downstream decisions. Where those results are isolated—unseen by bail courts, unshared with child protection, or inaccessible to victim services—the tool’s capacity to support intervention is lost.

4.2.1. Danger Assessment (DA) and Its Application in Ontario

Overview and Purpose

The Danger Assessment (DA), developed by Dr. Jacquelyn Campbell, is a validated risk assessment tool specifically designed to assess the risk of homicide or severe injury for victims of intimate partner violence (IPV). Unlike offender-focused tools such as ODARA, the DA is victim-centred, utilizing structured interviews conducted directly with victims to identify and evaluate the severity of risk factors associated with potential lethality or severe harm. The DA addresses specific indicators such as prior attempts at strangulation, threats involving firearms, extreme jealousy, and coercive control behaviours, all widely recognized as predictors of lethal outcomes in IPV situations.⁵⁸⁶

Administration and Frequency of Updates in Ontario Shelters

In Ontario, the DA is primarily administered by trained frontline staff within women’s shelters and community-based victim services. Typically, administration occurs during initial client intake to immediately establish a clear understanding of the victim’s risk profile and to inform initial safety planning strategies. After this initial assessment, the DA is updated either on a scheduled basis, often weekly, or when there are significant changes reported by the victim—such as new incidents of violence, changes in relationship status, or shifts in the victim’s perceptions of danger. Due to the dynamic nature of IPV risk, frontline workers regularly revisit and update the DA to ensure safety plans remain relevant and effective.

Integration with Safety Planning and Limitations in Inter-agency Information Sharing

Shelters and victim service providers in Ontario routinely integrate DA results into individualized victim safety plans, guiding immediate protective interventions and longer-term support strategies. However, despite its central role within shelters, the DA is typically not shared externally. As a result, critical risk information gathered through the DA generally remains siloed within the agency conducting the assessment. This isolation prevents vital risk data from informing broader justice responses, including bail conditions, probation supervision, child protection investigations, or coordinated offender management strategies.

Provincial Training and Standardization Issues

Currently, Ontario does not mandate standardized provincial training for frontline workers administering the DA. Instead, training practices vary significantly among individual shelters and community agencies, depending on available resources and internal organizational policies. This inconsistency results in varied levels of expertise and confidence among frontline workers, potentially undermining the reliability and uniformity of risk assessments conducted across different shelters and agencies. Frontline practitioners and shelter administrators frequently identify limited or unpredictable provincial funding as a critical barrier to providing consistent and standardized DA training for their staff.

Implications of Current Implementation Practices

The present system of DA administration in Ontario—with inconsistent training, limited inter-agency communication, and siloed information management—compromises the province’s overall capacity to effectively identify and manage IPV risks. Given the established predictive validity of the DA in preventing lethal IPV incidents, improving these operational gaps represents a clear opportunity to significantly enhance victim safety, offender accountability, and inter-agency cooperation across Ontario’s IPV response framework.

4.2.2. Ontario Domestic Assault Risk Assessment (ODARA)

Overview and Purpose

The Ontario Domestic Assault Risk Assessment (ODARA) is a 13-item actuarial risk assessment tool designed to predict the likelihood of future domestic assaults against intimate partners. It was developed through a collaboration between the Ontario Provincial Police (OPP) Behavioural Sciences and Analysis Section and the Waypoint Centre for Mental Health Care, in response to the recommendations of the Arlene May and Gillian Hadley inquests and the 1999 Joint Committee on Domestic Violence to the Attorney General of Ontario. ODARA is notable as the first empirically validated tool developed specifically to assess the risk of IPV recidivism in Canada.⁵⁸⁷

ODARA scores range from 0 to 13 and are used to rank male IPV offenders in seven risk categories, each associated with a likelihood of future violence. The items assess a combination of static factors, including criminal history (domestic and nondomestic violence), victim vulnerability, and circumstances of the most recent assault. Higher ODARA scores are associated not only with a greater likelihood of recidivism, but also with shorter time to reoffence, increased injury severity, and greater frequency of future assaults.⁵⁸⁸

Administration and Use in Ontario

Originally designed for use by police officers, ODARA is now widely used across Ontario and other Canadian jurisdictions⁵⁸⁹ by a range of justice and community professionals, including probation officers, Crown attorneys, correctional staff, and victim services providers. It is typically administered shortly after an IPV-related arrest and is used to inform decisions related to bail, release planning, supervision intensity, and, in some jurisdictions, to assist in high-risk case flagging.

Unlike structured professional judgment tools, ODARA does not require interviews or clinical expertise. All items can be scored using police and court records. While the tool was initially validated using heterosexual male offender samples, recent research has extended ODARA’s application to female offenders⁵⁹⁰ and dating relationships, although use with same-sex couples and transgender individuals remains unvalidated and is not currently recommended.

Importantly, ODARA does not require a formal conviction to be used. It can be scored based on any incident where the police record indicates a probable assault, allowing it to be applied in bail briefs or safety planning at an early stage in proceedings.⁵⁹¹ ODARA scoring has demonstrated interrater reliability and predictive validity across studies.⁵⁹²

Limitations and Critiques

While ODARA is an accessible and efficient risk triage tool, it has limitations. It was not designed to predict lethality, and the dataset used in its development did not include completed homicides. However, later research has shown that offenders who eventually commit intimate partner homicide typically fall into the tool’s highest risk category.⁵⁹³ The tool, like all other risk assessment tools, must be used in combination with action on risk management and additional safety planning strategies when these domains are present.

The tool’s emphasis on static factors also means it cannot be used to track changes in risk over time. It is a point-in-time estimate, not a dynamic monitoring tool. As a result, it may be less useful in ongoing supervision or rehabilitation contexts unless combined with dynamic assessments such as STABLE-2007 or LSI-CMI.

Practical Implications

ODARA is Ontario’s most widely used IPV risk assessment tool and is endorsed by many justice professionals for its speed, simplicity, and empirical foundation.⁵⁹⁴

ODARA’s ease of administration, strong validation record, and role in standardizing risk communication across agencies make it a foundational tool for any provincial risk assessment modernization strategy. However, it should be reviewed—along with other tools—for potential updates to incorporate emerging risk domains, improve applicability across genders and relationship types, and expand its utility in dynamic risk contexts.

4.2.3. Domestic Violence Risk Appraisal Guide (DVRAG)

Overview and Purpose

The Domestic Violence Risk Appraisal Guide (DVRAG) is a 14-item actuarial tool developed to estimate the likelihood that a male offender will commit future violence against a female intimate partner.⁵⁹⁵ It was designed as a second-generation extension of the Ontario Domestic Assault Risk Assessment (ODARA), combining ODARA’s static, offence-based predictors with a total score from the Psychopathy Checklist–Revised (PCL-R) to incorporate clinical risk traits such as antisociality.⁵⁹⁶

Administration and Use in Ontario

Unlike ODARA, which can be scored using standard police records, the DVRAG requires access to comprehensive clinical or correctional information, including a validated PCL-R score produced by a trained evaluator using structured interviews and collateral data. As such, the DVRAG is designed for use by forensic clinicians and criminal justice professionals with specialized expertise.

Its administration is typically limited to high-risk contexts such as Dangerous Offender proceedings, Long-Term Supervision Order assessments, or post-conviction forensic evaluations. In practice, the DVRAG is not used by frontline police, probation officers, or community-based agencies. Its complexity and resource requirements have restricted its application to institutional or court-mandated assessments conducted by psychologists and other forensic specialists.

Limitations and Critiques

The DVRAG’s primary limitation is its dependence on the PCL-R, which requires formal certification, semi-structured interviews, and corroborating documentation. This makes it impractical for use in community or first-response settings. As a result, the DVRAG remains inaccessible to many justice system professionals and is rarely used outside institutional contexts.

The DVRAG was developed and validated exclusively using heterosexual male IPV offenders. It is not empirically supported for use with women, adolescents, or individuals in same-sex relationships. These population constraints can limit its generalizability and may render it unsuitable for broad application in diverse IPV cases. The tool also does not explicitly assess non-physical risk factors such as coercive control, stalking, or the involvement of animals, which are increasingly recognized as important dimensions of partner violence.

Finally, while the DVRAG is empirically sound, it is not integrated into any provincial framework for coordinated risk assessment. In Ontario, there is no formal mechanism to guide when or how DVRAG assessments are ordered, how results are shared, or how they relate to other actuarial or structured judgment tools.

Practical Implications

Despite its limitations, the DVRAG remains one of the most statistically robust IPV risk tools available in Canada. Its inclusion of clinical indicators—especially psychopathy—makes it particularly valuable in high-risk or chronic offender cases. The DVRAG has demonstrated predictive validity across domestic violence, general violence, and general criminal recidivism.⁵⁹⁷ Given its intended use in post-conviction or institutional contexts, it may be particularly useful in tertiary prevention and forensic triage strategies.

In Ontario, the DVRAG could play a strategic role in complex offender management, especially in contexts involving multi-agency oversight or GIS-based risk monitoring. Used alongside ODARA, it can add depth to risk profiles by capturing personality-based factors not evident in criminal records alone.

4.2.4. Domestic Violence Supplementary Report (DVSR)

Overview and Purpose

The Domestic Violence Supplementary Report (DVSR) is an updated version of the Domestic Violence Risk Management (DVRM) tool, a structured professional judgment (SPJ) instrument originally developed by an expert committee at the Ontario Police College. In its most recent form, the DVSR assessment form consists of a list of 19 risk factors, including a history of violence, access to firearms, sexual abuse, and bizarre and/or unexplained behaviour. Its format also allows for some professional judgement in key risk areas.

The DVSR is often submitted as part of the Crown/Court Brief to be used by the Crown Prosecutor at different stages of the criminal court process including the bail hearing stage to assist police officers and justice partners in assessing and identifying risk of potential harm and to ultimately assist with intervention and safety planning.

The DVSR also provides a means of assessing risk in cases not eligible for the ODARA. Although there are strengths in terms of the range of factors captured by the DVSR, it is important to note that there is less research on this tool.

While the DVSR does not generate a numeric score, it provides a structured framework to support decision-making and professional judgment. It is frequently used in conjunction with ODARA in Ontario justice settings to supplement actuarial findings with contextual and behavioural indicators.

Administration and Use in Ontario

In Ontario, the DVSR is used by both police services and Probation and Parole Services. Testimony before the Renfrew County Inquest confirmed that the Ontario Provincial Police (OPP), other police services, and provincial probation officers use the DVSR routinely alongside ODARA as part of their standard IPV risk assessment process. Probation personnel indicated that even when ODARA could not be formally scored due to eligibility limitations, the DVSR remained a core part of risk evaluation and supervision planning. Similarly, OPP representatives noted that the DVSR’s structured format supported consistent decision-making and enhanced inter-agency coordination.

The DVSR is used at multiple points in the justice process, including:

• To support Crown bail briefs and high-risk flagging;
• To guide case prioritization within probation caseloads;
• As a reference in early intervention and coordination efforts, including through Situation Tables or high-risk offender panels.

Integration and Provincial Status

Despite its widespread use in certain regions, the DVSR is not currently subject to a provincial directive or standardized implementation framework. Training in the tool varies by agency and region, and there is no public guidance outlining when or how the DVSR should be used relative to other tools such as ODARA, B-SAFER, or SARA. Its inclusion in provincial training curricula, police college instruction, or probation onboarding is not consistent.

Practical Implications

The DVSR occupies a unique position in Ontario’s IPV risk infrastructure as an SPJ tool used routinely by justice system actors. Unlike more specialized tools such as SARA—which may require clinical assessment or psychological evaluation—the DVSR is designed to be used by frontline professionals and has been embedded in operational practice by many Ontario justice actors for over a decade.

Given its widespread use and frontline relevance, the DVSR should be included in any province-wide modernization, revalidation, training, or standardization efforts concerning IPV risk assessment tools.

4.2.5. Spousal Assault Risk Assessment (SARA)

Overview and Purpose

The Spousal Assault Risk Assessment (SARA) is a structured professional judgment tool specifically developed to assess and manage risks posed by individuals involved in intimate partner violence (IPV). Created by Dr. Randall Kropp and Dr. Stephen Hart at the British Columbia Institute on Family Violence in 1994, SARA systematically guides evaluators through evidence-based risk factors. Its primary objective is to provide a detailed, qualitative analysis of an individual’s potential to engage in future IPV—including severe violence or lethal harm—and to suggest targeted risk management strategies for mitigating identified risks.

Unlike actuarial instruments such as the Ontario Domestic Assault Risk Assessment (ODARA), which primarily use statistical formulas to generate risk scores, SARA emphasizes structured professional judgment (SPJ). SPJ methods provide assessors with a clearly defined set of factors to consider, but the final determination of risk level relies on professional interpretation and discretion rather than numerical scoring alone.

Administration and Frequency of Use

Due to its complexity and the level of professional judgment required, SARA is typically administered by specialized IPV units within larger police services, probation officers with advanced training, or forensic mental health professionals. In Ontario, SARA assessments are primarily reserved for high-risk or complex IPV cases involving repeat offenders or particularly severe incidents, rather than being routinely applied to all IPV incidents.

The assessment involves detailed interviews with both the offender and victim (where possible), careful review of police records, probation reports, psychological evaluations, and other relevant documentation. Typically, SARA assessments are updated or readministered at critical junctures in a case, such as new IPV-related charges, violations of existing bail or probation conditions, or significant observed changes in offender behaviour.

Integration with Justice System and Community Responses

In principle, results of SARA assessments are intended to guide decisions by Crown prosecutors around bail conditions, inform probation officers’ supervision plans, and aid Children’s Aid Societies (CAS) in safety planning, particularly in child custody or protection matters. Practically, however, the effective integration of SARA results into Ontario’s IPV response system is inconsistent and jurisdiction dependent. While theoretically available for inclusion in Crown disclosure or probation supervision, in practice, actual usage varies widely across Ontario. This variation primarily results from the absence of provincial standards or mandates governing when, how, and by whom SARA assessments must be conducted, and how assessment results must be communicated among police, Crown attorneys, probation, and victim-support agencies.

Moreover, despite its potential utility, there is limited documented evidence indicating routine use or consideration of SARA assessments by frontline Crown attorneys or judges at bail or sentencing hearings. As such, the practical benefit of this comprehensive risk assessment tool remains under-realized across Ontario’s justice system.

Training, Resource Requirements, and Jurisdictional Limitations

A central barrier to the widespread use and consistent application of SARA is the substantial resource and training demands required for its effective implementation. Conducting SARA assessments necessitates highly specialized training in IPV risk assessment methods and psychological evaluation, expertise typically beyond the standard training provided to frontline police officers, probation officers, or Crown attorneys. Ontario does not currently have a provincially standardized, mandated training framework for administering SARA, nor is there a designated provincial authority responsible for providing or overseeing such training.

The significant time, professional expertise, and training investments needed to reliably administer SARA disproportionately affect smaller, rural, or under-resourced jurisdictions. Consequently, its application remains concentrated predominantly in larger urban centres with specialized IPV units and dedicated forensic mental health resources. Smaller or remote jurisdictions often lack the capacity or expertise to conduct such detailed assessments, thus limiting the practical availability of SARA to IPV cases across Ontario.

Practical Implications

The existing limitations in training, resource availability, and systemic integration have led to the development and wider adoption of simplified derivatives such as the Brief Spousal Assault Form for the Evaluation of Risk (B-SAFER), which retain the core elements of SARA but are more practical and less resource-intensive for widespread use. Nevertheless, given its recognized validity and detailed approach, SARA retains significant potential value for high-risk IPV cases, provided existing systemic barriers—particularly training standardization, mandated use protocols, and provincial resourcing—can be effectively addressed.

Clarifying the Practical Use and Application of the SARA Tool

Professional literature and research on IPV risk assessments generally recommend that the Spousal Assault Risk Assessment (SARA) be reserved for cases requiring extensive analysis beyond the capabilities of simpler screening tools like the Ontario Domestic Assault Risk Assessment (ODARA). Specifically, SARA is recommended when detailed psychological evaluations, clinical insights into offender behaviour, and comprehensive management strategies are necessary to address complex or high-risk IPV situations. Due to its structured professional judgment (SPJ) framework, SARA allows assessors considerable discretion in interpreting qualitative factors—such as mental health issues, patterns of coercive control, and the offender’s capacity to adhere to risk management plans—which are not fully captured by actuarial tools relying exclusively on historical criminal data and statistical probabilities.

In an ideal implementation scenario, SARA would not necessarily replace simpler tools but rather complement them. Experts suggest that frontline assessments, such as those routinely conducted by police using ODARA, could serve as initial screening mechanisms, effectively identifying cases of moderate-to-high IPV risk. Those flagged as especially high-risk or presenting complex clinical or behavioural dynamics would then warrant a subsequent, in-depth assessment using the SARA framework.

However, despite clear guidance in the scholarly literature, practical application within Ontario remains fragmented and inconsistent. Currently, SARA is utilized predominantly by specialized domestic violence units or trained professionals within select Ontario police services, probation offices, and forensic mental health teams. Yet, standardized use across Ontario’s justice or social service systems is limited, with most frontline officers and even many Crown prosecutors being familiar primarily with ODARA rather than SARA due to resource constraints and lack of standardized provincial training initiatives.

These resource constraints significantly restrict the practical availability and routine implementation of SARA, particularly in smaller, rural, or under-resourced jurisdictions. As such, while ideal professional practice indicates SARA’s extensive use in complex cases, actual provincial implementation remains inconsistent and largely dependent upon localized resource availability and training infrastructure. This disparity highlights critical gaps in Ontario’s broader IPV risk assessment system, underscoring the need for clear provincial standards, strategic resource allocation, and systematic training protocols.

4.2.6. Brief Spousal Assault Form for the Evaluation of Risk (B-SAFER)

Development and Purpose

The Brief Spousal Assault Form for the Evaluation of Risk (B-SAFER) was developed by the British Columbia Institute Against Family Violence, P. Randall Kropp, Ph.D., Stephen D. Hart, Ph.D., Henrik Belfrage, Ph.D. and the Department of Justice Canada in 2005 as a condensed and streamlined alternative to the more resource-intensive Spousal Assault Risk Assessment (SARA). The tool was specifically designed to meet the operational needs of frontline professionals—including police officers, probation officers, and other criminal justice practitioners—who require efficient yet robust IPV risk assessments without sacrificing essential clinical judgment or accuracy.⁵⁹⁸

B-SAFER aims to provide a practical structured professional judgment (SPJ) framework that can be realistically implemented in settings where resources and specialized clinical training may be limited. Unlike purely actuarial assessments, B-SAFER allows for contextual professional judgment within a structured risk factor approach, thus enabling assessors to make informed decisions about risk management tailored to specific offender contexts.

Structure and Risk Factor Domains

B-SAFER consists of ten empirically validated risk factors divided evenly into two domains:

1. Intimate Partner Violence Domain:
   • Serious physical violence or threats of violence
   • Escalation of violence or threats
   • Violations of court orders or protective measures
   • Negative attitudes towards intimate partners
   • General criminality (related specifically to IPV incidents)
2. Psychosocial Adjustment Domain:
   • Substance abuse problems
   • Mental health concerns
   • Employment or financial instability
   • Criminal history (non-IPV related offences)
   • Relationship instability and dysfunction⁵⁹⁹

Each factor is rated based on presence and relevance, guiding evaluators to reach a comprehensive judgment regarding an individual’s risk of IPV recurrence or escalation. Evaluators use these ratings to inform decisions around risk management strategies such as bail conditions, probation supervision plans, and victim safety planning.⁶⁰⁰

Use and Implementation in Ontario

Within Ontario, B-SAFER has gained traction primarily among frontline police services, probation offices, and IPV-focused community support programs due to its practicality and accessibility.

Probation services across Ontario increasingly rely on B-SAFER assessments to guide supervision levels, manage offender risk, and facilitate targeted intervention planning.

Training and Professional Requirements

Effective B-SAFER administration demands specialized training to ensure that frontline professionals can accurately interpret risk factors and apply structured professional judgment appropriately. In Ontario, this training is typically facilitated through organizations specializing in IPV intervention, forensic training providers, or directly through dedicated IPV units within policing and probation agencies. The training curriculum includes foundational IPV theory, detailed explanations of each B-SAFER risk factor, case study analyses, and practical application scenarios designed to promote reliable, valid assessments in diverse professional contexts.⁶⁰¹

Despite its comparative simplicity, ongoing training and oversight remain crucial to maintaining accuracy and consistency in B-SAFER assessments. Without regular training refreshers, assessments may become inconsistent, undermining the reliability and predictive validity crucial for effective IPV risk management.

Empirical Validation and Limitations

B-SAFER is empirically validated and demonstrates strong predictive validity and reliability, particularly when administered by trained professionals.

However, limitations persist, particularly concerning inter-rater reliability when less experienced practitioners or those lacking ongoing professional training conduct assessments. Further, B-SAFER’s condensed format may exclude potentially relevant nuanced information available through more detailed assessments like SARA, suggesting it is best utilized as an initial or supplementary assessment rather than a definitive standalone evaluation in high-complexity IPV cases.

Conclusion and Practical Implications

Overall, B-SAFER represents an effective, practically implementable risk assessment tool in Ontario’s IPV response landscape. Its ability to balance brevity with robust predictive validity positions it as a critical element within a multi-tiered assessment framework, suitable for initial frontline assessments and complementing deeper evaluations where necessary. However, realizing its full potential requires sustained provincial investment in standardized training, regular updates of practitioner competencies, and clearly defined implementation protocols, especially in smaller jurisdictions with limited IPV-specialized resources.

4.2.7. Level of Service Inventory (LSI)

Development and Purpose

The Level of Service Inventory (LSI), including its widely utilized revision, the Level of Service/Case Management Inventory (LS/CMI), is an actuarial risk assessment tool extensively adopted by probation services across Ontario. Developed initially by Don Andrews, Ph.D. and James Bonta, Ph.D in the early 1990s, the LSI evaluates an offender’s likelihood of recidivism and identifies individualized intervention needs by systematically examining a comprehensive set of criminogenic factors.⁶⁰²

Structure and Risk Factor Domains

The LSI framework encompasses multiple risk and needs domains that have empirically demonstrated relevance to recidivism. Specifically, the assessment covers:

• Criminal history (frequency and severity of prior offenses);
• Education and employment stability;
• Financial management issues;
• Family and marital relationships;
• Housing stability;
• Leisure and recreation activities;
• Peer associations and influences;
• Substance abuse patterns;
• Emotional and mental health factors;
• Antisocial attitudes and orientations.⁶⁰³

These domains are assessed quantitatively, resulting in a cumulative risk score that classifies offenders into low, moderate, or high-risk categories. The results directly inform probation case plans, supervision intensity, and rehabilitative programming recommendations.⁶⁰⁴

Application in Ontario Probation Services

In Ontario, probation officers routinely administer the LS/CMI to offenders under their supervision, particularly at intake, during periodic review intervals, or following significant behavioural changes. The LS/CMI serves as the cornerstone of probation case management practices, guiding decisions about supervision frequency, program referrals, interventions, and compliance monitoring strategies.

For IPV cases specifically, probation officers generally use the LS/CMI as part of a broader assessment battery. Due to the generalist nature of the LS/CMI, probation officers frequently supplement this tool with IPV-specific assessments, such as the Ontario Domestic Assault Risk Assessment (ODARA) or the Brief Spousal Assault Form for the Evaluation of Risk (B-SAFER), to adequately capture the unique dynamics and risks inherent in domestic violence cases.

Training, Professional Standards, and Consistency

Proper administration of the LS/CMI requires structured training programs for probation officers, typically delivered provincially through the Ministry of the Solicitor General or through specialized correctional training organizations. Training emphasizes accurate administration, scoring, interpretation, and integration of LS/CMI results into individualized case management and community supervision plans.

Despite standardized training efforts, variability in the quality and consistency of LS/CMI administration and interpretation across Ontario remains a concern. Variability often stems from differences in regional training availability, professional experience of probation staff, and resource disparities, particularly in smaller or rural jurisdictions. Consequently, periodic re-certification and regular supervisory oversight are critical for maintaining accuracy, reliability, and utility in case management decisions.

Empirical Validation, Strengths, and Limitations

Numerous validation studies indicate that the LS/CMI reliably predicts general recidivism among diverse offender populations, including both male and female offenders and individuals with extensive criminal histories.

However, limitations emerge when applying the LS/CMI to IPV offenders, as the instrument does not explicitly assess many critical IPV-specific risk factors such as coercive control, victim-specific threats, economic abuse, or the presence of companion animals. Consequently, reliance solely upon the LS/CMI for IPV offenders without supplementary specialized risk assessments risks overlooking significant contextual nuances critical to effective IPV case management.

4.2.8. Sexual Offender Risk Assessment Tools

Ontario’s probation and corrections systems rely on several validated tools to assess the likelihood that an individual convicted of a sexual offence will reoffend. These tools are used to inform supervision intensity, case planning, and eligibility for treatment or parole. While similar in structure to some intimate partner violence (IPV) risk assessments, these instruments are designed to predict sexual recidivism—regardless of victim relationship—and are typically used after conviction or at intake to community supervision.

The tools are administered by probation officers, institutional correctional staff, and clinical experts, but are not currently accessible to police, Crown attorneys, or victim services. They are not used at the point of arrest, and they are not introduced at trial. However, they may be referenced in pre-sentence reports or clinical evaluations where the court has ordered a risk assessment under the Criminal Code.

Under s. 752.1 of the Criminal Code,⁶⁰⁵ a court may order a psychiatric risk assessment when considering a Dangerous Offender (DO) or Long-Term Offender (LTO) designation. This is most common in the context of serious sexual or violent offences. The court can order the offender to be remanded for up to 60 days for the preparation of a psychiatric and psychological assessment, typically conducted in a federal institution or designated forensic facility. The results are used to inform whether the Crown should proceed with a DO or LTO application under Part XXIV.⁶⁰⁶

The following tools are the most used in Ontario:

4.2.8.1. Static-99R

An actuarial risk assessment instrument designed to estimate the long-term probability of sexual recidivism. The tool includes ten static historical items such as age at release, number and nature of prior sexual offences, and victim characteristics. It is the most widely used sex offender risk assessment tool in Canada, including in Ontario, and is often administered by probation officers, correctional staff, and forensic psychologists for supervision planning and parole eligibility assessment.

4.2.8.2. STABLE-2007 and ACUTE-2007

These companion tools assess dynamic and acute risk factors among sexual offenders. STABLE-2007 measures longer-term factors such as intimacy deficits, general self-regulation, and deviant sexual interests. ACUTE-2007 is used to assess short-term changes in risk, such as access to potential victims or escalation in substance use. In Ontario, these tools are used within both institutional and community supervision settings to inform case planning and risk management.

4.2.8.3. SVR-20 (Sexual Violence Risk–20)

A structured professional judgment tool composed of 20 items grouped into historical, clinical, and risk management categories. SVR-20 is intended to guide clinicians and risk assessors in evaluating an individual’s likelihood of committing future sexual violence. While not as routinely used as the Static or STABLE/ACUTE tools, it is used in certain forensic evaluations and high-risk case reviews in Ontario.

4.2.8.4. SORAG (Sex Offender Risk Appraisal Guide)

An actuarial tool developed for use by forensic psychologists. It incorporates a range of demographic, psychiatric, and criminal history variables to predict risk of sexual and violent reoffending. Its use in Ontario is limited and appears to be restricted to clinical or specialized forensic settings.

Use and Visibility

Sexual offence risk tools are not subject to a standardized mandate in Ontario. While they are in active use by probation officers, correctional staff, and clinical evaluators, there is no consistent provincial framework governing when they are used, how results are documented, or under what circumstances they may be shared across systems. Risk scores generated by these tools are typically retained within internal supervision files or referenced in pre-sentence reports. They are not routinely disclosed to police, Crown attorneys, or victim services unless introduced in formal court proceedings such as when the Crown is seeking a DO or LTO designation, which is fairly rare.

As a result, police services and Crown counsel generally do not have access to sexual recidivism risk scores, even in cases involving active community supervision for a sexual offence. This limits the ability of enforcement actors to assess risk-informed conditions at bail or sentencing (from the perspective of probation or ancillary orders), or to prioritize compliance monitoring where risk is known to be elevated.

This limitation is particularly relevant considering this report’s proposal that police services assume a greater role in community-based compliance monitoring for individuals convicted of intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), or animal cruelty. If police or designated enforcement teams are tasked with field-based compliance checks, access to risk-related supervision data—including scores from Static-99R, STABLE-2007, or ACUTE-2007—may be necessary to ensure that enforcement resources are allocated proportionately and in accordance with the individual’s assessed level of risk.

At present, no structured mechanism exists to facilitate this type of role-based visibility. While privacy legislation permits the sharing of risk-relevant information in appropriate circumstances, there is no operational protocol to support the timely or standardized disclosure of sexual recidivism risk scores for enforcement or supervision purposes. This gap may warrant structured review as part of Ontario’s broader shift toward risk-informed monitoring and supervision practices.

4.2.9. Campus-Based Risk Identification and Community Management Tools: The Jung–Mendoza Model

Context and Rationale

Sexual violence and intimate partner violence (IPV) remain prevalent and under-addressed within Ontario’s post-secondary institutions. According to Statistics Canada’s national survey of over 100,000 students, 71% of students in post-secondary institutions reported experiencing or witnessing unwanted sexualized behaviours, and nearly one in ten reported being sexually assaulted during a single academic year.⁶⁰⁷

The consequences of campus-based sexual and IPV extend beyond immediate trauma. Student victims face elevated risks of academic disruption, delayed graduation, lost scholarship funding, and long-term earning suppression. Institutions may face reputational damage, decreased enrolment, civil liability, and regulatory compliance costs. One U.S. study estimated the lifetime economic burden of each sexual assault at over USD $122,000, accounting for lost productivity, health system strain, and criminal justice costs.⁶⁰⁸ Despite this, post-secondary institutions in Ontario lack any standardized tool or framework to assess or manage the risk posed by known or suspected perpetrators within the campus setting.

Overview and Purpose

In response to this gap, Dr. Sandy Jung and Dr. Jesmen Mendoza co-developed a structured community risk assessment tool specifically for post-secondary institutions under the national Courage to Act initiative.⁶⁰⁹ The tool is designed not as a predictive instrument, but as a decision-support framework to help campus professionals identify and manage risk associated with students who have caused harm.

Implementation and Use

The Jung–Mendoza model was developed and piloted under Courage to Act, a federally funded initiative led by Possibility Seeds. Although it has been well-received in practitioner settings and shows strong face validity, it has not yet undergone formal peer-reviewed validation or internal reliability testing.

In testimony before the Standing Committee on Justice Policy, Dr. Mendoza emphasized that most risk assessment tools currently used by colleges and universities are normed on criminal or justice-involved populations and are inappropriate for the pro-social, non-forensic context of post-secondary education.⁶¹⁰ Questions such as gang affiliation or criminal history may yield low scores despite the presence of serious and escalating risk, while relevant risk factors—such as digital harassment, ideological radicalization, or stalking of peers—are often absent from standard tools.

Dr. Mendoza further stated that high-stakes decisions are routinely made based on tools not designed or validated for campus use.

Limitations and Systemic Implications

Currently, no Ontario legislation, regulation, or ministerial directive mandates the use of risk assessment tools in post-secondary settings. Most campus sexual violence frameworks focus exclusively on survivor supports, with limited infrastructure for risk screening or threat management. Without evaluation, standardization, or dedicated implementation funding, institutions remain vulnerable to inconsistent practices, ineffective interventions, and failure to recognize escalating patterns of risk.

4.2.10. Children’s Aid Societies and Intimate Partner Violence-Related Risk Assessments

Children’s Aid Societies (CAS) in Ontario are mandated under the Child, Youth and Family Services Act, 2017 (CYFSA) to protect children from harm, including risks associated with intimate partner violence (IPV). To fulfill this statutory responsibility, CAS employs several standardized tools and frameworks, which guide assessments and interventions involving families affected by IPV. This section critically examines these tools, explores Indigenous Child and Family Well-Being Agencies, and outlines key challenges in information-sharing and privacy.

4.2.10.1. The Eligibility Spectrum

The Eligibility Spectrum, developed and regularly updated by the Ontario Association of Children’s Aid Societies (OACAS), serves as a standardized screening tool to assess initial reports and determine whether a formal CAS investigation is warranted.⁶¹¹ Updated most recently in 2024, this tool categorizes reported incidents into specific scales, including physical harm, sexual harm, emotional harm, neglect, and exposure to conflict or violence.⁶¹² For instance, scale 3, “Child Exposure to Partner Violence” includes exposure of children to IPV as a trigger for potential CAS involvement.⁶¹³ However, despite updates, the Eligibility Spectrum does not explicitly address coercive control, threats or harm to animals, or economic abuse, reflecting gaps relative to emerging IPV scholarship and practice.

4.2.10.2. Ontario Child Protection Standards

The Ontario Child Protection Standards, mandated by the Ministry of Children, Community and Social Services, establish baseline expectations for conducting child welfare assessments and interventions.⁶¹⁴ Specifically, Standard 4 outlines mandatory processes for conducting risk assessments.⁶¹⁵ Despite its detailed procedural guidance, Standard 4 lacks explicit consideration of modern IPV frameworks, including coercive control, economic manipulation, and threats or harm directed toward companion animals—factors recognized as critical predictors of IPV lethality and escalation. The standards are periodically reviewed but have not yet integrated these contemporary IPV understandings, raising concerns about the completeness of current risk assessments.

4.2.10.3. Comprehensive Family Risk Assessment (CFRA)

CAS agencies employ the Comprehensive Family Risk Assessment (CFRA), an actuarial tool intended to objectively predict the likelihood of future child maltreatment based on historical and present factors.⁶¹⁶ The CFRA evaluates variables such as caregiver history, parenting skills, prior abuse or neglect allegations, and environmental stressors.⁶¹⁷ Critically, research highlights that the CFRA’s quantitative focus often inadequately captures nuanced IPV dynamics, particularly coercive control and non-physical abuse tactics, potentially limiting its effectiveness in accurately assessing IPV-related risks to children. The absence of explicit IPV indicators within the CFRA further contributes to these limitations.

4.2.10.4. Indigenous Child and Family Well-Being Agencies

Indigenous Child and Family Well-Being Agencies arose from Indigenous-led advocacy in the 1970s and 1980s, responding to overrepresentation of Indigenous children in Ontario’s mainstream child welfare system and historical practices of cultural assimilation through child removal. These agencies, while operating independently from mainstream CAS, provide culturally tailored child welfare services grounded in community protocols and traditional Indigenous values. They are typically community-based, non-governmental organizations that receive statutory authority through agreements with provincial and federal governments, facilitated by Indigenous Services Canada (ISC), formerly Indigenous and Northern Affairs Canada (INAC).⁶¹⁸

Established in 1994, the Association of Native Child and Family Services Agencies of Ontario (ANCFSAO) supports these Indigenous agencies through advocacy, policy development, training, and capacity-building initiatives.

4.2.10.5. Information Sharing and Privacy Challenges

Effective child protection interventions, especially in IPV contexts, require robust information-sharing practices among CAS, law enforcement, healthcare providers, schools, and other community agencies. However, considerable barriers persist, often stemming from misinterpretations or cautious applications of privacy legislation. According to the Information and Privacy Commissioner of Ontario, privacy laws explicitly permit, and indeed support, the sharing of critical risk-related information when child safety is at risk.⁶¹⁹ Nevertheless, misunderstandings, inconsistent interpretations of legislation, and varying agency policies continue to impede timely information-sharing, ultimately affecting child safety outcomes.

Inter-agency collaboration is further complicated by concerns regarding victim autonomy, confidentiality, and potential repercussions on families seeking support. Clearer guidance, standardized inter-agency protocols, and ongoing training are identified as essential measures to address these persistent barriers.

4.2.11. Evaluating and Updating Ontario’s Comprehensive Family Risk Assessment Tool: Potential Developers and Alternative Models

Ontario’s child welfare system currently employs the Comprehensive Family Risk Assessment (CFRA), an actuarial tool intended to predict the likelihood of future child maltreatment. Initially developed by the Children’s Research Center (CRC) in California as part of the Structured Decision Making (SDM) model, the CFRA quantitatively evaluates risk factors such as prior allegations of abuse, caregiver characteristics, and environmental stressors.

4.2.11.1. Alternative Models: CARE-NL

There are alternative models that have demonstrated enhanced efficacy in predicting child maltreatment and guiding effective intervention strategies. One is the Child Abuse Risk Evaluation – Netherlands (CARE-NL). Developed in the Netherlands, the CARE-NL is a structured professional judgment tool specifically designed to assess the risk of child abuse across multiple dimensions, including parental characteristics, parent-child interactions, and broader family factors.⁶²⁰ CARE-NL integrates empirical risk factors identified through systematic literature reviews. Such models are worth investigating for implementation in the Ontario context.

4.2.11.2. Potential Ontario-Based Developers of an Updated Assessment Tool

Should Ontario decide to undertake the revision or redevelopment of its current CFRA or to integrate aspects from models such as SDM and CARE-NL, the province possesses several highly qualified local academic and professional institutions capable of leading such an initiative:

• Centre for Research & Education on Violence Against Women & Children (CREVAWC) at Western University, established in 1992, specializes in research on family violence, intimate partner violence, and child maltreatment. CREVAWC has consistently contributed evidence-based practices and policy recommendations, positioning them as experts in updating and refining risk assessment tools related to child welfare and IPV.
• Ontario Association of Children’s Aid Societies (OACAS), as a provincial umbrella organization, has extensive experience developing standardized child welfare protocols and tools. OACAS was instrumental in the creation of Ontario’s current Eligibility Spectrum and Child Protection Tools Manual, closely associated with the SDM model. Their existing expertise in tool development and provincial implementation is highly relevant.
• Canadian Child Welfare Research Portal (CWRP), based in Ontario and supported by national partners, coordinates extensive child welfare research initiatives, providing data-driven guidance to child protection services across Canada. CWRP’s experience in conducting rigorous evaluations of child welfare interventions and assessment tools positions it as a key resource for revising the CFRA or developing enhanced assessment protocols tailored to Ontario’s context.

4.2.11.3. Considerations for Moving Forward

Any revision of Ontario’s child maltreatment risk assessment framework should critically engage with empirical research and insights from local experts. Collaboration with CREVAWC, OACAS, and CWRP would leverage their specialized knowledge to ensure the revised tool comprehensively addresses critical gaps identified in current assessments, such as inadequate attention to coercive control, animal abuse, and psychological manipulation.

4.2.12. Screening Tools for Risk of Sex Trafficking

The commercial sexual exploitation of individuals—especially minors—is a recognized form of gender-based violence and a significant public safety and public health concern. Although Ontario accounts for nearly two-thirds of police-reported human trafficking cases in Canada,⁶²¹ the province does not currently have a standardized or widely adopted approach to identifying individuals at risk of being trafficked for sexual purposes. The availability and use of structured screening tools remain limited, particularly for adult victims and those outside urban health care or youth services settings. As a result, opportunities for early intervention may be missed.

Existing Tools and Their Applications

Several screening instruments have been developed in the United States to assist professionals in identifying children and youth at risk of sex trafficking. These tools vary in complexity, intended setting, and target population, but most are designed for use with minors in health care, education, or shelter environments. Examples include:

• Commercial Sexual Exploitation–Identification Tool (CSE-IT): Developed by WestCoast Children’s Clinic in California, the CSE-IT is a non-intrusive observational tool designed for universal use with youth aged 10 and older. It is currently used in multiple U.S. states across child welfare, juvenile justice, and education systems. While not a diagnostic tool, it assigns a score based on eight indicators to flag individuals requiring further assessment.⁶²²
• Short Screen for Child Sex Trafficking (SSCST): Designed for emergency department settings, the SSCST is a six-item questionnaire validated with youth aged 11–17. It has been shown to improve identification of high-risk youth in hospital environments.⁶²³
• Human Trafficking Interview and Assessment Measure (HTIAM-14): Targeted toward homeless youth aged 18–23, this 14-item instrument has demonstrated validity in identifying individuals with lived experiences of trafficking. It remains one of the few tools developed specifically for transition-age youth living in precarious housing circumstances.⁶²⁴
• Quick Youth Indicators for Trafficking (QYIT): A brief four-question screen, QYIT was developed for homeless shelters serving youth. It shows promising sensitivity (86.7%) and specificity (76.5%) in identifying a trafficking experience.⁶²⁵

These tools are increasingly used in U.S. jurisdictions but are not currently known to be implemented in Ontario. The CSE-IT, in particular, has been recommended for universal screening.⁶²⁶ However, none of these tools have been formally evaluated or adopted within Ontario’s provincial systems.

Use in Ontario: Early Signs, Limited Scale

To date, the most structured effort to implement sex trafficking risk screening in Ontario appears in the Multisector Community Response to Child Sex Trafficking protocol developed by SickKids’ Lotus Health program. The protocol does not endorse a specific screening instrument but articulates the need for systematic processes across health care, child welfare, and community services.⁶²⁷ The SickKids report acknowledges the fragmented nature of current services and calls for better integration and early identification mechanisms across sectors.⁶²⁸

Beyond the Lotus Health initiative, there is little evidence of widespread or standardized screening for sex trafficking in Ontario’s public systems. Most efforts appear to be localized, project-based, or focused on training staff in general trafficking awareness rather than structured risk identification. No known screening tools exist for use with adults at risk of or experiencing sex trafficking, nor are there validated instruments tailored to the adult Ontario context.

Evaluating Effectiveness

While the tools listed above have shown some success in their intended settings, the research base remains limited. Several studies suggest moderate accuracy, particularly in high-volume clinical environments, but concerns have been raised about generalizability to broader populations. For example, many tools were validated on homeless or runaway youth, and few have undergone peer-reviewed evaluation in Canadian contexts.

Researchers also note a significant gap in tools designed for use with adult women, men, or gender-diverse individuals—populations known to be affected by sex trafficking but often excluded from screening models. Additionally, while some tools are trauma-informed, most do not explicitly incorporate risk factors such as coercive control, technology-facilitated grooming, or criminalization-related fear of disclosure.

4.2.13. Risk Assessment Tools for Children and Youth: Early Trajectories of Violence

Overview and Purpose

Ontario’s current risk assessment framework focuses primarily on adult offenders, offering limited structured tools for identifying risk in children and youth exposed to IPV. While early exposure to IPV is a well-documented predictor of future violent behaviour, there is no formal integration of youth-specific risk tools into the province’s broader risk infrastructure. Several structured professional judgment (SPJ) tools exist that are designed to assess behavioural risk in children and adolescents who may be on a trajectory toward future violence, criminal offending, or interpersonal harm.

These tools are not intended to predict immediate lethality but offer important insight into early antisocial development and long-term violence risk. They are currently used in some mental health, youth justice, and early intervention settings in Ontario, but are not included in provincial violence prevention or risk assessment policy frameworks.

4.2.13.1. Early Assessment Risk List (EARL-20B and EARL-21G)

The EARL-20B and EARL-21G are SPJ tools developed by Canadian researchers to assess risk for future antisocial behaviour in boys and girls aged 6 to 12.⁶²⁹ Originally developed for use within the SNAP program, the EARL tools evaluate a range of static and dynamic factors—including family violence exposure, poor parental attachment, impulsivity, and peer rejection—that contribute to early behavioural risk trajectories. Although the tools are widely recognized internationally and are in use in Ontario, they are not referenced in any provincial IPV, youth justice, or child welfare risk policies.

4.2.13.2. Structured Assessment of Violence Risk in Youth (SAVRY)

The SAVRY is a validated SPJ tool for adolescents aged 12 to 18 that assesses the risk of future violent behaviour. It incorporates 24 items across historical, social, and clinical domains and is used internationally in youth justice, clinical mental health, and school-based settings. While SAVRY is used by some Ontario clinicians and youth justice providers, it is not referenced in any formal provincial framework for IPV prevention or child protection, despite its applicability to high-risk youth exposed to family violence.

4.2.13.3. Structured Assessment of Protective Factors – Youth Version (SAPROF-YV)

The SAPROF-YV is a protective factor assessment designed to complement tools like SAVRY.⁶³⁰ It helps practitioners evaluate strengths such as emotional regulation, prosocial peer support, and adult supervision, allowing for more balanced intervention planning. While SAPROF-YV is used by some clinicians in youth mental health contexts, it is not formally integrated into Ontario’s risk management systems.

4.2.13.4. Short-Term Assessment of Risk and Treatability – Adolescent Version (START:AV)

The START-AV is a short-term risk tool designed to assess acute risk (e.g., over a 90-day period) in youth aged 12 to 18. It evaluates both vulnerabilities and strengths across domains such as violence, substance use, and self-harm. The tool is particularly suited to settings where youth risk fluctuates quickly, such as custody, probation, or community-based mental health services. Its use in Ontario is limited and not subject to any provincial oversight or coordination.

Practical Implications

Ontario lacks a unified strategy for assessing risk among children and adolescents who may be on a trajectory toward future IPV or interpersonal violence. While tools like EARL, SAVRY, SAPROF-YV, and START-AV are used in some Ontario agencies, there is no provincial visibility into where they are applied, by whom, or how results are used.

4.2.14. Emerging Predictors Missing from Current Tools

Ontario’s current risk assessment tools used in cases of IPV, SV, and child abuse reflect the evidence base available at the time of their development. These tools are validated for specific outcomes and contexts, but they do not account for several risk domains that have since been flagged by researchers and service providers as potentially relevant to predicting future harm or lethality. In most cases, the omission of these factors does not appear to be based on findings that they lack predictive value. Rather, there is no indication that these factors were evaluated and excluded based on statistical findings; instead, they appear not to have been studied or incorporated at all.

As a result, Ontario’s current risk tools—while evidence-based in their original form—may no longer reflect the full range of factors practitioners encounter in high-risk cases. Further research is needed to determine whether these domains should be integrated into updated versions of existing tools.

4.2.14.1. Animal Cruelty

As detailed elsewhere in this report, animal cruelty has been documented as an early indicator of interpersonal violence, a tactic of coercive control, and a form of trauma amplification, particularly in cases involving children. Although it is a distinct domain of IPV-related harm, animal cruelty is notably absent from all major validated risk assessment tools currently in use in Ontario. It is not included as a scored or structured item in ODARA, SARA, Danger Assessment, B-SAFER, LSI-CMI, or any child protection risk screening instrument. Unlike several other emerging indicators, animal cruelty has already been linked in the literature to increased lethality risk. Its exclusion from structured frameworks limits the capacity of those tools to support early identification and consistent flagging—particularly in multi-victim households where child trauma and coercive control intersect with harm to animals.

4.2.14.2. Coercive Control

Coercive control refers to a pattern of domination and entrapment involving isolation, surveillance, threats, and micro-regulation of daily life. While coercive control is recognized in policy and legislative discussions as a defining feature of IPV, it is not explicitly scored in most of Ontario’s commonly used IPV risk assessment tools. ODARA, for example, does not assign weight to surveillance behaviours, restrictions on movement, or economic entrapment. SPJ tools such as SARA and B-SAFER reference controlling behaviours (e.g., obsessive behaviours, jealousy) and victim vulnerabilities often associated with being coercively controlled (e.g., isolation), but do not provide structured scoring for cumulative coercive dynamics specifically.

The absence of coercive control from structured risk tools has been identified in multiple submissions to the Standing Committee on Justice Policy. Experts note that coercive control often precedes physical violence, continues post-separation, and may persist undetected when tools focus only on chargeable or injury-based events. There is ample evidence in the social science literature that the presence of coercively controlling dynamics is associated with greater risk for IPV reoffending and lethality. Given submissions to the committee, further conversation and education is needed so that these dynamics are appropriately recognized and considered; underlining again the need for regular, high-quality training for professionals engaged such assessments.

4.2.14.3. Economic Abuse

Economic abuse—including financial entrapment, coerced debt, and deprivation of financial autonomy—is a common feature in IPV cases and a significant barrier to victim separation and safety planning. It is not captured in any of the major risk assessment tools currently used by police, probation, or shelters in Ontario. While some SPJ models used in child welfare or clinical settings include questions related to financial stress or dependency, these are not applied consistently and are not scored factors in tools such as ODARA or LSI-CMI.

Researchers have noted that economic abuse reduces victim mobility, access to legal recourse, and the ability to secure housing or childcare. These impacts increase exposure to continued harm and complicate exit strategies. Its exclusion from existing tools may limit the ability to flag serious cases where physical violence is not yet present but coercive dynamics are ongoing. Whether economic abuse contributes independently to the risk of future violence or lethality remains an open research question.

4.2.14.4. Technology-Facilitated Abuse

Technology-facilitated abuse—including online harassment, image-based abuse, stalkerware, and GPS tracking—has become increasingly prevalent in both youth and adult relationships. Ontario researchers have identified concerns around the use of AirTags, image-based sexual abuse, deepfake “nudify” apps and other tactics as part of technology-facilitated gender-based and sexual violence.⁶³¹

None of Ontario’s current IPV or SV risk assessment tools include structured questions or scored items related to digital control, surveillance, or harassment. Some elements of technology-facilitated abuse may be indirectly captured under broader categories such as “criminal harassment” or “threats,” but there is no formal integration of these behaviours into validated risk scoring frameworks.

This is especially relevant in teen dating violence cases and among populations with limited physical access to victims (e.g., post-separation abusers, long-distance coercive partners). Although technology-facilitated abuse is now frequently identified by frontline workers as a serious risk concern, its statistical predictive value for lethality or reoffending has not yet been established in the peer-reviewed literature.

4.2.15. Privacy and Information-Sharing Barriers in Risk Identification

Ontario’s ability to accurately identify and manage risk in cases of intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), and child abuse is consistently constrained by barriers to timely and effective information sharing. These barriers exist across government systems and between government and not-for-profit service providers. While often framed as privacy concerns, many of the underlying issues stem from structural fragmentation, technological incompatibility, risk-averse organizational culture, and ambiguity regarding the legal framework that governs disclosure.

The effect is cumulative. Critical risk-relevant information held by one agency is frequently inaccessible to others, and there is currently no unified system through which law enforcement, Crowns, child protection workers, probation officers, or victim services can share or retrieve information about high-risk individuals in a coordinated way. Even where statutory exceptions to privacy restrictions exist, they are applied inconsistently in practice.

4.2.15.1. Legal Permissions Exist, but Are Often Misunderstood

Ontario’s privacy laws—the Freedom of Information and Protection of Privacy Act (FIPPA), Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), Personal Health Information Protection Act (PHIPA), and Part X of the Child, Youth and Family Services Act (CYFSA)—permit inter-agency information sharing under specific conditions. For example, both FIPPA and MFIPPA allow disclosure without consent where it is “...to aid in an investigation undertaken by the institution or the agency with a view to a law enforcement proceeding” or “in compelling circumstances affecting the health or safety of an individual”.⁶³² PHIPA permits health custodians to disclose personal health information without consent where there is a significant risk of serious bodily harm.⁶³³ The CYFSA includes similar allowances for child and family service providers.⁶³⁴

These provisions are cited in policy documents, including those developed by the Office of the Information and Privacy Commissioner (IPC).⁶³⁵ The IPC has also provided guidance specific to sharing information around IPV – Sharing Information in Situations Involving Intimate Partner Violence: Guidance for Professionals.⁶³⁶ However, in practice, many agencies continue to interpret their responsibilities narrowly. A provincial literature scan on IPV case management noted that professionals across sectors are often concerned about breaching confidentiality and may have difficulty understanding the legal landscape.⁶³⁷

This uncertainty is not limited to frontline staff. It is frequently embedded in organizational policy and reinforced by internal legal guidance. The result is an overly cautious approach to disclosure that leads to the suppression of risk-relevant information, even in cases involving repeat offenders or escalating violence.

4.2.15.2. Justice and Social Services Operate Without Shared Infrastructure

At present, there is no province-wide infrastructure that enables government agencies to share or access risk-related information in real time. While police have access to the Canadian Police Information Centre (CPIC) and service-specific records management systems (RMSs), these systems are not accessible to Crowns, probation officers, or CAS. Crowns have access to prosecution files through the SCOPE system, but this is not available to other ministries. CAS workers use CFSIS or similar systems managed by their respective societies. Probation files are managed separately by the Ministry of the Solicitor General.

In practical terms, a probation officer conducting a risk assessment may not have access to an accused person’s full police history unless it has been proactively shared. A CAS worker conducting a child protection investigation may be unaware of an existing probation order or recent bail release. A shelter support worker may have no access to court orders or know whether an accused has been released from custody. And although pre-sentence reports and psychological assessments conducted by probation officers often contain extensive information relevant to risk, these reports are typically not shared with police, CAS, or victim services unless requested through formal disclosure.

These silos are not dictated by legislation, but by system design. The absence of a centralized, access-controlled data infrastructure means that agencies must rely on manual outreach—emails, phone calls, or formal disclosure requests—to obtain information that may be relevant to immediate safety planning or case coordination. These delays can be significant, particularly where cross-jurisdictional records are involved.

4.2.15.3. Fear of Prejudice in Legal Proceedings Constrains Sharing

In several settings, reluctance to share information appears to be driven by concern about prejudicing criminal or family court proceedings.

Similarly, some child protection workers have indicated hesitation in disclosing case information to police or probation where the information could be subpoenaed in criminal court or could influence a concurrent family law proceeding. Police are often reluctant to share ODARA information with CAS services to whom they are referring; which as a result, may mean that a situation is judged as high risk by police and as under the line of intervention for CAS or vice versa. In the absence of clear, standardized protocols for disclosure between agencies, discretion is often exercised inconsistently, even within the same region.

4.2.15.4. Information-Holding Responsibilities Differ Between Government and Not-for-Profit Agencies

The barriers between government systems are further complicated by the structural division between government agencies and not-for-profit service providers. In Ontario, the majority of frontline services for IPV, SV, and human trafficking victims—including shelters, sexual assault centres, community counselling agencies, and general victim services programs—are delivered by independent not-for-profits. While some are co-located with police or court offices, they are not government bodies and are not integrated into government databases.

Police, Crowns, probation officers, and CAS workers often express reluctance to share information with these organizations. Reasons vary but include concerns about confidentiality, accountability, and whether not-for-profit organizations are bound by equivalent professional obligations. In practice, these concerns result in information about offender status, conditions, and supervision being withheld—even when the agency requesting the information is actively supporting the victim and managing safety planning.

Victim service workers frequently rely on the victim’s own understanding of an offender’s release conditions, court involvement, or history of violence. In some cases, the information held by the victim is incomplete or incorrect. The risk implications are significant, particularly in cases involving known escalation.

In these cases, the police service’s Domestic Violence Risk Coordinator (DVRC) may become the only practical point of contact for risk-related information held within police systems. However, the consistency and capacity of this role varies significantly across the province.

4.2.15.5. Differing Mandates and Duties of Care Affect Disclosure Decisions

Professionals working in different systems operate under differing legislative mandates and duties of care. A police officer has a duty to investigate, a Crown attorney has a duty to the public interest in prosecuting criminal offences, and a CAS worker has a statutory duty to promote the safety and well-being of children. In contrast, not-for-profit victim service providers define their obligations with reference to the safety, agency, and consent of the individual they are supporting.

This difference plays a central role in information-sharing decisions. Victim services and shelters may hesitate to share disclosures made by a victim if doing so would trigger mandatory investigation by police or CAS. In cases where a victim has not made a formal complaint—or has explicitly asked not to involve other agencies—support workers must balance ethical obligations to maintain trust against the potential safety gains of disclosure. As noted in multiple reports, including provincial submissions to the Standing Committee on Justice Policy, this balancing act often results in service providers withholding information, even in high-risk situations, out of concern that mandatory investigation could drive the victim out of care.

At the same time, government agencies may be reluctant to provide information to not-for-profit agencies out of concern that it will be passed to the victim without context or misused. This leads to a situation in which the agency with the most regular and meaningful contact with the victim is also the least able to access formal case information.

4.2.15.6. Illustration: Barriers in the CKW Case

The 2022 inquest into the deaths of Carol Culleton, Anastasia Kuzyk, and Nathalie Warmerdam provides a detailed account of how siloed information systems, limited supervision infrastructure, and lack of cross-agency communication may contribute to fatal outcomes.⁶³⁸ At the time of the homicides, the perpetrator was under an active provincial probation order, having been released from custody following convictions for violence against two of the victims. The homicides occurred in September 2015, while he remained under supervision.

Throughout the inquest, it became evident that multiple agencies—including probation, police, and local victim services—held partial but uncoordinated information regarding Borutski’s escalating risk.

The result was a situation in which multiple service providers had legitimate safety concerns, but no coordinated way to confirm status, escalate intervention, or respond with urgency. The CKW case remains an important example of how siloed systems, discretionary disclosure practices, and the absence of shared infrastructure can combine to impede timely risk detection, even in the presence of known and escalating threats.

4.3. Other Risk Assessment Related Mechanisms

4.3.1. Situation Tables and Interagency Risk Coordination

Situation Tables are collaborative, multi-agency partnerships intended to reduce risk through early identification and coordinated intervention. While not originally designed as tools for monitoring violent offenders or managing long-term supervision, they are sometimes used in that capacity—particularly in regions where no other formal coordination mechanism exists. Their role in Ontario’s violence prevention landscape is evolving, often driven by community-level leadership, perceived utility, and available resources. This section focuses exclusively on Situation Tables as they relate to interagency collaboration around IPV, SV, HT, child abuse, and animal cruelty, recognizing that they are also widely used for broader community safety objectives.

Origins and Structure

The first Canadian Situation Table was launched in Prince Albert, Saskatchewan in 2011. This “Hub” model was subsequently adapted in Ontario. Ontario’s Situation Tables follow a common framework, including a four-stage “Filter” process designed to support structured, limited information sharing in accordance with provincial privacy laws.

The Filter model facilitates de-identified discussion in early stages, with personal information disclosed only once all participating agencies agree that the case meets the threshold for Acutely Elevated Risk (AER).

Participating agencies usually include police services, probation, child protection, school boards, mental health and addictions services, housing workers, and local not-for-profit supports. Participation is voluntary and varies across jurisdictions. Some tables meet weekly with consistent membership and well-developed protocols, while others operate on an ad hoc basis with inconsistent participation.

Scope of Practice and Applicability to High-Risk Cases

Situation Tables were not originally designed to coordinate long-term case management for known violent offenders. Instead, they were developed as tools for identifying individuals or households experiencing AER due to a complex combination of social, health, and justice-related factors. Common referral risk categories include, mental health issues, housing, criminal involvement, substance use, and lack of basic needs.⁶³⁹

However, in the absence of other interagency coordination mechanisms, some communities may have adapted Situation Tables to serve as de facto forums for collaborative discussion about high-risk IPV or SV offenders—particularly in rural areas where no formal high-risk panels or dedicated Domestic Violence Risk Coordinators exist. In these contexts, a table may be the only regular venue where multiple agencies with partial knowledge of a high-risk offender can meet to share information, verify status, and coordinate support.

Although the Tables might be a venue for this work, they are often not functioning in ways that make IPV and SV visible or that address these issues. Work of many of Ontario’s Situation Tables was recently reported on by the Ministry of the Solicitor General (SolGen). SolGen offers several provincial tools and resources that can support local safety and well-being efforts, one of which is the Risk-driven Tracking Database (RTD), a Microsoft technology solution that the ministry provides to allow for improved opportunities for data collection, analysis and reporting for communities, and in support of legislative requirements mandating municipalities to prepare and adopt community safety and well-being plans. SolGen has released an RTD report on the Situation Tables work each year since 2016.

Some Ontario-based practitioners have also described using informal “high-risk panels” or “ad hoc high-risk case meetings” for similar purposes. These are typically unscheduled, issue-specific meetings involving a limited number of partners (e.g., police, probation, CAS, and victim services) assembled in response to emerging concerns about an individual. Unlike Situation Tables, these panels are generally not documented, not governed by formal protocols, and lack structured thresholds for intervention.

The overlap between Situation Tables and these informal case discussions suggests that, in the absence of a formal coordination infrastructure, local actors are developing site-specific practices to manage violence-related risk. While these efforts may be effective, they also reflect a lack of provincial standardization or oversight.

Sustainability and Oversight

There is currently no centralized registry of Situation Tables operating in Ontario. There is no provincial mandate requiring the establishment or maintenance of a table, and no consistent stream of funding to support their operation. The province has produced guidance documents and supported initial implementation efforts, but governance has been largely decentralized since 2015. Situation Tables that continue to operate today are doing so based on local leadership and sustained agency commitment. A 2021 evaluation of British Columbia’s Situation Tables—Ontario has no standardized or mandatory provincial training framework for Situation Table operations; most training is delivered informally at the local level, if at all.⁶⁴⁰

While no comprehensive Ontario study exists, practitioner feedback collected by OAITH suggests that similar patterns are observable in Ontario: where coordination is valued and resourced, tables are active; where it is not, tables lapse.⁶⁴¹

In many communities, the continued operation of Situation Tables depends on administrative support from local police services. Where tables do not receive dedicated staffing or funding, coordination tasks—including scheduling, meeting facilitation, and documentation—are frequently carried out by police personnel, often without formal mandate or compensation. This informal support contributes to the persistence of tables in some regions, but also renders them vulnerable to turnover, internal restructuring, or shifting priorities within individual services.

Information Sharing and Role of Not-for-Profit Agencies

Situation Tables are structured to allow both governmental and non-governmental participants to engage in limited, legally compliant information sharing. Non-statutory partners—including shelters, sexual assault centres, and youth outreach agencies—frequently serve as the referring party, particularly in IPV and SV-related cases. These organizations often hold detailed contextual knowledge of victims and risks that are not visible to police or other institutional partners; however, they may also be hesitant to raise cases that might trigger involuntary intervention by police or CAS, particularly where the victim has not agreed to such action. Having sufficient funding to support inter-agency work is also a barrier for many not-for-profit agencies.

Additionally, most not-for-profit agencies do not have access to police databases, probation records, or court management systems. While Situation Tables provide a limited venue for these agencies to become aware of information otherwise inaccessible, the asymmetry remains. These constraints may limit their full participation, even when they are among the most engaged agencies with the client.

Relevance to Prevention and Early Risk Coordination

Although Situation Tables were not designed to manage high-risk offenders, their role in violence prevention and early intervention is significant. The ability to identify and intervene early—before risk escalates—is a central function of any prevention framework. Situation Tables provide a mechanism through which this type of early coordination can occur. In cases where formal supervision has not been triggered (e.g., no charges laid, probation expired, custody release), or where the individual’s behaviour is destabilizing but not chargeable, a referral to a table may represent the only available venue for shared planning.

Their current relevance to early-stage risk coordination suggests that Situation Tables may warrant further integration into broader provincial violence prevention infrastructure—particularly under the mandate of the proposed OIVPRN hubs.

4.3.2. Offender Monitoring and Accountability Mechanisms

Ontario’s mechanisms for post-conviction offender monitoring include community supervision through probation, formal risk assessments, behavioural analysis systems such as ViCLAS, and federally governed designations like Dangerous Offender (DO) and Long-Term Supervision Order (LTSO). These tools are structurally distinct, operate under separate jurisdictions, and are applied inconsistently across the province. In cases involving intimate partner violence (IPV), sexual violence (SV), or human trafficking (HT), the absence of shared infrastructure and clear coordination mechanisms reduces their effectiveness in protecting victims and managing escalating risk.

4.3.2.1. Probation Supervision and Risk Assessment

Most individuals convicted of IPV or SV offences in Ontario receive community-based sentences.

Probation services fall under the jurisdiction of the Ministry of the Solicitor General. Probation officers supervise compliance with court-ordered conditions and support rehabilitation. In high-risk cases, they may be responsible for monitoring individuals with histories of repeated violence or coercive control. Supervision is typically guided by the Level of Service Inventory–Case Management Inventory (LSI-CMI), a general risk/needs assessment that evaluates the likelihood of reoffending based on criminogenic factors such as criminal history, substance use, and peer associations. The LSI-CMI is not, however, designed to assess IPV- or SV-specific risk. Risk tools such as SARA or B-SAFER could add this understanding, but such tools are not mandated within probation services, and their use is not standardized.

Information flow between probation and other agencies is inconsistent. While certain high-risk cases may be flagged to police or Crown counsel on an ad hoc basis, there is no standardized information-sharing protocol or shared database infrastructure.

4.3.2.2. ViCLAS: Potential Accountability Gap

The Violent Crime Linkage Analysis System (ViCLAS) is a behavioural crime linkage database managed nationally by the RCMP. In Ontario, the system is administered by the Ontario Provincial Police, which maintains the provincial ViCLAS Centre. Police officers are required to submit ViCLAS Crime Analysis Reports (CARs) for designated serious offences under O. Reg. 395/23 of the Community Safety and Policing Act, 2019.⁶⁴² ViCLAS captures data related to: all solved or unsolved homicides and attempts; all solved or unsolved sexual assaults or attempts; familial or domestic assaults involving unique or significant physical, sexual, or verbal behaviour; missing persons or unidentified human remains where foul play is suspected; all non-parental abductions and attempts; false allegations of sexual assault or attempted murder; and all solved, unsolved, or attempted child luring cases. Investigators may also submit a case if they believe the known or unknown offender may have committed other violent crimes or is likely to reoffend.⁶⁴³

Until 2024, O. Reg. 550/96 under the former Police Services Act required every Chief of Police to report annually to the Minister of Community Safety and Correctional Services on the number of ViCLAS submissions made.⁶⁴⁴ This requirement was revoked with the transition to the Community Safety and Policing Act. While the reason for its removal was not made clear, it may have been intended to reduce administrative burden. The reports submitted under the former regulation were not publicly released, and there was no statutory obligation for the Ministry to publish or act on the data received. However, the removal of the reporting mechanism has also eliminated a province-wide visibility tool that previously provided some level of insight into service-level compliance.

Although the submission obligation remains in effect, there is currently no provincial oversight mechanism to verify whether reports are being submitted consistently. This may create a gap in visibility and accountability—not because non-compliance is presumed, but because no centralized mechanism exists to ensure compliance.

ViCLAS plays a recognized role in identifying patterns among violent crimes committed by the same offender. It is specifically designed to support the detection and linkage of serial sexual offences, leveraging behavioural data points such as victim selection, offence progression, and offender strategies. Without a mechanism to monitor compliance, there is a risk that valuable behavioural information may not be captured or linked across jurisdictions.

4.3.2.3. Dangerous Offender and Long-Term Supervision Order Designations

Dangerous Offender (DO) and Long-Term Supervision Order (LTSO) designations are federal sentencing tools governed by Part XXIV of the Criminal Code. DO applications may result in indeterminate sentences, while LTSOs impose extended supervision of up to 10 years following the completion of a custodial sentence.⁶⁴⁵ These tools are reserved for individuals convicted of serious personal injury offences and assessed as posing a high risk of future violence or sexual offending.

In Ontario, Crown counsel must seek the consent of the Attorney General before initiating a DO or LTSO application. Once granted, supervision of federally sentenced DO or LTSO individuals falls under Correctional Service Canada (CSC), and community supervision is handled by the Parole Board of Canada through federal parole offices.

Public data on the number of DO and LTSO applications filed or granted annually in Ontario is not currently available.

4.3.2.4. National Flagging System (NFS)

The National Flagging System (NFS) is a federal-provincial mechanism designed to track individuals who may warrant a DO or LTSO application if they reoffend. In Ontario, the Crown Law Office–Criminal oversees coordination of flagged files. A flagged individual is not subject to additional sentencing conditions, but the presence of a flag serves to alert future Crown counsel to past risk assessments or case history.

Flagging is discretionary and relies on local Crown input. While structured risk tools such as ODARA or Static-99 may be referenced, their use is not required, and no national or provincial standard governs how flags are assigned.

NFS flags are not accessible to police, probation, or victim services. They are held within Crown case files and may only be disclosed if a subsequent prosecution is initiated. As a result, individuals currently flagged for future DO/LTSO consideration may remain unmonitored by other agencies unless they re-enter the court system.

4.3.2.5. System Fragmentation and Risk Visibility

Ontario has no integrated system to consolidate ViCLAS submissions, LSI-CMI scores, NFS flags, or DO/LTSO designation data. Each operates on a separate platform, governed by a different agency or level of government. While Crown counsel may access certain probation or police records via internal case management systems such as SCOPE, this access is not reciprocal. Probation officers cannot see CPIC entries or ViCLAS submissions unless disclosed. Police cannot access LSI-CMI scores or pre-sentence assessments. Victim services have no access to any of these systems and must rely on information relayed by clients or disclosed through formal processes.

The result is a fragmented risk visibility environment in which no actor has access to the full spectrum of post-conviction risk data. In high-risk IPV and SV cases, this can directly impede risk flagging, safety planning, and timely intervention.

This does not mean all systems must be merged. In some cases, limited, role-specific access to core risk indicators would be sufficient. But at present, no structured process or platform ensures that agencies involved in supervision, enforcement, and victim support can view each other’s risk-relevant data. This lack of coordination remains one of the most consistent themes identified in DVDRC reviews, inquests, and practitioner literature.

4.3.3. Domestic Violence Risk Coordinators, Risk Flagging, and Interagency Tracking

In Ontario, Domestic Violence Risk Coordinators (DVRCs) are designated personnel within police services responsible for identifying, monitoring, and coordinating high-risk intimate partner violence (IPV) cases. While the title and structure of the role vary across jurisdictions, the position exists as part of Ontario’s compliance with the provincial policing standard LE-024 (Domestic Violence Occurrences).

Most police services in Ontario have assigned this mandate to a designated officer or unit, either as a standalone DVRC or as part of a broader role. In smaller or rural services, the officer assigned may be performing this function alongside multiple unrelated duties. In larger services, DVRCs may operate within specialized intimate partner violence units. However, there is no formal provincial definition of the role, and no uniformity in its resourcing, training, or mandate.

There is no publicly available provincial registry identifying which services currently maintain an active DVRC or equivalent function. Based on available testimony and documentation, it appears that implementation is determined locally, without centralized oversight.

4.3.3.1. Core Functions and Risk Flagging Responsibilities

Although models differ, DVRCs across jurisdictions are generally responsible for:

• Maintaining internal high-risk IPV offender lists;
• Entering and managing Special Interest Police (SIP) flags in CPIC;
• Flagging high-risk addresses in the computer-aided dispatch (CAD) system for officer safety;
• Supporting safety planning by liaising with Crown attorneys, probation, and, where appropriate, victim services;
• Tracking court outcomes, bail conditions, and probation compliance;
• Ensuring ViCLAS submissions are completed for qualifying offences.

The ViCLAS system, administered provincially by the OPP and nationally by the RCMP, requires the submission of detailed case reports for specified serious offences, including homicide, attempted homicide, sexual assault, and abduction by strangers. DVRCs may play a role in ensuring that ViCLAS submissions are completed in applicable IPV cases, particularly those involving serious sexual violence. However, ViCLAS does not apply to offences such as criminal harassment, and its use is limited to qualifying charges.

SIP entries in CPIC serve as a key mechanism for flagging risk across jurisdictions. These entries are created manually and require clear documentation of threat-related concerns. DVRCs are typically responsible for ensuring that SIP flags are entered, maintained, and updated based on evolving information. They may also flag addresses in CAD systems when an individual is known to pose an elevated risk to a specific victim or household.

Shelters, victim services, and child protection agencies do not have access to internal police databases, including CPIC or local records management systems. As such, the DVRC may become the only accessible point of contact for risk information in the community. The reliability and utility of this function depend on the capacity, structure, and discretion of the local service.

4.3.3.2. Capacity Challenges and Sustainability

In many jurisdictions, DVRCs are assigned to the role without dedicated administrative support. This limits their ability to consistently maintain high-risk tracking tools, update CPIC flags, or follow up on court outcomes. While some larger police services have developed internal dashboards or assigned multiple staff to the IPV file, others rely on a single officer to carry out all coordination functions. In such settings, responsibilities may be deprioritized when competing operational demands arise.

4.3.4. Victim Notification Systems: Structure, Access, and Gaps

Alongside these supervision-related visibility gaps, there are also distinct challenges with how victims are notified of offender movement and status—both in the federal and provincial systems.

4.3.4.1. Victim Notification Systems and Access

CSC and the Parole Board of Canada (PBC) jointly administer the federal victim notification regime. Victims must register to receive information, including:

• the offender’s name;
• the offence the offender was convicted of and the court that convicted the offender;
• the sentence start date and length; and
• the offender’s eligibility and review dates for unescorted temporary absences, day and full parole, and statutory release.⁶⁴⁶

Information is shared only if CSC determines that the victim’s interest in knowing outweighs the offender’s privacy. Notification is typically provided by telephone or mail. The system does not routinely include support referrals or automatic updates to community-based victim service agencies.

At the provincial level, Ontario operates a Victim Notification System (VNS) for provincially sentenced or supervised offenders. Notifications are issued by phone. There is no indication that email is used as a standard method.⁶⁴⁷ Victims must register and are responsible for keeping their contact information current.

In addition to the provincial Victim Notification System, victims of provincially sentenced offenders may also engage with the Ontario Parole Board (OPB), which is responsible for parole decisions for individuals serving less than two years in custody. Through the OPB, registered victims may receive notification of upcoming parole hearings and submit written or recorded victim impact statements or attend hearings in person or remotely. Victims may also designate a representative to participate on their behalf. The OPB maintains a separate registration and support process, distinct from the VNS. Victim information is kept confidential and is not shared with the offender. While the OPB provides procedural support through the Victim Support Line, it does not directly offer counselling or community referrals, and there is no integrated system for linking OPB notifications to victim services or local safety planning supports.⁶⁴⁸

4.3.4.2. Safety Planning and Victim Services

Because neither provincial victim services nor shelters have access to CSC supervision data, they rely entirely on the victim to relay any information they receive through the federal victim notification program. This creates risk in cases where the victim is unaware of a release, unreachable due to outdated contact information, or unable to interpret or act upon the information provided.

Currently, there is no structured protocol requiring the Ontario Parole Board or the Parole Board of Canada to alert local victim services about the release of a supervised offender, even when the victim is actively engaged with those services. In practice, this means that a victim services worker conducting safety planning may be unaware that an offender is about to be released or has already returned to the community.

Advocates have recommended that victim notifications be expanded to include not only the victim but also the relevant victim-serving agency, with appropriate consent and safeguards.

4.3.5. Visibility and Coordination in Federal Offender Supervision

Ontario’s public safety and justice systems have limited visibility into federally supervised offenders, including those on parole or statutory release. This gap arises from the jurisdictional division between Correctional Service Canada (CSC), which supervises federally sentenced individuals, and Ontario’s provincial systems for police, probation, victim services, and child protection. While protocols exist to share some information across systems, there is no centralized framework to ensure that Ontario agencies—particularly those responsible for high-risk intimate partner violence (IPV), sexual violence (SV), or child abuse cases—can access consistent, up-to-date risk information about federal parolees in their communities.

4.3.5.1. Federal Offender Supervision and Risk Tools

CSC supervises federal offenders serving sentences of two years or more. Risk assessment is conducted using tools such as Static-99R (for sexual recidivism), STABLE-2007, ACUTE-2007, and the Dynamic Factors Identification and Analysis–Revised (DFIA-R). These tools are used to determine supervision levels, parole conditions, and intervention strategies. However, these risk scores are not routinely disclosed outside CSC unless a new offence triggers formal prosecution or parole revocation.

Police services may receive basic parole information through CPIC or informal liaison, but probation services, victim services, and child protection workers do not have access to CSC’s internal systems, including the Offender Management System (OMS), where conditions, risk assessments, and incident reports are stored.

4.3.5.2. Systemic Limitations and Risk Visibility

There is no formal requirement that CSC notify Ontario’s Ministry of the Solicitor General, probation officers, or community victim services when a federally supervised offender with a history of IPV or SV relocates to a specific region. While police may be notified depending on the case and local practice, this process is not governed by a province-wide protocol. There is also no mechanism for risk information held by CSC—such as recent breaches, dynamic risk updates, or escalation of conditions—to be automatically shared with local police or prosecution services.

CSC’s “InfoPol” system provides selected law enforcement data to police partners. However, there is no documentation confirming whether Ontario police services routinely use or are trained on InfoPol, and no indication that this system is accessible to probation officers or to agencies involved in safety planning.

4.4. Recommendations

4.4.1. Recommendation 1: Modernize Ontario’s IPV and SV Risk Assessment Tools

Context and Purpose: Ontario relies on a range of structured risk assessment tools to identify and manage intimate partner violence (IPV) and sexual violence (SV) across police, probation, and victim service systems. These include the Ontario Domestic Assault Risk Assessment (ODARA), Domestic Violence Risk Management (DVRM), Danger Assessment, Spousal Assault Risk Assessment (SARA), Brief Spousal Assault Form for the Evaluation of Risk (B-SAFER), Level of Service/Case Management Inventory (LSI-CMI), and, for sexual violence, tools such as Static-99R, STABLE-2007, and ACUTE-2007.

These tools remain supported by the evidence base that informed their original design, but most were developed before several now-widely acknowledged IPV risk indicators were formally recognized—particularly coercive control, technology-facilitated abuse, economic abuse, and animal cruelty. There is no indication that these domains were systematically studied and excluded; more often, they were simply not examined in original validation efforts.

There is now growing consensus—across practice literature, DVDRC reports, and service provider testimony—that these factors may have significant implications for escalation or lethality. This recommendation does not assume their predictive value, but calls for a systematic and expert-led process to evaluate their potential inclusion within Ontario’s core risk assessment tools.

Jurisdiction: This recommendation falls under provincial jurisdiction. The Ministry of the Solicitor General (SolGen), Ministry of the Attorney General (MAG), and Ministry of Children, Community and Social Services (MCCSS) share operational responsibility for the systems that use these tools. Ontario is well positioned to fund academic partners to lead tool revalidation, establish update protocols, and provide updated training and interpretive guidance across sectors.

Recommendation Details: The Government of Ontario should fund the modernization of all core IPV and SV risk assessment tools used in justice, probation, and victim service contexts, with a mandate to:

1. Engage the original developer of each tool—or a designated academic or institutional successor nominated by the developer, host institution, or publisher—to:
   • Evaluate the predictive validity of coercive control, economic abuse, technology-facilitated abuse, and animal cruelty;
   • Conduct structured meta-analysis to assess their potential integration into revised scoring frameworks;
   • Propose revisions only where supported by clear evidence of enhanced predictive utility.
2. Prioritize the evaluation of animal cruelty, given its established association with elevated lethality risk in IPV contexts.
3. Commission further research into Ontario’s SV-specific risk tools (e.g., Static-99R, STABLE/ACUTE) to determine whether emerging domains—such as bestiality, image-based abuse, or digital exploitation—merit structured scoring consideration.
4. Require that revised tools include:
   • Updated training modules and interpretive guidance for affected frontline users;
   • Score transition guidance where thresholds or weighting change;
   • Integration guidance for use in bail briefs, supervision plans, and monitoring dashboards.
5. Establish a regular revalidation/assessment cycle (e.g., every 5–7 years) for all provincially supported IPV and SV risk instruments.

Implementation Considerations:

• In cases where the original developer is unavailable or declines participation, the Province should engage an appropriate research institution in consultation with peer networks, the tool’s original host institution, or its academic publisher.
• Ontario should identify internal leads within relevant ministries (e.g., MAG, SolGen, MCCSS) to coordinate sector-specific implementation of updated tools. These leads should be responsible for supporting the adaptation and standardization of training materials for use across frontline settings, and for ensuring that updated guidance is appropriately tailored to the operational context of police, Crown attorneys, probation officers, child protection workers, and victim service providers.
• Because revised scoring frameworks may affect how risk is interpreted in supervision planning and legal proceedings, updated tools should be accompanied by sector-specific interpretive guidance. Training and evidentiary considerations are addressed under subsequent recommendations.
• Where new scoring models are introduced, legacy scores should not be used interchangeably; clear transition guidance should be included to mitigate misinterpretation.

Rationale: Ontario’s current risk assessment tools are foundational—but aging. Most were developed when the available evidence base did not include coercive control, digital surveillance, or animal cruelty as clearly recognized predictors of risk. Today, these domains are repeatedly flagged by inquest findings, DVDRC reviews, and front-line practitioners—but they remain structurally absent from scoring models.

This recommendation does not call for wholesale tool replacement or untested revision. It supports a cautious, evidence-based revalidation process—anchored in academic leadership and structured evaluation. The goal is not to discard what works, but to ensure that Ontario’s risk infrastructure reflects what is now known about how IPV and SV risk presents, escalates, and endangers.

Modernizing these tools ensures that courts, police, probation officers, and support workers are working with the best possible guidance—not tools that have quietly become outdated. It also provides the evidentiary footing necessary for future reforms involving score visibility, interoperability, and public safety prioritization.

4.4.2. Recommendation 2: Commission a Targeted Review of Child Protection Screening Tools Used in IPV-Exposed Households

Context and Purpose: While not traditionally categorized as IPV risk assessments, the tools used by Ontario’s child protection system—most notably the Comprehensive Family Risk Assessment (CFRA) and Eligibility Spectrum—play a pivotal role in identifying and responding to child safety concerns in IPV-exposed households. These actuarial tools are used by Children’s Aid Societies (CAS) to determine the need for intervention, establish case planning priorities, and assess the likelihood of future harm.

However, the CFRA was developed as part of a broader U.S.-based Structured Decision Making (SDM) framework, and has not been formally revalidated or updated in light of emerging IPV dynamics such as coercive parenting, post-separation control, or the presence of animal cruelty. These risk domains have since been integrated into other international screening tools—such as the full SDM suite or the CARE-NL model—but have not been comprehensively evaluated for predictive value in Ontario’s child welfare context.

This recommendation does not suggest that Ontario’s current tools are inadequate, but that they should be benchmarked against emerging models to confirm continued suitability—and to ensure alignment with other risk assessment tools in use across justice and social services.

Jurisdiction: This recommendation falls under the purview of the Ministry of Children, Community and Social Services (MCCSS), which oversees Ontario’s child welfare system. The government may contract with an external academic or research body to conduct the review, drawing on leading Ontario institutions already active in this field.

Recommendation Details: The Government of Ontario should commission a time-limited review of the CFRA and related child protection screening tools, with a mandate to:

1. Assess whether the CFRA adequately accounts for:
   • Coercive control;
   • Economic abuse;
   • Technology-facilitated parenting interference;
   • Animal cruelty or threats toward pets in IPV-affected households.
2. Compare Ontario’s current tools with alternative validated models such as:
   • The full Structured Decision Making (SDM) framework;
   • The CARE-NL structured professional judgment model.
3. Identify whether revisions, targeted adaptations, or full replacement are warranted, with attention to:
   • Cultural relevance, particularly for Indigenous Child and Family Well-Being Agencies;
   • Predictive validity in IPV-exposed child welfare cases;
   • Interoperability with tools used by police, Crown, and probation.
4. Produce a public-facing summary report and policy recommendations within 18 months of contract award.

Implementation Considerations:

• MCCSS should engage a qualified Ontario-based institution with demonstrated expertise in child welfare risk assessment and IPV-informed family systems research (e.g., CREVAWC, OACAS, CWRP).
• The review must include consultation with both mainstream and Indigenous CAS agencies.
• Recommendations arising from the review may inform revisions to CFRA scoring, training, or protocols—but will not mandate immediate tool replacement unless clearly justified by findings.

Rationale: Child protection decisions in IPV-exposed families rely heavily on early-stage risk screening. If the tools used to identify or triage risk omit critical domains—such as coercive control or animal abuse—the resulting case plans may understate actual risk or fail to coordinate effectively with parallel safety planning efforts by police or probation.

This recommendation ensures Ontario’s child protection screening infrastructure is subject to the same evidence-informed scrutiny as its police and probation-based risk assessments. It is a due diligence step—not an indictment—and ensures the system remains defensible, responsive, and aligned with current understandings of IPV and child risk.

4.4.3. Recommendation 3: Integrate the DVRAG into Ontario’s High-Risk Case Management Framework

Context and Purpose: The Domestic Violence Risk Appraisal Guide (DVRAG) is a validated actuarial tool designed for use in high-risk and post-conviction cases involving male perpetrators of intimate partner violence (IPV). Developed as a second-generation extension of the Ontario Domestic Assault Risk Assessment (ODARA), the DVRAG incorporates psychopathy scoring via the Psychopathy Checklist–Revised (PCL-R), providing a layered evaluation of both offence history and clinically relevant personality traits.

The DVRAG has demonstrated predictive validity across IPV recidivism, general criminal offending, and general violence. It is currently used in a small number of institutional or Dangerous Offender (DO) assessments but has not been integrated into Ontario’s broader risk management or supervision infrastructure. No provincial guidance exists regarding appropriate domains of use, inter-agency sharing, or its potential value in cases where existing tools suggest high risk but lack clinical specificity.

This recommendation does not propose general expansion. The DVRAG is not appropriate for frontline use. Rather, it should be strategically deployed as a tertiary tool in clinically complex, high-harm IPV cases—particularly where multi-agency coordination, long-term supervision, or risk prioritization is required.

Jurisdiction: The Ministries of the Solicitor General and the Attorney General have joint jurisdiction over risk assessment policy, Crown operations, probation services, and forensic supervision pathways. The Ministry of Health may also be involved where assessments are conducted by clinicians embedded in forensic mental health programs. No legislative change is required.

Recommendation Details: The Government of Ontario should support the conditional integration of the DVRAG into high-risk IPV case management by:

1. Commissioning an expert re-review of the DVRAG to determine:
   • Whether it reflects current Ontario-relevant lethality domains (including coercive control, systems abuse, stalking, and animal harm);
   • Whether modernization, adaptation, or validation is required before integration.
2. Working in direct collaboration with the tool’s original developers, research custodians, or designated clinical experts to:
   • Confirm intellectual property rights and permissions;
   • Clarify scope of use and data limitations;
   • Adapt guidance for integration within Ontario’s current risk landscape.
3. Defining appropriate domains of use for DVRAG, including:
   • Dangerous Offender or Long-Term Supervision Order (DO/LTSO) assessments;
   • Post-conviction or bail-stage clinical evaluations where ODARA results are high but require further stratification;
   • Escalating cases flagged for enhanced triage through multi-agency case review processes or dashboards.
4. Supporting limited training and certification of qualified forensic professionals—embedded in corrections, forensic health, or Crown advisory teams—to administer and interpret DVRAG where clinically appropriate.
5. Developing operational protocols that clarify:
   • How DVRAG results should be summarized (e.g., within supervision planning or case review panels);
   • What interpretive safeguards must accompany any use in shared systems;
   • How DVRAG results relate to ODARA or other existing tools.

Implementation Considerations:

• The DVRAG does not currently incorporate certain risk indicators emphasized in recent Domestic Violence Death Review Committee (DVDRC) findings, including coercive control, stalking, systems abuse, and harm to animals. These domains may require formal inclusion or guidance on complementary tools before DVRAG integration can proceed.
• DVRAG assessments require certified PCL-R scorers and full access to clinical or correctional file histories. These preconditions are not met in most community or pre-trial settings.
• The interpretive structure of DVRAG scoring may not map cleanly to existing colour-coded tiering systems or operational dashboards. Additional bridging work would be required before dashboard integration.
• DVRAG was validated exclusively for use with adult male IPV offenders and should not be generalized to other populations.
• Any integration must clearly distinguish between point-in-time triage (ODARA, SARA) and tertiary clinical evaluation (DVRAG) to avoid misuse, overreach, or duplication.

Rationale: Ontario’s existing risk tools and processes could benefit from greater specificity in clinical differentiation of high-risk IPV offenders beyond basic offence-based scoring. The DVRAG, if modernized and applied appropriately, could help identify which offenders require more intensive supervision, higher scrutiny, or coordinated case review—especially in complex or escalating scenarios. Its predictive strength across multiple violence domains is established, but its operational role in Ontario remains undefined.

By commissioning a re-review and partnering with the tool’s developers or custodians, Ontario can clarify how the DVRAG should be used, by whom, and for what purpose. This would allow the province to improve case stratification and reduce harm in the small subset of IPV cases where current tools are insufficient—and where the cost of error is highest.

4.4.4. Recommendation 4: Support Validation and Structured Provincial Adoption of the Jung–Mendoza Campus Risk Assessment Tool

Context and Purpose: Ontario’s colleges and universities routinely encounter situations in which a known or suspected student has caused harm to others—often through stalking, coercion, or escalating relational aggression—but where no criminal charge has been laid. While most institutions have sexual violence policies in place, few have structured frameworks to assess and manage respondent risk. This gap leaves decisions around safety planning, access restrictions, and behavioural oversight vulnerable to inconsistency, legal challenge, or omission.

To address this, a campus-specific community risk assessment tool was co-developed by Dr. Sandy Jung and Dr. Jesmen Mendoza under the Courage to Act initiative. The tool is non-predictive and non-diagnostic. It is designed to help campus professionals document, assess, and respond to cases involving known individuals whose conduct suggests escalating risk. Although it has been shared through training networks and shows strong face validity, the tool has not been validated or formally evaluated for institutional reliability, legal defensibility, or safety outcomes. In the absence of validation, province-wide expansion would be premature and potentially inappropriate. No funding currently supports its use, adaptation, or review.

Jurisdiction: This recommendation falls under the jurisdiction of the Ministry of Colleges and Universities (MCU), which oversees post-secondary institutions and sexual violence prevention funding. The Ministry of the Attorney General and the Ministry of the Solicitor General may also be consulted where integration with threat assessment or justice pathways is relevant.

No legislation requires amendment. Implementation can proceed through programmatic funding, policy guidance, and partnerships with the tool’s developers and institutional stakeholders.

Recommendation Details: The Government of Ontario should support the validation and structured provincial adoption of the Jung–Mendoza campus risk assessment tool by:

1. Funding an independent evaluation of the tool’s reliability, institutional utility, and alignment with existing legal and policy frameworks.
2. Collaborating with the tool’s co-developers to:
   • Review and revise the tool for province-wide application;
   • Establish scope, limitations, and professional usage protocols;
   • Develop training, guidance, and implementation supports tailored to Ontario’s post-secondary environment.
3. Supporting a multi-institutional pilot across a diverse sample of colleges and universities to:
   • Identify institutional variation, operational barriers, and use-case diversity;
   • Evaluate impact on case consistency, early risk identification, and procedural transparency.
4. Developing optional integration pathways for institutions seeking to embed the tool into campus threat response protocols or respondent risk management practices, contingent on validation findings.
5. Ensuring that any eventual implementation is voluntary, rights-compliant, and consistent with the principles of procedural fairness.

Provincial expansion or formal adoption should proceed only if the tool is validated through independent evaluation and pilot testing. Any future integration into campus policies or threat protocols must be grounded in demonstrated reliability, procedural fairness, and operational feasibility.

Implementation Considerations:

• The tool has not yet undergone peer-reviewed validation or outcome analysis. No data currently exists on interrater reliability, legal defensibility, or institutional impact. These issues must be resolved before any system-wide adoption.
• Misuse of the tool—such as use for prediction or unstructured flagging—could expose institutions to reputational, legal, or human rights risk. Clear operational guidance and safeguards must be in place prior to adoption.
• Procedural fairness must be maintained. Risk frameworks involving alleged perpetrators must include transparency standards, role delineation, and consistency with Ontario’s post-secondary policies on student rights and due process.
• Smaller or less-resourced institutions may lack capacity to implement the tool without external support. Early implementation may require direct assistance or differentiated expectations.
• Cultural and structural variation across institutions—including legal frameworks, respondent protocols, and staff configuration—will require flexibility in application and evaluation.

Rationale: Ontario’s post-secondary institutions face real and recurring challenges in managing behavioural risk where no criminal charge exists. Victim-support frameworks are in place, but there is no corresponding structure for respondent risk management. The Jung–Mendoza tool addresses this gap. It does not replace police or legal processes, but offers institutions a structured, trauma-informed framework to make safety-related decisions where concerning behaviour is already known.

By validating the tool and supporting structured uptake, Ontario can strengthen institutional capacity, reduce risk management inconsistency, and improve campus safety infrastructure—while ensuring fairness, caution, and voluntary participation throughout.

4.4.5. Recommendation 5: Standardize Risk Tool Usage by Sector

Context and Purpose: Ontario’s current use of risk assessment tools in intimate partner violence (IPV), sexual violence (SV), and child protection contexts is marked by inconsistency across professions, geographic regions, and stages of the justice and service system. Some police services administer ODARA routinely at the point of charge; others do not. Probation offices may or may not use B-SAFER alongside LSI-CMI. Child protection workers apply tools such as the Comprehensive Family Risk Assessment (CFRA), but it is unclear whether IPV-specific risk factors are addressed consistently or how those tools interact with justice-led assessments.

This lack of alignment reduces the reliability, comparability, and operational value of risk scores. Tools designed to enhance objectivity and coordination become fragmented in their application. Even where tools like ODARA are used, they are applied and interpreted differently across police services, undermining cross-agency communication and case management.

This recommendation proposes a formal but flexible pathway toward sector-specific standardization—while acknowledging that some tools may already be required in certain sectors or embedded in existing policy frameworks. The goal is not to impose strict uniformity, but to clarify expectations, promote equity, and reduce operational uncertainty.

Jurisdiction: This recommendation falls under provincial jurisdiction. The Ministries of the Solicitor General (SolGen), the Attorney General (MAG), and Children, Community and Social Services (MCCSS) all have the authority to commission research, fund expert-led reviews, and issue operational guidance to the systems they oversee. No legislative amendments are required.

Recommendation Details: The Government of Ontario should commission a sector-by-sector academic and policy review to establish a provincial framework for the use of validated IPV, SV, and child protection risk tools. This review should:

1. Be conducted by an independent academic or research institution, such as CREVAWC, with expertise in risk assessment, interagency systems, and victim-centred practice.
2. Be explicitly mandated to consult with:
   • Police services (municipal and provincial);
   • Crown attorneys (including per diem and bail court staff);
   • Probation officers;
   • Children’s Aid Societies (including Indigenous well-being agencies);
   • Victim services organizations and VAW shelters;
   • Relevant ministry staff (MAG, SolGen, MCCSS).
3. Include a review of validated youth-focused structured professional judgment (SPJ) tools—including EARL-20B, EARL-21G, SAVRY, SAPROF-YV, and START:AV—currently used by mental health providers, school-based clinicians, or early intervention programs such as SNAP, to assess whether their application could be better supported, coordinated, or integrated across Ontario’s broader violence prevention framework.
4. Be accompanied by written authorization permitting frontline personnel to speak freely to researchers without concern that participation will be construed as criticism of ministry policy, local practice, or management decisions.
5. Document:
   • What tools are currently in use by sector, role, and region;
   • Whether their use is mandatory, recommended, or informal;
   • Whether the tools are used at charge, bail, sentencing, supervision, or safety planning stages;
   • The extent to which scores are recorded, interpreted, and shared across systems.
6. Produce a recommended framework that:
   • Clarifies expected tool use by sector and context (e.g., ODARA for police at charge; LSI-CMI for probation intake);
   • Identifies permissible variations or local adaptations where applicable;
   • Supports consistency without overriding professional judgment.

Implementation Considerations:

• The final framework should be issued publicly by the responsible ministries, with clear language that distinguishes between mandatory, recommended, and context-specific uses.
• Ministries should align the framework with modernization timelines for tools (Recommendation 1), updates to child protection screening (Recommendation 1.1), and standardized training infrastructure (Recommendation 3).
• Where multiple tools may be appropriate for a given sector (e.g., B-SAFER or SARA), the framework should identify conditions for use, comparability guidance, and documentation expectations.
• If any tools are currently mandated by regulation or internal directive, that status should be clearly acknowledged and incorporated into the review.

Rationale: Clarity about which risk tools are to be used by whom—and when—is foundational to consistency, coordination, and defensibility. In the absence of a sector-wide framework, Ontario’s risk assessment infrastructure remains fragmented. This undermines safety planning, compliance monitoring, court decisions, and interagency communication. It also increases the likelihood that risk tools will be used in ways that are inconsistent, undertrained, or misinterpreted.

This recommendation does not call for top-down imposition or a one-size-fits-all tool. It calls for Ontario to commission a credible, independent review that produces clear, practical, and evidence-informed expectations—allowing professionals across systems to operate with confidence, consistency, and accountability.

4.4.6. Recommendation 6: Standardize Risk Tool Training, Certification, and Sector-Specific Literacy

Context and Purpose: Validated risk assessment tools—including ODARA, B-SAFER, LSI-CMI, the Danger Assessment, and CFRA—are increasingly used across Ontario to inform bail decisions, probation supervision, child protection involvement, and victim safety planning. However, there is currently no province-wide framework for training, certification, or recertification in these tools, even among frontline professionals using them in high-stakes contexts.

Training access and content vary significantly by sector and region. Some professionals receive structured instruction while others rely on informal or ad hoc learning. Inconsistent application and interpretation undermine the value of the tools themselves, contribute to interagency communication failures, and risk over- or underestimating the actual level of danger in a given case.

This recommendation proposes a practical, phased framework for standardized risk assessment training across Ontario’s justice, child protection, and community service systems. It emphasizes coordination with tool modernization efforts (Recommendations 1 and 1.1), accommodates the realities of existing training infrastructure, and supports gradual, system-aligned implementation at scale.

Jurisdiction: The Ministries of the Solicitor General, Attorney General, and Children, Community and Social Services are responsible for professional development standards within their respective sectors. These ministries hold authority over training expectations and delivery mechanisms, including police colleges, probation onboarding, Crown education, and child protection guidance.

However, responsibility for training content lies with the original developers of each validated risk tool, or their designated academic or institutional successors. Ministries are not curriculum designers, but are responsible for funding, delivery, and ensuring province-wide coordination and access.

The Province does not have jurisdiction over the internal policies of non-profit, community-based organizations such as shelters and victim services. However, these organizations routinely support victims at high risk, participate in safety planning, and often engage with the justice system before formal involvement occurs. They bring substantial operational insight and practical experience to risk-informed work. Training and interpretive materials should therefore be made fully accessible to them, and the proposed OIVPRN hubs should support their inclusion and engagement.

Recommendation Details: The Government of Ontario should implement a standardized, phased training framework for validated IPV, SV, and child protection risk assessment tools, supported by ministry infrastructure, developer-led content creation, and a long-term plan for delivery at scale.

Phase 1: Immediate Improvements Using Existing Resources

1. Fund and support the development of standardized, role-specific training materials by the original developers or designated academic successors of each validated tool.
2. Deliver training through existing platforms and institutional pipelines, such as:
   • Online modules (e.g., ODARA 101);
   • Ontario Police College, Crown School, probation onboarding, and regional child protection networks;
   • Webinars, printed scoring guides, train-the-trainer sessions, and downloadable resources.
3. Launch a phased, province-wide rollout with the objective that, within two years, all operational users of validated tools—including police officers, probation staff, and CAS workers—will have completed standardized training appropriate to their role.
4. Where risk tool use is currently supported by training infrastructure (e.g., ODARA at OPC), existing materials should be reviewed and refreshed for consistency, alignment, and integration with modernized tool versions.
5. Establish recertification or refresher training expectations at defined intervals (e.g., every 3–5 years), tailored to sector-specific needs and tool usage frequency.
6. Ensure that all training materials reflect the most current validated version of the tool. Where a tool has been revised, ministries should coordinate with developers to issue version-specific training and communicate clearly to avoid score inconsistencies across regions or systems.
7. Calibrate training expectations by role:
   • Police and probation: scoring, documentation, communication of risk levels;
   • Crown attorneys: interpretation, admissibility, and evidentiary framing at bail and sentencing;
   • CAS and shelter staff: cross-sector interpretation and risk communication in case conferencing or service triage.
8. Make training materials and interpretive guidance fully accessible to non-profit service providers, including VAW shelters, sexual assault centres, and community-based victim support organizations. Although these providers are not subject to ministry mandates, their participation is critical to effective, coordinated risk response.

Phase 2: Strategic Infrastructure and Long-Term Delivery

9. Begin development of a centralized, province-wide training portal (potentially integrated into the proposed OIVPRN digital backbone) to host:
   • Training modules by tool and sector;
   • Role-based simulations and walkthroughs;
   • Certification and recertification tracking;
   • Updated scoring protocols as tools are revised.
10. Recognize that full portal implementation and operational readiness will require sustained effort over several years. Ministries should continue expanding access to asynchronous training and maintain interim infrastructure to reach rural and under-resourced services.

Judicial Education

11. The Province should respectfully call on federal and provincial judicial leadership—including the Chief Justices of the Ontario Court of Justice and Superior Court of Justice, the Ontario Judicial Education Secretariat, and the Canadian Judicial Council—to develop and deliver education materials for the judiciary (including part-time, per diem, and Unified Family Court judges) on the foundations, purpose, and evidentiary relevance of validated risk assessment tools.
12. Judicial education materials should:
    • Introduce the most commonly encountered tools (e.g., ODARA, DVRM, SARA);
    • Explain scoring methodology, validation history, and appropriate interpretation boundaries;
    • Clarify how these tools may be introduced or considered in bail, sentencing, custody, or child protection proceedings.

Implementation Considerations:

• Ontario currently lacks a scalable, integrated training infrastructure for risk assessment tools. This recommendation proposes a phased approach that avoids sudden disruption or unrealistic expectations.
• While full compliance cannot occur overnight, a two-year target period provides a reasonable timeframe to ensure that operational users receive standardized instruction without risking frontline service continuity.
• Ministries should coordinate interim rollout with developers to avoid overlap or misalignment between legacy and updated tool versions.
• Bench education must respect judicial independence while encouraging risk literacy across criminal, family, and child protection contexts.
• Ontario’s existing Victim Services Training Portal may offer a foundation for expanding access to risk assessment content for community-based victim service providers. Further review would be required to determine the extent to which the portal currently supports risk tool education, and whether it could serve as a host platform or referral point for standardized interpretive materials.
• The OIVPRN could serve as both a delivery mechanism and coordination platform, especially for cross-sector training, certification tracking, and engagement with non-governmental actors.

Rationale: Risk assessments cannot function reliably without structured training. Poorly applied tools may produce misleading scores or erode trust in evidence-based supervision and safety planning. Consistent training strengthens interagency coordination, improves risk interpretation across contexts, and supports meaningful use of risk scores in bail, sentencing, and child protection decisions.

This recommendation is not based on the assumption that overnight compliance is feasible. It reflects Ontario’s current starting point—no centralized infrastructure, no province-wide mandate—and provides a structured, realistic pathway forward. It supports tool modernization (Recommendation 1), sector-wide standardization (Recommendation 2), and the eventual integration of risk-informed practice into all stages of decision-making across systems.

4.4.7. Recommendation 7: Establish a Structured Framework for Role-Based Information Sharing to Support Risk-Informed Decision-Making

Context and Purpose: Professionals across Ontario’s justice, child protection, and victim support systems routinely make decisions about risk—whether related to supervision, intervention, safety planning, or support triage. However, there is currently no structured, cross-sector framework governing access to risk-relevant information such as validated risk scores, supervision conditions, release status, applicable court orders, or relevant case histories.

Victim services and shelters carry a distinct responsibility for safety planning with victims of intimate partner violence, sexual violence, and coercive control, including those who have not engaged the justice system. These organizations operate outside of government structures and are not generally granted access to formal criminal records, court files, child protection systems, or supervision information. This limits their ability to develop informed, risk-responsive safety plans—even in cases where high-risk indicators are already known to other service providers.

At the same time, child welfare workers, probation officers, and police officers may lack visibility into parallel risk assessments or conditions imposed by other systems. No coordinated structure currently exists to support lawful, role-based sharing of this information.

This recommendation proposes a two-phase approach: first, to establish clear legal, operational, and privacy parameters for cross-sector information sharing, including with non-governmental victim services; and second, to assess the feasibility of long-term digital infrastructure that could securely manage and document that sharing, under the eventual oversight of the Ontario Integrated Violence Prevention and Response Network (OIVPRN).

Jurisdiction: The Ministries of the Solicitor General, Attorney General, and Children, Community and Social Services each oversee institutions that hold risk-relevant information. While nonprofit victim services organizations fall outside government employment structures, the province holds responsibility for facilitating a legal and policy environment that supports risk-informed safety planning.

Each ministry should designate a responsible representative to participate in the planning and review process described below. While the ministries are not the primary authors of the operational framework, they must enable implementation by directing and supporting the participation of agencies under their mandate.

Phase 1: Framework Development and Implementation Planning

1. Fund and facilitate a time-limited, multi-agency planning process involving representatives from police, probation, CAS, Crown/VWAP, victim services, and privacy/legal experts. This process should:
   • Identify what risk-relevant information is currently held in each system;
   • Determine what may be lawfully shared, with whom, under what conditions, and for what purpose;
   • Recommend protocols, usage boundaries, and safeguards;
   • Deliver findings and implementation-ready recommendations within 12 months.
2. Develop interim operational guidance for structured information-sharing between government systems and victim services, including but not limited to:
   • ODARA score or tier (where scored);
   • Criminal records;
   • Community supervision status and relevant conditions;
   • Existence of active proceedings and next court date;
   • Past IPV- or SV-related occurrence reports or charges involving the accused or identified abuser;
   • Child welfare information relevant to the accused, subject to legal review and applicable privacy protections.
3. Develop standardized policies requiring designated liaisons to be identified within each OIVPRN-local system or office (e.g., police service, probation office, CAS branch, Crown/VWAP) to receive and respond to structured information requests from authorized personnel at victim services organizations.
4. Develop and distribute interpretive guidance and training materials for victim services organizations receiving this information. This should include guidance on interpreting risk scores, understanding legal documents, and applying that information appropriately within the scope of safety planning. Training content should be developed in collaboration with original tool authors and delivered in alignment with Recommendation 3.
5. Establish appropriate use safeguards, including:
   • Identified personnel within each victim services organization to receive and handle shared information;
   • Signed confidentiality and use agreements outlining limits on access and disclosure;
   • Clear restrictions stating that, absent exceptional circumstances to be defined in policy, any records or documents shared with and received by victim services under this framework—including but not limited to criminal records, risk scores, supervision data, or occurrence reports—are not to be disclosed to the victim, made available for the victim’s viewing, or otherwise communicated in a way that reveals their content. These materials are intended for internal use by authorized personnel for safety planning purposes only and are not to be shared, excerpted, or distributed in any form to the victim or others;
   • Where there is risk of imminent or serious harm, indirect disclosure of essential information to the victim may be permitted, provided that no original record is shared and disclosure occurs through a structured, policy-compliant communication protocol.
6. Reaffirm that victim-generated tools such as the Danger Assessment must not be disclosed to police, Crown, CAS, or any government actors without the victim’s informed and explicit consent or when risk level warrants sharing regardless of consent. These are not forensic instruments and may contain sensitive disclosures that, if inadvertently disclosed (e.g., in a Crown brief), could create legal or safety risks for the victim.

Phase 2: Long-Term Infrastructure and Digital Access Planning

7. Commission a feasibility assessment of a centralized, secure digital platform—modeled after the SCOPE system—to support structured, role-based access to risk-relevant information across sectors. The system should:
   • Be scoped for eventual integration into the OIVPRN infrastructure;
   • Support structured uploading and tracking of: risk assessments and scores, court orders (past and present), and court dates across parallel proceedings (criminal, family, child protection);
   • Enable requests from victim services to be submitted and acted on through the same platform;
   • Include configurable, role-based access controls to ensure that each user sees only the information required for their function;
   • Allow linking by individual, family, or household identifiers without requiring duplicate data entry.
8. Ensure that digital infrastructure follows—not drives—policy development. System design and procurement should only begin after legal, operational, and governance frameworks have been clearly defined and accepted by all participating systems.

Implementation Considerations:

• Victim services organizations are not Crown agencies but provide a core public safety function. Their non-governmental status must not be a barrier to participation in risk-informed service coordination.
• Information shared under this framework is for internal planning and coordination only. Shared documents and records are not to be distributed, excerpted, or used for any purpose beyond what is authorized under the framework.
• VWAP’s dual role—as both a Crown-adjacent program and a communication conduit to victims—should be clarified. VWAP remains responsible for explaining court processes, preparing victim impact statements, and serving as the Crown’s primary intermediary, even where a victim is also connected to a non-governmental support agency.
• Administrative burden must be accounted for. Where agencies are asked to respond to external information requests or upload documents into shared platforms, appropriate staffing support must be considered.
• Regional variation in readiness should be anticipated. While policy should be standardized, implementation support may need to be locally tailored.

Rationale: Ontario’s risk assessment infrastructure remains fragmented. Information needed to manage risk across systems—police, probation, CAS, court, and victim support—exists, but is not shared in a coordinated, lawful, or structured way. Victim services workers are often left to safety plan in the absence of supervision conditions, risk scores, or case histories that could affect the immediacy of danger. Other professionals may make supervision or child protection decisions without knowing the full context of risk in parallel systems.

This recommendation does not call for open access or universal integration. It proposes a measured, two-phase approach. First, define what can be shared, how, and with whom—then assess whether shared infrastructure could support that structure responsibly. The intent is not to dismantle institutional privacy obligations but to enable thoughtful coordination in the interest of public safety, child protection, and victim support.

Improved risk information sharing allows professionals to make more informed decisions, allocate limited resources more effectively, and ensure that those tasked with managing risk are not doing so in isolation. Preventing harm before escalation occurs not only improves safety outcomes but also reduces downstream system strain. When coordinated safety planning succeeds, it can avoid costly justice system involvement, emergency response, re-victimization, and long-term service utilization. The individuals whose cases are implicated in this framework are, by definition, at elevated risk. This is not general information-sharing—it is targeted prevention that benefits both the individual and the broader public system.

This recommendation establishes the groundwork for a scalable, role-based, legally sound approach to that coordination—anchored in the province’s long-term commitment to violence prevention and public protection.

4.4.8. Recommendation 8: Align Police Access to Probation Risk Information to Support Community-Based Compliance Monitoring

Context and Purpose: Police and probation services play complementary roles in supporting community safety and supervision. Probation officers are responsible for managing individuals subject to community-based sentences. Their focus includes verifying participation in mandated programs, confirming attendance at scheduled appointments, and supporting rehabilitation and reintegration. In support of this role, probation services make use of validated risk assessment tools such as the Level of Service Inventory (LSI-CMI), Static99R, and STABLE/ACUTE, along with other documentation that may include risk-related psychological evaluations or recidivism-focused reports.

Probation services are not structured or resourced to conduct mobile compliance monitoring. They do not perform field-based checks on curfews, geographic restrictions, or residence conditions. Police services, by contrast, are equipped for enforcement and have the operational capacity to respond in the community. As proposed elsewhere in this report, certain enforcement-related compliance responsibilities may shift from probation to police, particularly in cases involving intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), or animal cruelty—a known risk indicator for interpersonal violence.

To carry out these functions effectively, police services require visibility into risk-related information held by probation. At present, there is no structured mechanism for accessing such information. Risk scores and other relevant assessments are not routinely shared, and discretionary disclosure remains the exception rather than the norm. A policy and operational framework is needed to ensure that this information can be shared where it is relevant to enforcement, within clear legal and operational parameters.

Jurisdiction: The Ministry of the Solicitor General oversees both probation and police services and holds the necessary authority to facilitate information-sharing frameworks across these domains. Where compliance functions intersect with court-imposed conditions, coordination with the Ministry of the Attorney General may also be required.

Recommendation Details: The Government of Ontario should develop a structured framework to support the operational transition of certain community compliance responsibilities to police by enabling appropriate access to probation-held risk information. This framework should:

1. Confirm that police services tasked with enforcing community-based conditions in cases involving IPV, SV, HT, or animal cruelty require access to relevant probation-held information, including:
   • LSI-CMI scores;
   • Static-99R and STABLE/ACUTE scores, where applicable;
   • Relevant findings from recidivism-related reports or psychological evaluations, where those findings relate to managing active risk in the community.
2. Conduct a policy and legal review, led by the Ministry of the Solicitor General, to determine:
   • What information may be operationally relevant to enforcement;
   • What form that information should take (e.g., full, redacted, or summary);
   • How this information may be lawfully shared, documented, and audited.
3. Establish operational protocols for the identification, review, and structured sharing of probation-held information with police services, including:
   • Designated roles within probation for handling requests;
   • Standardized request templates and secure transfer mechanisms;
   • Clear documentation and retention requirements.
4. Maintain the distinct role of probation. This recommendation does not alter probation’s rehabilitative focus. It recognizes that enforcement functions require different resources and tools, and that operational alignment is necessary where supervision and enforcement responsibilities are shared.
5. Provide role-specific training and interpretive guidance to probation and police personnel to support implementation, including:
   • How risk scores are derived and what they indicate;
   • How to apply risk information when prioritizing compliance activity;
   • What constitutes appropriate use and communication.
6. Plan for integration into future shared infrastructure, including the potential for uploading and role-based access to risk assessments and supervision-related documentation through the OIVPRN data platform.

Implementation Considerations:

• Psychological and clinical content must be carefully screened. Only risk-relevant and operationally appropriate information should be shared.
• The framework should clarify thresholds for when risk information becomes relevant to enforcement, without requiring full file access.
• Templates and summary formats may support consistency and reduce administrative burden.
• The policy framework should align with existing privacy legislation and preserve institutional accountability.

Rationale: As enforcement of community-based conditions evolves to reflect risk-informed public safety strategies, operational coordination between police and probation becomes more important. Police cannot triage or prioritize compliance checks in the absence of risk information. Probation services already hold that information—but the systems do not currently speak to one another in a structured or sustainable way.

This recommendation enables that alignment. It does not call for system-wide data sharing or redefinition of roles. It proposes a targeted, legally grounded structure to ensure that when police are asked to act on risk, they can do so based on evidence already collected within the supervision system.

Aligning visibility with responsibility improves coordination, supports public safety, and ensures that enforcement capacity is used effectively and proportionately. It also lays the groundwork for longer-term integration within a shared, access-controlled infrastructure—without duplicating mandates or compromising institutional roles.

4.4.9. Recommendation 9: Strengthen and Standardize the Domestic Violence Risk Coordinator (DVRC) Role Across Police Services

Context and Purpose: Many police services in Ontario have designated Domestic Violence Risk Coordinators (DVRCs), a role that appears to be aligned with the intent of Ontario’s 2013 LE-024 Policing Standard on Domestic Violence. While the role is widely implemented in practice, it is not formally defined in regulation and does not appear in the Community Safety and Policing Act (CSPA) or its regulations. No provincial standard currently exists to guide implementation.

In practice, DVRCs may take on a range of coordination responsibilities, including managing IPV-related case lists, entering and monitoring Special Interest Police (SIP) flags in CPIC, maintaining CAD-based address flagging, liaising with Crown, probation, and child welfare agencies, participating in Situation Tables or high-risk panels, and responding to information and safety planning requests from victim services and shelters. In smaller or more rural police services—or in services where the role is assigned minimal priority—these responsibilities may be added to a broader portfolio of unrelated tasks. The function may be held by officers with multiple concurrent roles, and is not always clearly identified or externally visible.

There is currently no public-facing roster of DVRCs across Ontario, which can make it difficult for partner agencies to determine the appropriate liaison point for risk-related coordination or safety planning—particularly in regions without established interagency history.

Jurisdiction: The Ministry of the Solicitor General is responsible for developing provincial policing standards and issuing operational guidance. While police services are governed locally and funded primarily through municipal budgets, the ministry holds authority to establish role expectations, coordination protocols, and reporting standards that support consistent implementation.

Recommendation Details: The Government of Ontario should strengthen and standardize the Domestic Violence Risk Coordinator (DVRC) role across all police services, including:

1. Defining the DVRC function through ministry-issued operational guidance, with role expectations that include:
   • Coordination of internal responses to elevated-risk IPV cases;
   • Oversight of high-risk case lists and structured case follow-up;
   • Management of SIP flags and CAD address alerts (directly or with administrative support);
   • Liaison work with Crown, probation, child protection, and victim services personnel;
   • Participation in interagency safety planning meetings and risk coordination mechanisms.
2. Requiring that each police service designate at least one DVRC, with flexibility to combine responsibilities in smaller or lower-volume jurisdictions.
3. Establishing and maintaining a public-facing registry of DVRC contacts, listing the designated point of contact in each police service and OPP detachment or cluster.
4. Assessing how the DVRC function is implemented within the OPP, including whether each detachment requires its own coordinator or whether shared coverage is appropriate in remote or low-volume areas.
5. Directing and supporting the development of a standardized training module for newly appointed DVRCs, with optional refresher materials made available on a defined cycle. Training should align with evidence-based risk assessment tools, coercive control indicators, and current technology-facilitated abuse trends.
6. Directing that administrative support be made available for DVRC functions, including responsibilities such as list management, flag tracking, coordination documentation, and interagency scheduling. In larger services, this support may be dedicated; in smaller or rural services, it may be provided on a part-time or shared basis across roles or departments.
7. Reintroducing an annual provincial DVRC meeting or conference, last held in 2017, to support cross-jurisdictional learning, coordination, and the sharing of practices and challenges across Ontario police services.

Implementation Considerations:

• Services vary significantly in staffing and structure. The framework should allow flexibility while ensuring province-wide consistency in function and accessibility.
• Where responsibilities are already assigned under another title or portfolio, the DVRC function should be clearly identified and documented to support external coordination.
• Police services are funded through municipal budgets. Expanding and standardizing the DVRC function may require modest local investment, particularly for administrative support, role clarity, and participation in interagency activities.
• Ontario’s LE-024 Policing Standard may have provided the original policy rationale for the DVRC role. While broader LE-024 updates are addressed elsewhere in this report, the DVRC function should be explicitly considered within any future modernization of that standard.

Rationale: The Domestic Violence Risk Coordinator role plays a central part in Ontario’s local risk coordination systems, but its implementation has been informal, uneven, and under-resourced. Officers have continued fulfilling these responsibilities without provincial infrastructure, formal definition, or consistent administrative support.

This recommendation affirms the value of the DVRC function and provides a clear structure for its continued implementation. It ensures that every police service identifies a responsible contact, that training and support are available, and that the function is accessible to the external partners who rely on it to coordinate safety plans and manage risk. It also supports longer-term integration of the DVRC role into OIVPRN-coordinated risk management systems and digital platforms.

By standardizing this role, Ontario strengthens its capacity for coordinated risk response—and ensures that a key point of connection in violence prevention systems is supported, visible, and consistent across the province.

4.4.10. Recommendation 10: Assess and Strengthen ViCLAS Compliance Visibility Mechanisms

Context and Purpose: Ontario police officers are required to submit ViCLAS Crime Analysis Reports (CARs) to the provincial ViCLAS Centre—administered by the Ontario Provincial Police—for designated violent offences under O. Reg. 395/23. Until 2024, a now-revoked regulation required every Chief of Police to report annually to the Ministry of the Solicitor General on the number of ViCLAS submissions made. These reports were not made public, and the Ministry was not obligated to act on or publish the data.

Although the obligation to submit ViCLAS reports remains, no oversight mechanism currently exists to verify compliance across services. This is not presented as evidence of non-compliance, but the absence of a consistent, visible verification process may create a gap in system-level accountability. Given the role ViCLAS plays in detecting patterns of violent behaviour—including serial sexual offending—ensuring consistent participation is important for public safety and investigative continuity.

Jurisdiction: The Ministry of the Solicitor General oversees provincial policing standards and the regulatory framework governing ViCLAS submission obligations. The Ontario Provincial Police administers the provincial ViCLAS Centre. This recommendation does not propose changes to ViCLAS operations, but rather a review of whether service-level compliance can be made more consistently visible to oversight bodies or system partners.

Recommendation Details: The Government of Ontario should assess whether a consistent and visible mechanism exists—or should be established—for verifying service-level compliance with ViCLAS submission obligations under O. Reg. 395/23. This process should:

1. Confirm what monitoring capacity currently exists, if any, within the Ontario Provincial Police or Ministry of the Solicitor General to:
   • Identify services that are consistently submitting ViCLAS reports;
   • Flag cases where qualifying offences are not being reported;
   • Support continuous improvement in ViCLAS compliance and training.
2. Determine whether an independent or inter-agency visibility mechanism is feasible, such as:
   • Localized service-level compliance summaries shared with police service boards;
   • Aggregate compliance summaries provided to oversight bodies or the proposed OIVPRN;
   • Internal dashboards tracking submission frequency by offense category and year.
3. Clarify that the goal is not to resume reporting for its own sake, but to ensure that a known investigative tool is being used consistently, and that data integrity is preserved across jurisdictions.

Implementation Considerations:

• The former annual reporting requirement did not include a public accountability mechanism. Any new system should consider who will receive, interpret, and act on compliance data.
• Oversight structures could align with broader data visibility recommendations included in this report, including integration with OIVPRN reporting infrastructure.
• Any mechanism should avoid duplication of reporting already occurring at the service level and be designed to minimize administrative burden.

Rationale: ViCLAS submissions are required by regulation and serve a recognized investigative and public safety function. While there is no indication that services are failing to comply, the removal of a province-wide reporting requirement has created a visibility gap. Without a centralized or inter-agency mechanism to verify that reports are consistently submitted, opportunities to detect serial offending patterns may be missed, and system-wide quality assurance is harder to sustain.

This recommendation proposes a practical review of whether existing oversight is sufficient, and if not, what lightweight and locally useful compliance tools could be developed. It supports broader efforts to improve risk data coordination, without duplicating mandates or assuming non-compliance in the absence of evidence.

4.4.11. Recommendation 11: Sustain and Formalize the Use of Situation Tables Within an Integrated Risk Coordination Framework

Context and Purpose: Situation Tables are collaborative, multi-agency forums designed to coordinate interventions for individuals or households identified as being at acutely elevated risk. Following a four-filter model, these Tables bring together representatives from police, housing, mental health, child protection, and social services, among others, to share limited information and determine whether coordinated, consent-based intervention is appropriate. Their primary objective is early identification and de-escalation of risk, particularly in cases that cross multiple service boundaries.

Although not designed specifically for intimate partner violence (IPV), sexual violence (SV), or human trafficking (HT), Situation Tables frequently surface individuals vulnerable to victimization in these domains. They offer one of the few consistent cross-sector structures for early intervention in many Ontario communities, particularly in regions without formal high-risk case panels or risk-focused interagency teams.

Despite their value, Situation Tables remain locally governed and unevenly resourced. Some communities have long-standing, well-supported Tables; others have no comparable mechanism in place. Administrative support is often provided by police services, but not consistently. There is no province-wide system to track where Tables exist, what roles they play, or whether they are functioning effectively. This variability creates challenges for long-term sustainability, knowledge transfer, and integration into broader violence prevention strategies. Current Situation Tables also vary in the extent to which high risk IPV, SV and HT cases are typically included as part of their work.

This recommendation affirms the importance of Situation Tables, supports their continued use, and proposes a phased integration into Ontario’s broader risk coordination framework through the Ontario Interpersonal Violence Prevention and Response Network (OIVPRN).

Jurisdiction: Situation Tables are not mandated by legislation, but the Ministry of the Solicitor General has supported their development through prior training and guidance initiatives. OIVPRN, once operational, may offer a consistent platform for supporting, connecting, and expanding Table operations across the province.

Recommendation Details: The Government of Ontario should sustain and support the use of Situation Tables within Ontario’s risk coordination ecosystem and begin integrating them into the structure and supports offered by the Ontario Interpersonal Violence Prevention and Response Network (OIVPRN). This should include:

1. Confirming provincial support for the continued use of Situation Tables, recognizing their value in identifying individuals at risk of victimization or escalation, and supporting early intervention in cross-sector cases.
2. Supporting and maintaining existing, locally coordinated Situation Tables, including those currently administered by police or community safety networks, by providing access to:
   • Optional documentation tools and shared coordination resources;
   • Regional training and knowledge-sharing opportunities;
   • Infrastructure supports through OIVPRN where appropriate.
3. In regions where no functioning Situation Table currently exists, facilitating the establishment of one through OIVPRN coordination, with flexibility to reflect local context and community capacity.
4. Clarifying that each OIVPRN catchment area is expected to have access to a structured, multi-agency early intervention mechanism, in the form of a Situation Table or equivalent model that adheres to recognized principles and structure (e.g., the four-filter model used in Ontario).
5. Ensure reporting of information in IPV, SV and HT, as part of the Risk Driven Tracking Data to monitor the recognition and inclusion of IPV, SV and HT cases as part of Situation Table processes.
6. Encouraging participating agencies to designate consistent liaison representatives, to support institutional memory, case continuity, and smoother inter-agency collaboration.
7. Assessing administrative support needs across communities and exploring resourcing options—including the possibility of OIVPRN-supported staffing models—for jurisdictions that do not have dedicated coordination capacity.
8. Supporting structured sharing of risk-relevant information, where appropriate and permitted, in accordance with the information-sharing frameworks outlined in Recommendation 4.

Implementation Considerations:

• Provincial support should reinforce, not replace, the local flexibility that has contributed to the model’s success in many communities.
• In regions with established Tables, OIVPRN may play a light-touch role, offering infrastructure and coordination tools but deferring to local leadership.
• In regions without current access, OIVPRN may take a more active role in facilitating implementation, with resources, sample protocols, and optional staffing supports.
• Some Situation Tables are currently supported in part by police services or local in-kind contributions. Provincial support through OIVPRN may include mechanisms to supplement, but not duplicate, those investments.

Rationale: Situation Tables are a valuable part of Ontario’s risk coordination infrastructure. They identify cases of acutely elevated risk that might otherwise go unrecognized, and provide a structured setting for collaborative, cross-sector intervention. While not designed specifically for IPV/SV/HT, they often surface related risk and serve as a bridge to more specialized support pathways.

This recommendation ensures that existing Tables are sustained, communities without Tables are supported, and OIVPRN provides the structure necessary to connect and reinforce these local mechanisms. It also reinforces the expectation that early intervention capacity—through a Table or recognized equivalent—should exist in every region, without mandating a one-size-fits-all model.

Over time, OIVPRN may offer a natural home for shared resources, administrative support, and potential resourcing strategies to ensure the continued viability of early intervention models province-wide.

4.4.12. Recommendation 12: Improve Ontario’s Visibility into Federally Supervised Offenders Released into the Province

Context and Purpose: Federally supervised individuals—those serving parole or statutory release following a sentence of two years or more—are monitored by Correctional Service Canada (CSC) under federal jurisdiction. While police services may receive basic information through CPIC or liaison with parole offices, there is currently no structured protocol requiring CSC or the Parole Board of Canada (PBC) to notify Ontario’s probation services, child protection authorities, or community-based victim services when an offender with a known history of intimate partner violence (IPV), sexual violence (SV), or human trafficking (HT) returns to a specific region.

CSC uses validated risk assessment tools, including Static-99R, STABLE-2007, ACUTE-2007, and the Dynamic Factors Identification and Analysis–Revised (DFIA-R), to guide supervision and case planning. However, these scores are not routinely shared with Ontario authorities unless new charges are laid, or a parole breach is formally adjudicated. Even where high-risk supervision is underway, provincial agencies responsible for safety planning may be unaware of the offender’s presence, supervision conditions, or risk classification.

Public Safety Canada has acknowledged that while some information-sharing agreements exist, they are limited in scope, inconsistent across jurisdictions, and may fail to meet the operational needs of provincial actors. Victim services and shelters—unless directly informed by the victim—often remain unaware that an offender has been released. There is no designated point of contact within CSC for cross-jurisdictional safety coordination at the regional level, nor any integration with Ontario’s proposed OIVPRN catchment model.

Jurisdiction: This recommendation relates to federally supervised offenders and falls under federal jurisdiction. While Ontario cannot unilaterally impose requirements on Correctional Service Canada or the Parole Board of Canada, it can formally call on the federal government to implement system-level improvements to protect Ontarians. Ontario’s ministries responsible for public safety, justice, and victim protection are well positioned to make such a request through intergovernmental channels.

Recommendation Details: The Government of Ontario should formally request that the federal government—through CSC and the Parole Board of Canada (PBC)—establish structured coordination mechanisms to support risk-informed information sharing with Ontario when federally supervised individuals with known histories of IPV, SV, or HT are released into the province.

These mechanisms should include:

• A requirement that CSC notify Ontario’s Ministry of the Solicitor General (or designated contact point within the proposed OIVPRN structure) of any planned release into the province involving an offender assessed as high-risk due to a history of IPV, SV, or HT;
• A commitment to provide relevant, role-specific risk and supervision information to appropriate Ontario agencies (e.g., police, probation, CAS, and—where the victim is actively engaged—authorized victim services), consistent with federal privacy legislation and subject to consent and operational safeguards;
• The designation of federal-regional liaison roles or coordination points to ensure timely communication with local officials, particularly in cases where multiple provincial agencies may be impacted;
• Technical support for the integration of risk-related data into Ontario’s structured safety planning infrastructure, including potential future OIVPRN dashboards or alerting systems;
• A formal response timeline for Ontario’s request, including opportunities for bilateral planning and implementation monitoring.

Implementation Considerations:

Ontario should develop and submit this request through appropriate federal-provincial channels, including the Federal-Provincial-Territorial (FPT) Ministers Responsible for Justice and Public Safety tables.

The request should be accompanied by:

• A jurisdictionally grounded rationale based on provincial responsibilities for policing, child protection, and victim safety;
• Documentation from inquests, DVDRC reviews, and Public Safety Canada evaluations highlighting the consequences of fragmented information-sharing;
• A proposal to pilot coordination in select regions (e.g., those covered by the early OIVPRN catchments) before wider rollout;
• Confirmation that Ontario is not requesting access to confidential federal databases, but structured, role-based visibility to facilitate lawful supervision and risk management under Ontario’s jurisdiction.

Ontario should also assess whether its own internal systems are equipped to receive and act on this information—including whether each region has a designated contact for high-risk federal offender coordination, and whether additional staffing or system adaptations are needed to receive, triage, and act on notifications.

Rationale: High-risk federally supervised individuals routinely return to communities in Ontario. At present, there is no consistent, structured mechanism through which the province’s police, probation, child protection, or victim support systems are alerted—unless the individual reoffends, or the victim independently notifies their support network. This undermines Ontario’s ability to carry out its public safety mandate and support effective risk-informed supervision and safety planning.

This recommendation does not propose system integration or data sharing beyond legal or constitutional boundaries. It proposes that Ontario take formal, documented steps to improve intergovernmental coordination—anchored in existing risk and safety planning structures and responsive to what is already known about the dangers posed by high-risk repeat offenders.

Timely and structured notification is a precondition for effective public safety response. By requesting defined coordination pathways and role-based visibility, Ontario can better protect victims, reduce system blind spots, and uphold its responsibility to ensure that risk is identified and managed—regardless of whether the offender falls under federal or provincial supervision.

4.4.13. Recommendation 13: Convene and Fund a Provincial Exploration of Screening Tools for Youth at Risk of Sex Trafficking

Context and Purpose: Ontario continues to report the highest number of police-reported human trafficking incidents in Canada, with the majority involving the sexual exploitation of girls and young women. Despite this, there is currently no province-wide approach to screening for risk of sex trafficking among youth—either in health care, education, child protection, or community-based victim services. Several structured screening tools have been developed and used in other jurisdictions, including the Commercial Sexual Exploitation–Identification Tool (CSE-IT), Short Screen for Child Sex Trafficking (SSCST), Human Trafficking Interview and Assessment Measure (HTIAM-14), and Quick Youth Indicators for Trafficking (QYIT). These tools have demonstrated moderate predictive value in certain service contexts—such as emergency departments, homeless shelters, and youth outreach programs—but have not been formally evaluated or adapted for use in Ontario.

The Multisector Community Response to Child Sex Trafficking protocol developed by SickKids’ Lotus Health program is the only known initiative in Ontario to explicitly incorporate screening for sex trafficking risk. While the protocol does not prescribe a specific tool, it outlines an approach to identification that includes structured assessments, safety planning, and coordinated response pathways. At present, no similar framework exists at the provincial level, and no comprehensive evaluation has been conducted to determine whether and how structured screening tools might be used more effectively to identify youth at risk of sex trafficking in Ontario.

This recommendation proposes that the Province fund a collaborative expert-led initiative to explore whether the use of screening tools for sex trafficking risk could be safely, ethically, and effectively integrated into Ontario’s existing service systems.

Jurisdiction: The proposed initiative would fall under the joint mandate of the Ministry of Children, Community and Social Services (MCCSS) and the Ministry of Health (MOH), with additional participation from the Ministry of Education and the Ministry of the Solicitor General. Expert involvement from frontline practitioners, researchers, and anti-trafficking service providers would be essential. The initiative could be supported through a targeted grant under the Ontario Anti–Human Trafficking Strategy.

Recommendation Details: That the Province of Ontario create a time-limited grant to support an expert-led exploration of the role that structured screening tools could play in identifying youth at risk of sex trafficking. The initiative should result in clear, evidence-informed options and guidance for future provincial consideration.

Implementation Considerations:

• The grant should support a multi-sectoral working group that includes representatives from health care, child protection, education, policing, anti-trafficking service providers, Indigenous organizations, and academic researchers with expertise in sexual exploitation and youth vulnerability.
• The working group should review available screening instruments, assess their applicability to Ontario’s legal and service environment, and identify gaps in current tools—particularly for adult, gender-diverse, and Indigenous populations.
• Deliverables should include a public summary report and a detailed technical review identifying where, if at all, further development, adaptation, or piloting may be appropriate.
• The initiative should be time-limited and include a defined budget, reporting timeline, and engagement plan.
• The process must account for ethical concerns related to consent, data use, and potential downstream effects of screening, including over-surveillance or unintended child protection or law enforcement involvement.
• This recommendation does not propose mandatory or province-wide screening at this time.

Rationale: Structured screening tools are not diagnostic instruments, but they may help frontline professionals identify youth who are vulnerable to sexual exploitation, particularly in cases where the young person does not self-disclose. Tools such as the SSCST, CSE-IT, and HTIAM-14 have demonstrated usefulness in U.S.-based studies, particularly in health care and shelter settings. However, these tools have not been validated in Canadian populations or adapted to Ontario’s service delivery systems. At present, there is no publicly documented use of these tools in Ontario beyond the SickKids Lotus Health protocol. Given Ontario’s disproportionately high rates of reported sex trafficking, the absence of any structured provincial exploration of these tools represents a clear gap in prevention infrastructure. A grant-funded initiative would allow the Province to assess options in a deliberate and informed manner, while ensuring that any future guidance reflects the needs of Ontario’s diverse communities and service sectors.

Section 5: Civil Legal Remedies for Victims

5.1 Background on Civil Legal Remedies

5.1.1. Introduction: Why Civil Liability Matters for Victims of IPV, SV, and HT

Victims of intimate partner violence (IPV), sexual violence (SV), and human trafficking (HT) often experience forms of harm that do not result in criminal charges, do not meet the threshold for criminal conviction, or are not fully redressed through the criminal system. Criminal law is designed to punish wrongdoers on behalf of the state and requires proof beyond a reasonable doubt. Victims are witnesses, not parties to the proceeding. While some victims may receive restitution under a sentencing order, this requires a conviction and is limited to quantifiable economic loss. It does not cover pain and suffering, reputational harm, or emotional trauma. Punitive damages are not available in criminal court.

Civil law provides a parallel and complementary route. Under Ontario’s common law, victims may bring tort claims to seek compensation, recognition, and injunctive relief for the harms they have suffered. The burden of proof in civil proceedings is lower: plaintiffs must establish their case on a balance of probabilities. Civil claims allow victims to initiate legal action themselves, control the process, and pursue remedies not available through criminal prosecution.

Civil remedies are particularly important in cases involving stalking, harassment, psychological abuse, coercive control, or non-consensual image sharing—forms of violence that may not meet the elements of a criminal offence or where the criminal justice system declines to act. Civil claims can also serve as a means of reputational repair, safety planning (through injunctive relief), and financial redress. However, the availability of tort remedies does not guarantee access. Tort claims require legal counsel, and few victims have the resources to pay for litigation.

Tort damages may be difficult to collect. In personal injury cases, recovery is typically paid by an insurer or institutional defendant. In IPV or SV claims, by contrast, the defendant is usually an individual with limited assets or income. Even where judgment is granted, enforcement may be challenging. The procedural tools available—such as garnishment, writs of seizure, or examination in aid of execution—are governed by the Courts of Justice Act and the Rules of Civil Procedure, but these mechanisms are complex, slow, and frequently ineffective in cases involving defendants without stable income or property.

Despite these limitations, tort law remains a crucial legal tool for victims seeking civil accountability, particularly in cases where the criminal justice system is unavailable, ineffective, or incapable of addressing the full scope of harm.

5.1.2. Civil Causes of Action Currently Available in Ontario

All of the following torts are common law in origin. Ontario has not enacted any statutory torts specific to IPV, SV, stalking, or harassment. While some causes of action—such as breach of confidence or public disclosure of private facts—are more recent developments, they have been recognized through judicial decisions rather than statute. There is no provincial legislation in force that creates a standalone right of action for victims of interpersonal violence.

Each tort below is analyzed for its doctrinal foundation, legal elements, relevance to IPV/SV/HT contexts (including stalking and harassment), and limitations.

5.1.2.1. Assault and Battery

Assault and battery are distinct but related intentional torts. Battery is the intentional application of force to another person without consent. Assault is the intentional creation of a reasonable apprehension of imminent harmful or offensive contact. Both are actionable per se, meaning that the plaintiff does not need to prove damages to establish liability. These torts are longstanding in Ontario common law.

While frequently pleaded in civil claims involving physical IPV, they are limited to discrete episodes of contact and do not capture the cumulative nature of coercive control or psychological abuse.

5.1.2.2. False Imprisonment

False imprisonment arises when a person is intentionally confined within a bounded space without lawful justification. The plaintiff must show a complete restriction on liberty, imposed by force or threat. There is no need to prove physical harm, but the restraint must be total.

The tort is available in the IPV context where victims are physically restrained or prevented from leaving a home or room. However, false imprisonment does not apply to psychological coercion, manipulation, or threats unaccompanied by physical restraint.

5.1.2.3. Intentional Infliction of Mental Suffering (IIMS)

Intentional Infliction of Mental Suffering (IIMS) requires that the defendant engaged in (1) flagrant or outrageous conduct, (2) calculated to produce harm, which (3) resulted in a visible and provable illness. This tort was confirmed by the Ontario Court of Appeal in Boucher v. Wal-Mart Canada Corp., where a jury award was upheld for an employee subjected to workplace bullying and humiliation over an extended period.⁶⁴⁹

Although IIMS is conceptually applicable to psychological abuse in IPV contexts, its use has been limited. Courts have set a high bar for what constitutes “outrageous” conduct, and plaintiffs must typically present medical evidence of a diagnosable psychiatric illness. Emotional distress, fear, or trauma without formal diagnosis may not suffice.

5.1.2.4. Intrusion Upon Seclusion

The Ontario Court of Appeal recognized the tort of intrusion upon seclusion in Jones v. Tsige where the defendant accessed the plaintiff’s private banking records without consent over a period of several years. It applies where a defendant intentionally intrudes upon the plaintiff’s private affairs or concerns, in a manner that would be highly offensive to a reasonable person. There is no requirement to prove economic loss. The Court established a presumptive upper limit of $20,000 in damages.⁶⁵⁰

The tort is most applicable to unauthorized access to personal data, email, or digital files. It may apply in some stalking or surveillance scenarios, particularly where digital snooping is involved. However, it has not yet been widely adopted in such cases. It does not apply to reputational harm or public disclosure of information.

5.1.2.5. Public Disclosure of Private Facts

This novel tort was recognized by the Ontario Superior Court in Jane Doe 72511 v. NM. It applies where a defendant publicizes intimate or personal facts about the plaintiff—such as sexual conduct or health information—and where the disclosure would be highly offensive to a reasonable person and not a matter of legitimate public concern.⁶⁵¹ In Jane Doe, the defendant uploaded a private sex video to a pornography site without the plaintiff’s consent. He had done so as revenge for being convicted of assaulting her. The video had a derogatory and racist title and the plaintiff’s face could be seen in the footage. She was able to get the video taken down but not before it had been viewed over 60,000 times. It was connected to at least ten different websites and downloaded an unknown number of times. The court awarded $50,000 in general damages, $25,000 for aggravated damages and $25,000 for punitive damages. These sums were awarded even though the plaintiff did not present evidence of a psychological diagnosis or of psychological treatment because of the publication. The case is a leading example of tort liability for image-based abuse, particularly non-consensual pornography.

While this tort addresses some forms of reputational harm and psychological injury, it is procedurally complex, requires proof of publication, and has not been broadly expanded beyond sexually explicit materials.

The term “public disclosure” requires dissemination to the public or a sufficiently broad audience to constitute publicity—not just to a small group or single person. “Publication” may be proven through evidence of web uploads, social media dissemination, or distribution to third parties.

The procedural complexity arises from the need to show actual disclosure and harm, in contrast to intrusion upon seclusion which is actionable per se. Plaintiffs must also rebut defences such as public interest or consent.

5.1.2.6. Breach of Confidence

The tort of breach of confidence arises where a party discloses information that was imparted in confidence, in circumstances where there was a reasonable expectation of confidentiality, and where such disclosure causes harm. This doctrine is historically rooted in equity and is recognized as part of Ontario tort law.

The tort is occasionally pleaded in image-based abuse cases, particularly where intimate images or communications were shared in a relationship of trust. However, courts have applied it narrowly, and it often overlaps with other privacy torts. It is not designed to address stalking, coercion, or threats.

5.1.2.7. Defamation

Defamation consists of the publication of a false statement that would lower the plaintiff’s reputation in the eyes of a reasonable person. Truth is a complete defence and fair comment and responsible communication may also apply. The tort includes both libel (written) and slander (spoken). It is actionable without proof of special damage.

Defamation has been used in cases where abusers make false allegations about the victim online or in public forums. It may also apply to retaliatory postings after a relationship ends. However, it is a poor fit for most IPV/SV claims because it requires the statements to be false and published. It does not address true statements made maliciously, private conduct, or coercive patterns of behaviour that fall outside public communication.

5.1.2.8. Harassment in Internet Communications (Caplan v. Atas)

In Caplan v. Atas, 2021 ONSC 670, the Ontario Superior Court recognized a novel common law tort of harassment in internet communications. The defendant had created dozens of pseudonymous accounts and used them to publish defamatory, threatening, and harassing content for many. The postings targeted former litigation opponents, lawyers, family members, and unrelated third parties.⁶⁵²

Justice Corbett held that the existing law of defamation, privacy, and intentional infliction of mental suffering was insufficient to address the breadth, persistence, and malevolence of the abusive conduct.

Although Caplan did not involve IPV or a domestic relationship, the conduct it addressed—obsessive digital stalking, reputational sabotage, and relentless targeting over time—closely parallels certain forms of coercive control and stalking experienced by IPV victims online. The Court’s rationale may therefore have implications for future IPV cases involving digital abuse, even if the doctrinal scope remains narrowly drawn.

The apparent tension between Caplan and the Ontario Court of Appeal’s decision in Merrifield v. Canada (AG)—where the Court rejected a general tort of harassment—is addressed in Section IV.

5.1.3. Unsettled and Emerging Areas in Ontario Tort Law

5.1.3.1. Merrifield v. Canada (Attorney General) – Tort of Harassment Rejected

The leading appellate decision on the tort of harassment in Ontario remains Merrifield v. Canada (Attorney General), 2019 ONCA 205. In this case, the Ontario Court of Appeal overturned the trial court’s recognition of a novel tort of harassment in the employment context. The plaintiff, a long-serving RCMP officer, had alleged a pattern of workplace mistreatment by superiors that he argued constituted harassment in tort.

The Court of Appeal declined to recognize the proposed tort.

The Court emphasized that existing torts—particularly intentional infliction of mental suffering—already addressed much of the same conduct and that there was no clear need to expand the law.

This deferential stance may have had a chilling effect on subsequent attempts to plead a freestanding tort of harassment in Ontario. Merrifield remains binding appellate authority and casts doubt on the long-term doctrinal stability of later decisions such as Caplan v. Atas, which recognized a narrow internet-based harassment tort at the Superior Court level. While Caplan was not addressed in Merrifield, the Court of Appeal’s broader concern about legal coherence, incrementalism, and judicial restraint creates an unresolved doctrinal tension.

Notably, however, the Merrifield decision also signals that judicial restraint does not preclude legislative action. The Court’s repeated references to legislative competence in this area may be interpreted as a tacit invitation to Parliament or the provincial legislatures to act where existing tort law proves insufficient. This framing creates a doctrinal foundation that both justifies and encourages legislative intervention, particularly in addressing persistent stalking, coercive control, and digital harassment that do not clearly fall within current tort categories.

5.1.3.2. Caplan v. Atas – Narrow Tort of Harassment in Internet Communications

In Caplan v. Atas, 2021 ONSC 670, the Ontario Superior Court recognized a new, narrowly framed tort of harassment in the context of sustained and obsessive internet abuse. The defendant, Atas, had engaged in what the court described as a 15-year campaign of “malicious falsehoods” against more than 150 individuals. She posted hundreds of anonymous or pseudonymous defamatory statements online—targeting former legal opponents, their lawyers, family members, and unrelated third parties—across a wide array of blogs, forums, and comment sections.

The court found that existing torts, including defamation, intrusion upon seclusion, and intentional infliction of mental suffering, were inadequate to address the full scope and persistence of the conduct.

Justice Corbett emphasized that the tort should be available only in “the most serious and persistent of harassment conduct”.⁶⁵³

While Caplan was groundbreaking in recognizing a common law tort of harassment, it raises significant doctrinal tension with Merrifield. The Court of Appeal in Merrifield had explicitly rejected the creation of a general tort of harassment, noting that such innovation was best left to the legislature. Because Caplan is a trial-level decision, it does not override or modify Merrifield’s binding authority. It exists in tension with appellate precedent and risks being overturned or limited in future appellate decisions.

Lower courts have been cautious in applying Caplan. Some have cited it cautiously in the context of online abuse, but it has not yet been endorsed by the Ontario Court of Appeal. In Alberta Health Services v. Johnston, 2023 ABKB 209, the Alberta Court of King’s Bench expressly declined to follow Caplan, citing concerns about doctrinal overreach and inconsistency with Merrifield.⁶⁵⁴

Nevertheless, Caplan has prompted renewed academic and legislative interest in codifying a statutory tort of harassment, particularly as it applies to technologically facilitated abuse. The trial decision provides a detailed evidentiary record and doctrinal rationale that could guide legislative reform. The court’s clear statement that its ruling applied only to the internet context may also serve as a blueprint for legislative tailoring.

Whether Caplan ultimately invites codification will depend on how Ontario’s appellate courts respond to future pleadings and whether the legislature chooses to formalize and expand the tort to cover other non-digital forms of stalking, coercive control, and persistent harassment.

5.1.3.3. Ahluwalia v. Ahluwalia – Tort of Family Violence

In Ahluwalia v. Ahluwalia, 2022 ONSC 1303, the Ontario Superior Court recognized a novel tort of family violence based on a pattern of coercive and controlling conduct. The plaintiff, a physician, brought a civil claim against her former husband alleging a decade-long pattern of physical, emotional, verbal, financial, and psychological abuse. She described incidents of physical assault, forced isolation, financial manipulation, and threats to her professional standing. Justice Mandhane concluded that the cumulative nature of the abuse constituted behaviour that existing torts failed to adequately capture.

The trial decision awarded the plaintiff $150,000 in general, aggravated, and punitive damages.

Justice Mandhane emphasized that family violence, as understood in both social science and statutory family law frameworks, includes forms of abuse that are not episodic or physical but cumulative and relational. She drew from the Divorce Act’s post-2021 definition of “family violence” as part of the contextual basis for this civil cause of action.

The Ontario Court of Appeal overturned the decision in Ahluwalia v. Ahluwalia, 2023 ONCA 476, finding that the trial judge erred in recognizing a novel tort. Justice Benotto, writing for the Court, held that the harms described could be adequately addressed through existing torts and that expanding the law in this domain should be left to the legislature. The Court did not dismiss the seriousness of the conduct but expressed caution around judicial innovation.

The Court suggested that intentional infliction of mental suffering, assault, battery, and potentially breach of fiduciary duty would be available in such cases, depending on the facts.

The plaintiff sought and was granted leave to appeal to the Supreme Court of Canada. Intervenors in the Supreme Court appeal included the Women’s Legal Education and Action Fund (LEAF); Luke’s Place Support and Resource Centre for Women and Children; National Association of Women and the Law; Canadian Centre for Men and Families; The Barbra Schlifer Commemorative Clinic; the Canadian Bar Association; the Attorney General of Ontario; the Attorney General of British Columbia; and the Attorney General of Canada.⁶⁵⁵ As of May 2025, the appeal has been argued but judgment is under reserve.

The Supreme Court’s forthcoming decision will have significant implications. If the novel tort is upheld, it would represent a landmark recognition of coercive control as a freestanding civil wrong in Canadian law. If the appeal is dismissed, the authority of Ontario’s existing torts will be reaffirmed, and legislative action may become the only viable path forward.

Politically, Ahluwalia is highly significant. The trial court’s reasoning aligns with growing public and policy concern about coercive control in intimate relationships, and many antiviolence advocates have pointed to the case as evidence that the civil system must evolve to meet the lived realities of victims. Whether through judicial development or legislative reform, the case has laid the groundwork for future change. This report does not take a position on the underlying legal merits of the trial or appellate decisions, as it will await further insight from the forthcoming Supreme Court of Canada ruling, which had not yet been released at the time of writing.

5.1.4. Toward a Legislative Response: Conceptualizing a Statutory Tort of Harassment

A statutory tort of harassment could be scoped to avoid duplicating remedies already available under other legal regimes. Harassment in the workplace is addressed through a combination of tort law (e.g., IIMS), employment law (e.g., constructive dismissal), and statutory protections under the Occupational Health and Safety Act. Likewise, harassment in housing and human rights contexts may be actionable through the Residential Tenancies Act or the Human Rights Code.

A new tort could focus on conduct occurring outside of these domains—particularly repeated, targeted, non-consensual interference with a person’s dignity, safety, or autonomy in personal, social, or public life. The cause of action could apply where no employer-employee, landlord-tenant, or institutional relationship exists, and where harm is not otherwise compensable.

Definitional thresholds could include:

• A “pattern of conduct” that is intentional or reckless;
• Conduct “without lawful justification” or “not otherwise protected by law” (e.g., fair comment);
• A resulting harm in the form of psychological distress, reputational injury, or material hardship.

Procedural features could be included to enhance access to justice. These might include:

• A presumption of harm upon proof of conduct, subject to rebuttal;
• Authority for the court to issue interim injunctive relief before trial;
• Damages without proof of economic loss, and express recognition of aggravated or punitive damages where appropriate.

These models treat harassment not as a collection of marginal legal problems, but as a cumulative, relational wrong deserving of coherent civil response.

5.1.5. Barriers to Civil Enforcement

Civil remedies are often inaccessible to individuals without financial means. Contingency fee arrangements, while technically possible, are rare in the context of harassment, IPV, and non-tort-based stalking claims. Unlike personal injury litigation—where claims are typically paid by insurers—these cases often involve individual defendants who lack assets or stable income. Where a defendant is judgment-proof, the claim may have symbolic rather than practical value.

Even where judgment is obtained, enforcement can be procedurally and practically difficult. Tools such as garnishment, writs of seizure and sale, or examination in aid of execution are available under the Rules of Civil Procedure and Courts of Justice Act but require persistence and legal knowledge. In Ontario, judgments must be enforced within a 10-year window unless renewed through a formal court application. Judgment renewal under section 16(1)(b) of the Limitations Act, 2002 permits plaintiffs to extend enforceability if initiated before the expiry of that period.⁶⁵⁶

These limitations mean that civil justice in this space is, in practice, most accessible to those who have financial resources or the support of institutional counsel. There is no publicly funded legal representation for tort matters. Many victims are unable to pursue claims because they cannot afford legal fees or risk adverse costs.

The psychological burden of civil litigation must also be considered. For victims of interpersonal violence or prolonged harassment, the adversarial nature of proceedings—especially when facing a self-represented abuser—can be traumatizing. Discovery processes may compel disclosure of private communications, health records, or other sensitive information.

None of these barriers undermine the importance of civil accountability. But they contextualize the practical limitations of tort as a widespread remedy. Civil claims may still serve a deterrent function, particularly in cases that receive public or media attention. Publicly reported judgments—especially those involving punitive damages—can signal legal recognition of emerging harms, such as stalking, coercive control, or non-consensual image distribution.

Increased awareness of these causes of action may itself be beneficial. Many Ontarians are unaware that civil recourse exists in cases of reputational attack, synthetic image abuse, or targeted emotional harm. Educational outreach—particularly in the context of school-based programming or online safety initiatives—may help ensure that victims and their families are aware of their legal options, even if they choose not to pursue them.

5.1.6. Non-Tort Civil Remedies for Image-Based Abuse

Victims of non-consensual image distribution and synthetic sexual imagery may also benefit from non-tort civil remedies and administrative takedown systems. The Canadian Centre for Child Protection (C3P) operates two nationally recognized tools: Cybertip.ca⁶⁵⁷ and Project Arachnid.⁶⁵⁸

Cybertip.ca is Canada’s national tipline for online child sexual exploitation. Project Arachnid is a global web-crawling and automated detection system that scans for known or hash-matched illegal images and sends removal notices to internet platforms. These systems increasingly respond to synthetic and non-consensual content involving youth, including AI-generated imagery.

These tools operate independently of courts or police. They are free, anonymous, and globally effective, particularly for reducing distribution and visibility. They do not, however, provide compensation, enforceable orders, or legal recognition of harm.

In the United States, the proposed TAKE IT DOWN Act (S.146, 2025) received bipartisan support when tabled in the U.S. Senate in March 2025. The Act would create a federally administered takedown system for intimate digital forgeries.⁶⁵⁹

Unlike the United States, Canada does not currently have any central regulatory authority empowered to mandate content removal. No federal legislation—whether the Telecommunications Act, RSC 1985, c T-3; Competition Act, RSC 1985, c C-34; or the pending Online Harms Act (Bill C-63)—explicitly authorizes platform takedown orders for AI-generated sexual content.⁶⁶⁰

Ontario cannot legislate in this domain, as platform regulation falls under federal jurisdiction. However, it could call on the federal government to explore similar options—either through standalone legislation or amendments to Bill C-63. A federally mandated takedown regime could mirror the FTC’s approach under the TAKE IT DOWN Act, offering civil penalties, compliance timelines, and enforceable victim protections.

Ontario’s role would be to advocate for such a system and to ensure alignment with provincial service providers. The integration of federal tools with existing referral mechanisms—such as Cybertip.ca and Project Arachnid—could increase system efficiency and improve outcomes for victims.

5.1.8.1. Statutory Tort Models for Image-Based Abuse: British Columbia and Manitoba

Ontario has not enacted any statutory tort for the non-consensual creation, possession, or distribution of intimate images. By contrast, other Canadian provinces—British Columbia and Manitoba as two examples—have implemented legislation specifically designed to fill this gap. These statutes establish streamlined civil causes of action for image-based abuse that lower evidentiary burdens, authorize injunctive relief, and recognize harm without requiring criminal conviction or proof of financial loss.

1. British Columbia: Intimate Images Protection Act, SBC 2023, c 14 – British Columbia’s Intimate Images Protection Act received Royal Assent on March 30, 2023 and was proclaimed into force by regulation on January 29, 2024, with the exception of s 3(2)(a), which remains unproclaimed as of May 2025. The Act creates a statutory cause of action for the unauthorized creation, distribution, or threatened distribution of an intimate image. The Act provides remedies for non-consensual distribution of intimate images including takedown orders, de-indexing and awards for general, aggravated, and punitive damages.⁶⁶¹

   This Act captures two novel and expansive scenarios: (1) digital alteration of an original image, and (2) entirely synthetic or AI-generated content that simulates an individual’s likeness in a sexual context. Although the statute does not use the word “deepfake,” the legislative language anticipate and include fabricated images of a sexual nature that are designed to appear real, whether or not based on an actual person’s image.

   The Act also permits victims to seek relief through either the Supreme Court of British Columbia or the Civil Resolution Tribunal (CRT). As of May 2025, no case law has interpreted these provisions, but several claims have reportedly been filed before the CRT.

   The Act does not cap damages and applies even where the defendant’s conduct does not rise to the level of a criminal offence.

2. Manitoba: The Non-Consensual Distribution of Intimate Images Act, CCSM c N93

   Manitoba’s Intimate Image Protection Act (now The Non-Consensual Distribution of Intimate Images Act, CCSM c N93) was passed in 2015 and came into force on January 1, 2016. It provides a statutory cause of action for non-consensual distribution of intimate images, along with supporting protective orders and remedies, and has been updated to include references to fake images created through AI.

   To date, reported case law under the Act is limited. The statute has not imposed any ceiling on recoverable damages, though amounts awarded to date appear consistent with the general range of $50,000–$100,000 in analogous common law cases.

5.1.8.2. Comparative Considerations

Both British Columbia and Manitoba framed their statutory torts as necessary legislative interventions. In both provinces, the legislatures explicitly acknowledged that existing tort law was inadequate to meet the realities of image-based abuse. Their statutes remove the need to rely on difficult-to-plead common law doctrines like breach of confidence, intentional infliction of mental suffering (IIMS), or public disclosure of private facts.

Ontario, by contrast, has not enacted a comparable statute. Victims in Ontario must navigate common law torts that are procedurally burdensome, uncertain in scope, and not specifically designed for image-based abuse. The evidentiary thresholds are high, defences such as consent or public interest are difficult to rebut without legal support, and very few victims are able to access legal representation. This context is central to understanding the policy rationale behind statutory reform.

5.1.7. Barriers to Civil Enforcement and Access to Justice

Civil liability may offer victims of IPV, sexual violence, and harassment a path to financial compensation and recognition, but access to this form of justice is frequently shaped by practical and financial barriers. For most victims, pursuing a tort claim means hiring private legal counsel and absorbing significant cost risk. Legal Aid Ontario does not fund tort litigation, and while contingency fee arrangements are possible in principle, they are far less common in this context than in personal injury law.

The primary reason is structural: personal injury claims are typically backed by insurance coverage, meaning that if the claim succeeds, the defendant (or their insurer) can pay. In IPV and harassment cases, defendants are usually individuals who may be unemployed, underemployed, or judgment-proof. Even where a judge finds liability and awards damages, those damages may not be collectible. There is no public insurance or guaranteed pool from which judgments are paid.

Where a civil judgment is granted, enforcement becomes a second challenge. Ontario’s Rules of Civil Procedure provide tools for enforcement—such as garnishment, writs of seizure and sale, or examination in aid of execution—but these require the plaintiff to locate the defendant’s assets, obtain and renew court orders, and navigate procedures that may require legal expertise. Under the Limitations Act, 2002, judgments expire after ten years unless actively renewed through a motion (s 16(1)(b)). This means plaintiffs must monitor and re-engage the legal system to preserve enforceability over time.

There are also significant emotional and psychological costs. Civil litigation requires plaintiffs to participate in examinations for discovery, answer undertakings, disclose records, and potentially testify in open court. For many victims—particularly of stalking, coercive control, or image-based abuse—this can be retraumatizing, especially if the defendant is self-represented and permitted to question them directly.

None of these realities negate the importance of civil remedies. But they do contextualize the limits of civil liability as a tool for broad or systemic redress. In many cases, the symbolic or deterrent value of a public ruling may be more meaningful than the financial outcome. Media coverage of civil cases—particularly those resulting in punitive damages—can raise public awareness and help signal that certain forms of conduct carry consequences.

Awareness itself is part of access. Many victims do not know that tort remedies are available for psychological harm, stalking, reputational injury, or image-based abuse. Public legal education, especially in partnership with schools, clinics, and frontline service providers, may help ensure that individuals who are harmed know that civil recourse exists—even if they ultimately choose not to pursue it.

5.2 Protection Orders and Legal System Fragmentation

5.2.1. Function and Structure of Protection Orders in Ontario

Protection orders are a category of legal intervention designed to prevent future violence by imposing behavioural restrictions on a person who poses a risk to another. Commonly used in the context of intimate partner violence (IPV) and family violence, these orders are typically preventive in nature, founded on the existence of a reasonable fear of harm, and are not contingent upon the laying or outcome of criminal charges.⁶⁶²

In Ontario, protection orders are issued across several legal domains, each with distinct statutory authorities, evidentiary standards, enforcement mechanisms, and application procedures:

• Family Law Act (FLA), RSO 1990, c F.3⁶⁶³:
  • s. 46: Restraining orders for spouses and former cohabitants.
  • s. 24: Orders for exclusive possession of the matrimonial home.
• Children’s Law Reform Act (CLRA), RSO 1990, c C.12⁶⁶⁴:
  • s. 35: Restraining orders involving parental responsibility and child safety.
  • s. 28: Parenting and contact orders.
• Child, Youth and Family Services Act (CYFSA), SO 2017, c 14, Sch 1⁶⁶⁵:
  • s. 102(3): Restraining orders deemed to be issued under CLRA s. 35.
  • s. 137: Restraining orders involving child protection proceedings.
• Criminal Code, RSC 1985, c C-46⁶⁶⁶:
  • s. 810: Peace bonds (criminal no-contact orders).
  • ss. 515–519: Bail release conditions (recognizance, undertakings).
  • s. 732.1: Probation conditions.
  • s. 742.1: Conditional sentences with supervision terms.
  • s. 742.3: Conditions that may be attached to conditional sentences.
• Common Law:
  • Common law peace bonds granted by justices of the peace in the absence of statutory authority.⁶⁶⁷
• Indigenous Law and Federal Aboriginal Law⁶⁶⁸:
  • Community-specific protection orders under the Family Homes on Reserves and Matrimonial Interests or Rights Act, SC 2008, c 20, ss. 16, 20 as well as band-enacted laws.

Ontario does not currently have standalone civil protection order legislation akin to that found in most other Canadian jurisdictions. As a result, victims of IPV and family violence must navigate a fragmented legal landscape that offers no unified statutory framework, no emergency order infrastructure, and highly variable access and enforcement practices.

5.2.2. Evidentiary Fragmentation and Enforcement Gaps

Although Ontario’s protection order provisions span multiple statutes and domains, they operate as disconnected tools rather than as elements of a cohesive system. The absence of coordination across legal frameworks—family, child protection, criminal, and Indigenous law—creates systemic confusion, enforcement inconsistency, and heightened risk for victims.

Police services report difficulty enforcing civil restraining orders, especially those issued under the FLA or CLRA, due to the limited visibility of these orders in police databases and the ambiguity surrounding enforcement mechanisms. While peace bonds under s. 810 of the Criminal Code and bail conditions under s. 515 are routinely entered into the Canadian Police Information Centre (CPIC), restraining orders issued through family or child protection courts are often absent or inconsistently recorded.

In practice, this means police may hesitate to act—even when a valid court order is in effect—because they cannot confirm the existence or conditions of the order in real time. Section 127 of the Criminal Code (disobeying a lawful order of court) is the nominal enforcement mechanism for civil breaches, but it is rarely invoked due to evidentiary hurdles, including the need to prove notice, wilfulness, and jurisdictional validity.

Moreover, protection orders often coexist without coordination. Victims may simultaneously be subject to a family court restraining order, a peace bond, and a set of bail conditions—all with different terms, expiry dates, and enforcement pathways. There is no provincial database to aggregate these orders, and no standardized format for issuing, sharing, or updating them. The Law Commission of Ontario has recommended the creation of a confidential, province-wide protection order database accessible to police, courts, and authorized service providers.⁶⁶⁹

The fragmentation has life-and-death consequences. One risk factor recognized by Ontario’s Domestic Violence Death Review Committee is an offenders’ failure to comply with authority, which includes breaches of court orders.⁶⁷⁰ A widely cited example is the 2015 triple homicide examined in the CKW Inquest, where the perpetrator—despite repeated breaches of probation—remained unsanctioned until after the final fatal act.⁶⁷¹

Victims of IPV and family violence often report that protection orders feel meaningless. The result is a legal architecture that offers theoretical protection but fails to ensure safety in practice.

5.2.3. Access Barriers and Procedural Delay

The inaccessibility of protection orders in Ontario is one of the most widely cited shortcomings in the current legal framework. The absence of emergency application procedures, limited eligibility criteria, and a lack of consistent procedural triage have rendered timely protection functionally out of reach for many victims of violence.

Restraining orders under the Family Law Act are limited to individuals who are, or were, spouses or cohabitants.⁶⁷² This definition excludes individuals in dating relationships, long-distance relationships, or relationships that involve neither cohabitation nor shared children. Similarly, exclusive possession orders for the matrimonial home are only available to legally married spouses, not common-law partners.⁶⁷³ These constraints are out of step with the forms of violence increasingly documented in modern relationship contexts and have been criticized as structurally exclusionary.

Even when statutory authority exists, procedural access is often delayed. Applications for restraining orders under the FLA, CLRA, or CYFSA must typically be filed in person, during court hours, and are processed according to the broader docket of family or child protection proceedings. Ontario does not currently provide a statutory mechanism for emergency access to protection orders outside regular court hours. By contrast, jurisdictions such as Alberta permit designated representatives (e.g. police officers, victim services workers) to seek temporary protection orders by phone or fax 24/7.⁶⁷⁴

The Law Commission of Ontario has emphasized the dangers of these delays, particularly in the context of separation—known to be one of the most dangerous periods for women in abusive relationships. Although courts can in theory grant ex parte relief, such motions are subject to judicial discretion and procedural backlog and are inconsistently available across regions.

Procedural burdens also extend beyond initial access. Service of documents, the need for affidavit evidence, and cost-related obstacles such as legal fees or process server costs present serious barriers for low-income litigants. While Legal Aid Ontario offers some coverage, its availability is subject to income testing and discretionary eligibility assessments.

These access limitations disproportionately affect the same populations already at elevated risk for intimate partner and family violence: women with disabilities, racialized and newcomer women, Indigenous women, low-income households, and rural residents. Where legal protection is delayed or denied, victims are left without recourse at critical points of risk escalation.

5.2.4. Eligibility Criteria and Legislative Design Gaps

Ontario’s statutory framework for protection orders lacks clear, inclusive, and contemporary definitions of both qualifying relationships and qualifying harms. These legislative design gaps not only exclude many victims from access but also fail to capture the full range of coercive behaviours used in intimate partner and family violence. As noted, the Family Law Act limits access to restraining orders to individuals who are currently or formerly in a spousal relationship or who have cohabited. This excludes many victims in dating relationships, particularly those who have never lived with the respondent. Such exclusions are increasingly out of step with other jurisdictions.

The Children’s Law Reform Act similarly fails to articulate a broad conception of eligible applicants, although some interpretive flexibility is available through judicial discretion and the cross-application of CYFSA provisions.⁶⁷⁵ The lack of consistency across statutes creates confusion and risk of exclusion for victims whose relationships fall outside traditional paradigms.

As another example, Ontario’s protection order statutes do not include provisions for safeguarding companion animals, despite extensive evidence that threats or harm to animals are frequently used as coercive tactics in IPV contexts. By contrast, as of 2024, at least 41 U.S. states authorize courts to include pets in civil protection orders.⁶⁷⁶

The LCO has stated that protection orders may be strengthened through inclusion of animal-related protective authority. This is important given the clear evidence that threats and harm to pets are used to control, intimidate, and punish human victims. Legislative silence on this issue leaves courts without explicit authority to grant possession, protection, or contact restrictions relating to animals, even when safety risks are evident.

Without legislative direction, decision-makers may be reluctant to interpret protection order powers expansively. This has led to inconsistent jurisprudence and underutilization of catch-all clauses intended to permit context-specific relief. The Law Commission has noted that stronger protection orders could include tailored conditions addressing pets, technology, financial control, and other coercive mechanisms.⁶⁷⁷

5.2.5. Tailored Conditions and Underutilized Judicial Authority

Ontario’s legislative framework grants courts broad discretion to impose tailored conditions within protection orders. Despite this permissive authority, protection orders issued under the Family Law Act, the Children’s Law Reform Act, and the Child, Youth and Family Services Act often lack individualized terms that address the specific risk dynamics and safety needs of the protected person.

Section 46(3) of the FLA allows the court to include “any other provision that the court considers appropriate” in addition to no-contact and no-go conditions.⁶⁷⁸ Parallel catch-all clauses exist in s. 35(2) of the CLRA and s. 137 of the CYFSA.⁶⁷⁹ These provisions provide clear legal authority to include creative or context-sensitive conditions addressing technology misuse, financial coercion, threats to animals, and broader control tactics.⁶⁸⁰

However, court practice has not kept pace with the statutory potential.

Conditions to prevent tech-facilitated abuse—such as restrictions on email, social media, or digital surveillance tools—are also inconsistently applied, despite their growing prevalence in IPV and family violence cases. Where imposed, they often lack specificity, rendering them difficult to enforce. Similarly, threats or harm to animals—commonly used to instill fear or enforce compliance—are not routinely addressed in restraining orders.

The same underutilization exists in criminal justice contexts. Although bail and probation orders may include animal-related conditions or prohibitions on technology use, they are rarely sought unless explicitly linked to a criminal offence. There is no standard judicial training on how coercive control can manifest through these means, nor is there guidance on how to structure conditions to reduce the risk of escalation.

Advocates have called for the creation of a statutory list of illustrative conditions—modelled on provisions in British Columbia’s Family Law Act and New Brunswick’s IPV legislation—that would encourage courts to consider a wider range of protective terms.⁶⁸¹ Such reforms would clarify the court’s authority, reduce regional inconsistency, and better align protection orders with contemporary patterns of abuse.

In addition to legislative amendment, the LCO recommends that courts receive updated training and practice directives to support the crafting of conditions that reflect the lived realities of victims.⁶⁸² These should include structured examples, model language, and context-driven decision tools to help judges apply existing statutory authority with greater consistency and responsiveness.

5.2.6. Breach, Non-Compliance, and the Case for Centralized Enforcement Infrastructure

Ontario’s protection order framework suffers not only from fragmentation in access and judicial discretion, but also from inconsistent monitoring and enforcement. Breaches of protection orders are frequent, underreported, and inconsistently prosecuted. This erodes public confidence and undermines the preventive logic that justifies the use of protection orders in the first place.

Civil restraining orders issued under the FLA or CLRA are enforced, if at all, through section 127 of the Criminal Code (disobeying a lawful order of court). This provision requires proof of valid service, knowledge of the order, and wilful breach. Police and Crown attorneys report a low rate of section 127 charges, owing to the procedural hurdles and unfamiliarity with the enforcement pathway. When used, the offence is rarely treated as serious, even in the context of repeated or escalating violations.

Criminal justice orders—including peace bonds, bail conditions, and probation terms—offer somewhat more direct enforcement mechanisms, including arrest upon breach under section 811 (peace bonds) and section 145 and 733.1 (failure to comply with bail or probation).⁶⁸³ Yet even in these contexts, enforcement is uneven. Victims often report difficulty having breaches taken seriously, especially when harm has not yet occurred. This is exacerbated by poor inter-agency information sharing and a lack of visibility across protection order types.

Ontario currently lacks a centralized registry or database that aggregates all active protection orders across systems. Orders issued in family court may not be visible to police. Peace bonds may be stored locally or entered into CPIC without detail. Noncriminal protection orders from other provinces are unlikely to be visible or communicated at all. Bail and probation terms may be logged through different platforms, accessible only within specific jurisdictions. The result is that front-line officers, probation supervisors, and even court officials may be unaware of active protective conditions.

The LCO has recommended the creation of a confidential, real-time, province-wide protection order database.⁶⁸⁴ This platform would allow authorized stakeholders—including police, courts, and victim services—to access, confirm, and act on protection orders regardless of origin. The proposed system would mirror best practices in British Columbia, where the Protection Order Registry is electronically linked and accessible to police across the province.⁶⁸⁵ BC’s system ensures that every recognized protection order is entered automatically by court staff and tracked for enforcement purposes.

In the interim, enforcement remains inconsistent and dependent on local memory, paper-based files, or victim-initiated reporting. A unified data infrastructure would reduce delays, improve compliance, and shift the burden of enforcement from victims to institutions better equipped to manage it.

5.2.7. Bill 10 and Incremental Legislative Movement

In May 2025, the Government of Ontario introduced Bill 10, the Protect Ontario Through Safer Streets and Stronger Communities Act, 2025, which included targeted amendments to both the Family Law Act and the Children’s Law Reform Act regarding restraining orders.⁶⁸⁶ These amendments were framed as part of a broader legislative package focused on public safety, but do not mark a significant change in the province’s protection order architecture.

Specifically, Bill 10 amends s. 46(1) of the Family Law Act and s. 35(1) of the Children’s Law Reform Act to expand the pool of eligible applicants for restraining orders. Under the revised provisions:

• The person in need of protection (as before) may apply directly;
• A designated representative—as defined by regulation—may apply on behalf of and with the consent of the person in need of protection; and
• Any person may apply with leave of the court, subject to regulatory conditions.⁶⁸⁷

These changes mirror longstanding recommendations from stakeholders and other jurisdictions regarding the need to authorize third-party applications in appropriate cases.

However, Bill 10 does not address other key limitations identified throughout this report:

• It does not alter or broaden the definition of eligible relationships (e.g., to include non-cohabiting dating partners);
• It does not define or expand the concept of family violence to include coercive control, tech-facilitated abuse, or threats to animals;
• It does not introduce any mechanism for emergency access to protection orders outside regular court hours;
• It does not include any data integration, enforcement modernization, or centralized registry provisions.

As such, the legislative amendments made under Bill 10 may be viewed as incremental improvements to procedural access, but not structural reform. They expand the procedural gateway for initiating restraining order applications, but do not modify the conditions, content, or enforcement architecture of protection orders in Ontario. Implementation of the new provisions will depend on forthcoming regulations to define who may qualify as a designated representative and under what conditions courts may grant leave to other third-party applicants. At the time of writing, these regulations had not yet been published.

5.3 Clare’s Law (Interpersonal Violence Disclosure Protocols)

5.3.1. Origin and Conceptual Basis

The concept known as “Clare’s Law”—formally the Domestic Violence Disclosure Scheme (DVDS)—originated in the United Kingdom following the 2009 murder of Clare Wood by a former partner with a known history of violence. Public outcry after the incident centered on the fact that Ms. Wood had no way of accessing information about her partner’s previous convictions for abuse. The UK Home Office introduced the DVDS as a pilot in 2012 and implemented it nationally in 2014. The policy authorized police to disclose information about a person’s history of violence to a partner who may be at risk. It provided two pathways for disclosure: the “Right to Ask,” initiated by the person at risk, and the “Right to Know,” initiated by police based on operational concerns.⁶⁸⁸ The DVDS aimed to support early decision-making by providing information that might not otherwise be accessible to the public. While its adoption was intended to improve victim safety, the program was also designed to complement existing legal mechanisms rather than replace them.

Since its introduction in the UK, the DVDS model has influenced similar legislative efforts internationally, with a small number of Canadian jurisdictions enacting comparable laws under the name Clare’s Law or Interpersonal Violence Disclosure Protocols.

5.3.2. Legislative Implementation in Canada

5.3.2.1. Saskatchewan

Saskatchewan was the first Canadian jurisdiction to implement Clare’s Law, passing The Interpersonal Violence Disclosure Protocol (Clare’s Law) Act, SS 2019, c I-10.4. The law came into force on June 29, 2020.⁶⁸⁹

The legislation authorizes the two access pathways: the Right to Ask and the Right to Know. The Right to Ask permits individuals to apply for information about a current or former intimate partner’s history of interpersonal violence. The Right to Know enables police to proactively initiate a disclosure if they receive information suggesting that an individual may be at risk, even in the absence of an application.

Both the Royal Canadian Mounted Police (RCMP) and municipal police services participate in the implementation of Clare’s Law in Saskatchewan, depending on local jurisdiction. Following either route, police conduct a structured risk assessment, reviewing relevant databases including CPIC, local police records, and interjurisdictional checks. The file is then forwarded to a multi-sector review committee composed of up to ten representatives from law enforcement, victim services, and domestic violence agencies.⁶⁹⁰ The committee categorizes the risk as “low,” “medium,” or “high” and makes a non-binding recommendation on whether disclosure should occur.

Disclosures, where approved, are delivered verbally to the person at risk in a private setting. No written materials or copies of records are provided. The content of the disclosure includes the assessed level of risk and may include general contextual information, but not specific case details or identifiers. The subject of the disclosure is not notified, and all participants in the process—including the review committee—are bound by confidentiality agreements.⁶⁹¹

Saskatchewan’s implementation is supported by a publicly accessible application process, typically initiated through police stations or referral agencies. However, critics have noted the absence of published data on applications, disclosure rates, victim outcomes, or system costs. No formal evaluation has been released as of 2024. Concerns have also been raised about whether the process meaningfully alters safety planning, and what recourse is available to individuals who receive a disclosure but lack the structural resources to leave the relationship.

5.3.2.2. Alberta

Alberta enacted its own version of Clare’s Law under the Disclosure to Protect Against Domestic Violence Act, SA 2019, c D-13.5. The Act received Royal Assent in 2019 and came into force on April 1, 2021.⁶⁹²

Like Saskatchewan’s law, Alberta’s version provides the same two disclosure pathways: the Right to Ask and the Right to Know. Police services assess risk using internal procedures and databases, and disclosure decisions are reviewed by designated officers within the RCMP. Unlike Saskatchewan, Alberta does not require a multi-sector review committee as part of the decision-making process.⁶⁹³

Disclosures, where authorized, follow a similar process to that in Saskatchewan. The information is delivered verbally to the person at risk. The information is not provided in written form, and the person subject to the disclosure is not notified. Information disclosed is limited to what is necessary to inform the recipient of risk, and may include relevant criminal convictions, court orders, or documented incidents of violence.

Applications may be made online or in person at participating police stations. Alberta RCMP reported that applications are processed by designated officers within 30 days, although timeframes may vary depending on complexity and operational load.

As of 2024, Alberta has not released a public evaluation or annual report on Clare’s Law implementation. Key outcome measures—including the number of applications submitted, disclosures made, and impact on victim decision-making—remain unavailable. Concerns similar to those raised in Saskatchewan have emerged, including unclear benefits for recipients, potential misuse of the disclosed information, and absence of structured follow-up for those who receive a disclosure but remain in a high-risk situation.

5.3.2.3. Newfoundland and Labrador

Newfoundland and Labrador passed its version of Clare’s Law—the Interpersonal Violence Disclosure Protocol Act, SNL 2019, c I-18.1—in 2019. The law was not proclaimed in force until November 1, 2023, due to a multi-year process of protocol development and stakeholder consultation.

The Act authorizes two disclosure routes: the Right to Ask and the Right to Know. The Right to Ask allows individuals to apply for information about a current or former intimate partner. Applications can be submitted online or directly to police and may also be made by a designated support person, such as a lawyer, social worker, or Indigenous representative.⁶⁹⁴ The Right to Know enables police to initiate disclosure where operational information suggests a person may be at risk.

The Newfoundland and Labrador model incorporates a four-tiered risk framework: Insufficient Information, Low Risk, Medium Risk, and High Risk. Risk assessments are conducted by police using national and local databases, including CPIC, PROS (RCMP), and ICAN (RNC), as well as information from other jurisdictions.⁶⁹⁵ Based on the assessment, police may provide verbal disclosure to the person at risk. Information disclosed includes the assigned risk level and, in some cases, conviction details. No written information is provided, and the subject of the disclosure is not notified.⁶⁹⁶

Disclosure meetings typically occur in person, though alternative arrangements (e.g., telephone or video conference) may be made for safety reasons. The person at risk may be accompanied by a support person. All parties involved in the process must sign confidentiality agreements.

A low risk rating or “insufficient information” does not guarantee safety and should not be interpreted as an all-clear. Police retain discretion to offer safety planning and connect individuals to support services regardless of the assigned risk level. The protocol document also affirms that it does not override or interfere with existing police duties to investigate offences or respond to child protection concerns.⁶⁹⁷

As of early 2024, Newfoundland and Labrador has not released implementation data. Media coverage during launch noted high public interest and concern about whether police resources and community supports would be sufficient to respond to increased demand.

5.3.2.4. Ontario

Ontario has not implemented Clare’s Law but has seen recurring political and policy-level interest in exploring its adoption. In 2021, NDP MPP Jennie Stevens introduced Bill 274, the Intimate Partner Violence Disclosure Act, which proposed to establish a provincial disclosure framework similar to those in Saskatchewan and Alberta. The bill did not advance past second reading.⁶⁹⁸

In 2023, PC MPP Christine Hogarth tabled a motion requesting that the government study whether a disclosure mechanism like Clare’s Law would be beneficial in Ontario. The motion passed, but no legislative proposal followed.⁶⁹⁹

Ontario’s Office of the Chief Coroner has previously endorsed the concept of proactive risk disclosure in domestic violence cases. The 2022 Renfrew County Inquest included a recommendation that Ontario adopt a disclosure mechanism enabling individuals to access information about a partner’s history of violence.⁷⁰⁰ This recommendation has been cited in political and advocacy discourse but has not translated into operational design or costed implementation.

As of 2024, Ontario does not provide a Right to Ask or Right to Know mechanism, and there is no provincial protocol or guidance on police-initiated disclosures of interpersonal violence history outside of formal judicial processes. There is also no public commitment to pilot or cost such a program, and no evaluation framework has been proposed.

5.3.3. Intended Benefits and Documented Limitations

Clare’s Law frameworks are typically justified by reference to a small set of core principles: empowerment of victims, prevention of future violence, and facilitation of informed decision-making. These aims have been widely adopted in government communications, political speeches, and public-facing materials. However, empirical research offers a more mixed portrait of what disclosures actually achieve in practice. Victim experiences, academic evaluations, and operational data suggest that Clare’s Law often functions less as an intervention and more as a symbolic gesture—affirming state concern but offering limited material impact.

5.3.3.1. Empowerment and the ‘Right to Know’

Disclosure mechanisms are often described as empowering tools that give individuals control over their own safety. In theory, knowledge of a partner’s prior violence allows a person to reassess the risks in their relationship, seek support, or disengage before harm escalates. Proponents argue that Clare’s Law reduces the ability of abusers to gaslight or isolate victims, and that access to criminal history helps disrupt patterns of coercive control.⁷⁰¹

Some police forces have framed the disclosure process as a means of undermining the abuser’s “monopoly on perception” by replacing denial or doubt with verified information. In this context, officers report using criminal history disclosures to reduce shame, build self-trust and self-confidence.⁷⁰²

5.3.3.2. Limits of Usefulness in Practice

Despite these theoretical benefits, research has repeatedly shown that disclosures rarely function as decisive turning points. Most victims do not act on the information alone, especially in contexts of financial dependence, coercive control, or shared children. Some victims reported that the information came too late to change course, or that it merely confirmed what they already knew. Others said the absence of a disclosure—or receipt of a “low risk” or “insufficient information” label—left them feeling dismissed or misled.

Disclosure content is often minimal. Victims typically receive a verbal communication, devoid of specific detail, and are prohibited from sharing it with others. This confidentiality constraint has left some feeling morally responsible but legally restricted: unable to warn others, yet distressed at the idea that future harm may occur.⁷⁰³

5.3.3.3. Responsibilization and Structural Harm

A consistent theme in the literature is that Clare’s Law shifts responsibility for safety from institutions to individuals.⁷⁰⁴ Several victim accounts describe feeling judged for not acting on a disclosure, or having the disclosure used against them in child protection contexts. In some cases, women reported concerns about future relationships and an added responsibility to avoid potential abusers.⁷⁰⁵

This responsibilizing tendency is particularly acute for women with structural vulnerabilities. For racialized and Indigenous victims, disclosures may trigger unwanted scrutiny or surveillance, particularly in family court or immigration contexts.

The emotional labour of managing a disclosure—interpreting vague language, deciding whether to share with others, navigating fear or guilt—is often underestimated. Victims may feel isolated after receiving a disclosure, especially when it does not come with tangible support, legal options, or housing alternatives.

5.3.3.4. Inequitable Access and Operational Variability

Disclosures are only possible where police already have relevant information on file. This creates access disparities given the significant underreporting of domestic violence incidents to police.⁷⁰⁶ Victims of non-physical or undocumented abuse may receive no disclosure at all—even when risk is present.

There is also wide variation in how disclosures are processed. Across the UK, Right to Ask and Right to Know application rates, approval thresholds, and content vary by jurisdiction. In Canada, no jurisdiction has standardized disclosure criteria or follow-up pathways. Some services report delays of over 30 days, while others note confusion about eligibility or application format.

5.3.4. Evaluation, Measurement, and Research Gaps

Across jurisdictions where Clare’s Law has been implemented—including the UK, Saskatchewan, Alberta, and Newfoundland and Labrador—no jurisdiction has published comprehensive evaluation data on efficacy, cost-effectiveness, or system impacts. This gap has led to significant challenges in determining whether the disclosure model delivers the prevention benefits claimed by its proponents.

5.3.4.1. Absence of Outcome Data

Most jurisdictions have tracked application and disclosure volumes but have not collected follow-up data on what happens after a disclosure is made. There are no public studies showing whether disclosures lead to protective action, reduced revictimization, or improved long-term outcomes. In the UK, one freedom of information study suggested that up to 45% of disclosure recipients were subsequently victimized by the same partner.⁷⁰⁷ These data points raise questions about the preventive value of Clare’s Law in the absence of robust post-disclosure support.

Moreover, none of the Canadian provinces with Clare’s Law legislation—Saskatchewan, Alberta, or Newfoundland and Labrador—has released formal evaluation reports or annual statistics beyond basic application numbers. No data are available on demographic usage patterns, effectiveness across risk categories, or comparative outcomes with other tools such as restraining orders or bail enforcement.

5.3.4.2. Cost and Administrative Burden

There is no public information on the administrative costs of operating Clare’s Law frameworks in any Canadian jurisdiction. Police services are responsible for processing applications, conducting records checks, assigning risk levels, delivering disclosures, and coordinating with support agencies. These steps require dedicated personnel, training, and data infrastructure. In jurisdictions such as Saskatchewan, disclosures must also be reviewed by multi-sector committees, further increasing system overhead.⁷⁰⁸

The opportunity cost of deploying officer and agency time to disclosure tasks—rather than direct enforcement or support roles—has not been formally assessed. Nor have jurisdictions estimated the costs of potential unintended consequences, such as escalated CAS involvement, support service overload, or re-traumatization.

5.3.4.3. Variation Across Jurisdictions

Implementation patterns vary widely. Within the UK, disclosure approval rates have ranged from below 10% in some jurisdictions to nearly 100% in others. Canadian jurisdictions have not published comparable metrics, but media and practitioner reports describe inconsistent timelines and variable access across police services. In Alberta, disclosures reportedly take 30–40 days to process; in Newfoundland, implementation was delayed for years due to protocol development.

This undermines public trust and complicates cross-jurisdictional coordination.

5.3.4.4. Research Methodology Constraints

Measuring prevention is methodologically difficult. Disclosure effects cannot be ethically tested using randomized control trials. Victim-reported outcomes are shaped by multiple, intersecting factors. Victim decisions after disclosure depend not only on the information itself, but also on housing availability, economic dependence, legal support, immigration status, and trauma history.

Academic researchers have cautioned against evaluating Clare’s Law based solely on usage rates or anecdotal success stories. Without a control group or pre-post impact data, it is unclear whether Clare’s Law offers added value compared to other, better-established interventions.

5.3.4.5. Comparison with Existing Tools

A range of risk identification and enforcement tools are already in existence. These include police flagging systems; protection orders; probation and bail conditions; and structured risk assessment tools such as ODARA, B-SAFER, and DVRM. These systems are embedded in enforcement pathways and supported by statutory authority.

Unlike these tools, Clare’s Law has no enforcement component, no mandatory follow-up, and no legal remedy attached to disclosure. Critics have suggested that the law may duplicate, rather than supplement, existing safeguards—particularly if protection orders, case monitoring, and dashboard systems are already in place and functioning.

In summary, despite political and public interest in Clare’s Law, there is currently no empirical basis for concluding that it improves safety, reduces violence, or represents an efficient use of public resources. The absence of standardized outcome tracking, cost estimates, and methodological rigour remains a central challenge to its future consideration.

5.3.5. Strategic Assessment and Recommendation

Based on the available evidence, no recommendation is made for the implementation of Clare’s Law in Ontario at this time. While the disclosure framework has been legislated in several jurisdictions and is supported by a range of political and public actors, key implementation variables remain untested, and the long-term effects of such policies are not yet established. The evaluation literature emphasizes that there is no jurisdiction in Canada—or internationally—that has published a comprehensive analysis of Clare’s Law’s efficacy, cost-effectiveness, or comparative advantage.

Empirical studies and victim accounts suggest that while disclosures may provide some individuals with emotional validation or informational clarity, they do not consistently support safe exit or protection in high-risk situations. The absence of structured legal follow-up, enforceable remedies, or guaranteed access to supports limits the practical effect of disclosures. In some cases, disclosures may be associated with increased institutional surveillance or victim-blaming in family law or child protection contexts.

Additionally, Clare’s Law operates in a space already populated by protective and preventive tools. Ontario’s existing infrastructure offers broader and more actionable frameworks for identifying and mitigating interpersonal violence, if properly implemented. These mechanisms already function within enforceable legal contexts and are designed to prompt system-level interventions rather than individual-level burden. In comparative terms, the reforms recommended elsewhere in this report—including cross-sector protection order visibility, centralized compliance infrastructure, and integrated risk monitoring—are expected to achieve greater protective reach and practical enforcement impact than a standalone disclosure scheme.

Some academic commentary has proposed that further study of Clare’s Law may be warranted before implementation decisions are made. However, given the scale of existing research, the consistent pattern of concerns raised across jurisdictions, and the availability of higher-leverage interventions, it is not clear that further study would yield different results. At present, there is no demonstrated need for a standalone disclosure framework, and no evidence to suggest that it would deliver superior outcomes relative to tools Ontario is already developing.

Accordingly, this report does not recommend further pursuit of Clare’s Law in Ontario. It further recommends that institutional focus remain on enhancing enforcement of existing orders, expanding structured risk assessment infrastructure, and improving data visibility through cross-sector dashboards and protective intelligence systems. These investments are likely to deliver a broader scope of protection and a stronger return on prevention resources than a passive disclosure model.

5.4 Recommendations

5.4.1. Recommendation 1: Establish the Violence Prevention and Civil Accountability Act

Context and Rationale: Ontario does not currently have a dedicated statute that provides victims of intimate partner violence (IPV), sexual violence (SV), and human trafficking (HT) with accessible, procedurally supported civil remedies. Victims who experience coercive control, stalking, image-based abuse, reputational sabotage, or persistent harassment often face complex legal barriers when attempting to seek redress through common law torts or fragmented court processes. Existing causes of action such as defamation, intrusion upon seclusion, or intentional infliction of mental suffering may not apply, may impose unreasonably high evidentiary burdens, or may not reflect the lived reality of cumulative, relational, or technology-facilitated harm.

Recent judicial decisions have attempted to fill this gap. In Caplan v. Atas (2021), the Superior Court of Justice recognized a narrow tort of harassment in internet communications. In Ahluwalia v. Ahluwalia (2022 ONSC 1303), the court recognized a novel tort of family violence—though that decision remains under appeal to the Supreme Court of Canada at the time of this recommendation. While these cases reflect growing recognition of sustained, non-physical abuse as legally actionable, the resulting legal framework remains patchwork and doctrinally unstable. Most importantly, it remains procedurally inaccessible to the majority of victims.

To address these gaps and modernize Ontario’s civil response to violence, the Government of Ontario should enact a new statute—the Violence Prevention and Civil Accountability Act. This statute would consolidate and codify three core civil remedies: a statutory tort of harassment, a statutory tort of intimate image abuse, and a reformed civil protection order regime. Together, these provisions would create a coherent, accessible framework for victims to seek recognition, safety, and redress outside the criminal system.

Jurisdiction and Legislative Authority: The province has clear constitutional authority under section 92(13) of the Constitution Act, 1867 to legislate in matters of property and civil rights. A new statute—the Violence Prevention and Civil Accountability Act—would serve as the legislative vehicle.

This statute could be administered under the Ministry of the Attorney General (MAG), with associated changes to the Courts of Justice Act, the Rules of Civil Procedure, and MAG’s online service platforms to facilitate implementation.

Recommendation: The Government of Ontario should enact a new statute titled the Violence Prevention and Civil Accountability Act, structured as follows:

• Part I: Interpretation and Purpose
  • Define key terms including harassment, intimate image abuse, coercive control, and civil protection orders.
  • Articulate the Act’s purpose as providing victims with civil pathways to safety and accountability where criminal or family court mechanisms are unavailable or insufficient.
• Part II: Statutory Tort of Harassment (see Recommendation 2)
  • Codify a civil cause of action for persistent, malicious, and harmful harassment.
• Part III: Statutory Tort of Intimate Image Abuse (see Recommendation 3)
  • Provide a civil remedy for the distribution or threat of distribution of intimate images, including deepfakes and synthetic sexual imagery.
• Part IV: Civil Protection Orders (see Recommendation 4)
  • Establish a modernized, standalone protection order regime available 24/7, enforceable by police, and responsive to coercive control, stalking, and TFV.
• Part V: Procedural and Access Supports
  • Mandate the development of model pleadings, plain-language public materials, digitized order and claim templates, and streamlined fee waiver processes under O. Reg. 193/95.
  • Permit pseudonym use, publication bans, and sealed records where required to protect victim dignity and safety.

Implementation Considerations: The creation of a new statute will require coordinated policy development within MAG and inter-ministerial consultation with justice sector partners. Particular attention should be given to:

• Avoiding duplication or conflict with existing civil remedies under the Courts of Justice Act or the Family Law Act;
• Ensuring that the Rules of Civil Procedure are updated to support the new torts and protection order process;
• Training judiciary, legal clinics, and frontline service providers in the scope and structure of the Act;
• Developing multilingual, plain-language explanatory materials and digitized user pathways for claimants without counsel.

To avoid delay or fragmentation in implementation, the Act could include regulation-making powers permitting staged rollouts of each Part, with Parts II–IV brought into force through separate proclamations.

Rationale: This Act would serve as the civil law counterpart to the institutional coordination and prevention architecture advanced through the Ontario Intimate Partner Violence and Sexual Violence Response Network (OIVPRN). It addresses key gaps in civil redress, complements upstream prevention and justice reforms, and aligns with the report’s broader goal of creating a seamless, multi-jurisdictional framework for victim safety and offender accountability. By consolidating civil remedies into a single, accessible statute, Ontario can simplify navigation, increase procedural equity, and position itself as a national leader in civil law modernization for violence prevention.

5.4.2. Recommendation 2: Create a Statutory Tort of Harassment in Ontario

Context and Purpose: Victims of IPV, SV, and HT are frequently subjected to patterns of conduct that cause cumulative harm but fall outside the scope of recognized common law torts. These include sustained digital harassment, reputational sabotage, obsessive surveillance, impersonation, and non-physical coercion. While some cases may be captured by torts such as defamation, intrusion upon seclusion, or intentional infliction of mental suffering, these doctrines are often either too narrow or too procedurally burdensome to be meaningfully accessible.

The 2021 decision in Caplan v. Atas marked the first formal recognition in Ontario of a narrow tort of harassment in internet communications. However, this lower court ruling exists in doctrinal tension with the Ontario Court of Appeal’s earlier decision in Merrifield v. Canada (AG), which rejected a general tort of harassment and deferred to the legislature for any expansion of tort law in this area. The 2022 trial decision in Ahluwalia v. Ahluwalia, which recognized a novel tort of family violence, further illustrates the willingness of lower courts to respond to persistent relational harm through tort law. However, the Ahluwalia case is currently under appeal at the Supreme Court of Canada, and as of the time of this recommendation’s drafting, the outcome remains pending.

While the pending Ahluwalia decision may shape the doctrinal boundaries of novel relational torts, the recommendation to codify a narrowly framed, statutory tort of harassment remains sound. This recommendation reflects a targeted policy choice to address egregious, persistent, and malicious conduct that current common law remedies inadequately capture. Codification would also provide doctrinal clarity, procedural consistency, and a clearer pathway to redress for victims.

Jurisdiction: The Government of Ontario has the constitutional authority to create statutory causes of action under its jurisdiction over property and civil rights (Constitution Act, 1867, s. 92(13)). This tort would be enacted as Part II of the proposed Violence Prevention and Civil Accountability Act, under the policy and administrative authority of the Ministry of the Attorney General.

Recommendation: The Government of Ontario should codify a statutory tort of harassment as Part II of the Violence Prevention and Civil Accountability Act. The tort should:

• Be defined in statute as arising where:
  • The defendant has engaged in a pattern of conduct directed at the plaintiff;
  • The conduct is calculated to cause, and does cause, fear, emotional distress, reputational damage, or psychological harm;
  • The conduct exceeds the bounds of lawful expression, ordinary annoyance, or non-malicious interpersonal conflict.
• Apply to both physical-world and technology-facilitated abuse, including:
  • Digital stalking and surveillance;
  • Online impersonation or account spoofing;
  • Reputational sabotage (e.g., malicious complaints to employers or family services);
  • Coercive public allegations or character attacks intended to intimidate or isolate.
• Allow for:
  • Compensatory and punitive damages;
  • Declaratory relief;
  • Injunctive orders, including cease and desist directives.
• Permit the use of pseudonyms in pleadings where appropriate to protect the safety or dignity of victims.
• Clarify that the tort is available regardless of whether criminal charges have been laid or prosecuted.
• Include a provision directing the Ministry of the Attorney General to develop:
  • Model pleading templates;
  • Plain-language explanatory materials;
  • Partnerships with Legal Aid Ontario and community legal clinics to support claim navigation.

Implementation Considerations: While this recommendation codifies an existing legal direction reflected in Caplan, the pending Ahluwalia decision at the Supreme Court of Canada may influence broader doctrinal developments in this area. The province should monitor the outcome and be prepared to adjust statutory framing if necessary, while maintaining the narrow and focused purpose of the statutory tort.

The Ministry of the Attorney General should anticipate and mitigate access-to-justice barriers. These include filing fees, service-of-process challenges, and the risk of retraumatization during civil litigation. The Ministry should update fee waiver guidelines under O. Reg. 193/95 to explicitly reference harassment and image-based abuse as eligible grounds for hardship consideration.

Judicial education should accompany implementation, including guidance on the cumulative nature of coercive control, psychological targeting, and technology-facilitated harassment. The province may also consider supporting the Ontario Judicial Council or National Judicial Institute in updating IPV-related civil adjudication modules.

This tort is not intended to duplicate statutory remedies for harassment arising solely within the employment context. Where conduct occurs within a formal workplace relationship and falls within the scope of the Occupational Health and Safety Act or Human Rights Code, those statutory frameworks will continue to govern. However, this tort may apply to relational or extra-institutional harassment that extends into workplace settings—such as reputational sabotage, obsessive contact, or coercive conduct targeting the plaintiff through their employer or colleagues.

Rationale: This recommendation aligns with the report’s broader strategy of establishing responsive, trauma-informed, and procedurally accessible civil accountability mechanisms for victims of violence. It provides a legal foundation for claims that often arise in tandem with IPV, SV, HT, or image-based abuse, and complements proposed recommendations on protection orders and civil remedies for digital harms. By codifying this tort, Ontario would enable civil courts to recognize and respond to sustained harm where criminal thresholds are not met, without overextending existing tort doctrines or requiring piecemeal innovation by lower courts.

5.4.3. Recommendation 3: Create a Statutory Tort of Intimate Image Abuse in Ontario

Context and Purpose: Ontario lacks a dedicated civil remedy for victims of image-based sexual abuse, including the distribution of intimate images without consent, synthetic sexual images (deepfakes), and related technology-facilitated harms. Existing legal tools—such as breach of confidence, intrusion upon seclusion, or Criminal Code s. 162.1—offer incomplete or procedurally inaccessible avenues for redress, especially in cases involving anonymous actors, platform-based dissemination, or non-physical coercion.

Jurisdictions such as Manitoba and British Columbia have introduced specialized statutes, but these have been criticized for omitting synthetic imagery, failing to address minors’ procedural needs, and limiting access to injunctive relief against third-party platforms. A more comprehensive approach is needed in Ontario to provide civil accountability, enable takedown and enforcement mechanisms, and support victims who face long-term reputational and psychological harm from digital sexual abuse.

Jurisdiction: The statutory tort of intimate image abuse would be enacted as Part III of the Violence Prevention and Civil Accountability Act, under the authority of the Ministry of the Attorney General.

Recommendation: The Government of Ontario should codify a statutory tort of intimate image abuse as Part III of the Violence Prevention and Civil Accountability Act. The tort should:

• Define an “intimate image” to include:
  • Visual recordings (photo, video, livestream, or still frame) depicting nudity, sexual activity, or private bodily exposure;
  • Digitally altered, synthetic, or deepfake images portraying the plaintiff in such contexts;
  • Images taken or shared without the plaintiff’s knowledge or consent, including through coercion, manipulation, or deception.
• Allow a cause of action where:
  • The defendant distributed, threatened to distribute, created, possessed, or failed to remove an intimate image without the plaintiff’s consent;
  • The plaintiff suffered harm to safety, dignity, emotional wellbeing, or reputation;
  • The identity of the defendant is known, unknown, or reasonably inferred from platform data or digital context.
• Permit claims against:
  • Individuals known to the plaintiff;
  • Anonymous or pseudonymous defendants, including placeholder names such as “John Doe”;
  • Platforms or third parties who are given notice of an image and fail to remove it within a reasonable time, or who profit from the image’s distribution.
• Authorize service by alternative means where traditional service is not feasible, including by email, platform message, or publication.
• Provide for:
  • Compensatory, aggravated, and punitive damages (where the defendant is identified);
  • Declaratory relief and findings of liability against anonymous users;
  • Mandatory injunctive relief, including de-indexing, takedown orders, cease-publication orders, and emergency interim orders to prevent imminent distribution or compel removal.
• Authorize the use of pseudonyms in pleadings and sealed court records where public identification would risk re-traumatization, safety, or reputational harm.
• Permit the court to waive formal notice or service requirements where delay would exacerbate harm.
• Require the Ministry of the Attorney General to:
  • Develop model pleadings, plain-language self-help guides, and digital service tools, including guidance for claims against unknown defendants;
  • Establish partnerships with Legal Aid Ontario and community legal clinics for navigational support;
  • Monitor the effectiveness of the tort and conduct a 5-year legislative review.

Implementation Considerations: The Ministry of the Attorney General should develop procedural guidance for initiating claims against unknown or pseudonymous defendants. This includes permitting placeholder naming (e.g., “John Doe”), allowing courts to authorize service by electronic or platform-based methods, and enabling declaratory or injunctive relief even if the defendant does not appear. These mechanisms are already supported in Ontario case law and are essential for victims seeking relief where perpetrators conceal their identities.

The Ministry of the Attorney General should anticipate the need for:

• Judicial and tribunal training on image-based abuse, synthetic content, trauma-informed adjudication, and platform architecture;
• Expansion of fee waiver eligibility under O. Reg. 193/95, including presumptive hardship status for image-based abuse victims;
• Development of platform accountability frameworks or regulatory agreements to support enforcement of injunctive relief;
• Specialized court procedures for minors, including presumptive sealing of records and the appointment of litigation guardians.

The statute should be technology-agnostic and avoid limiting definitions to current file types or platforms. Courts should be permitted to interpret terms broadly in light of evolving media forms, including AI-generated content and ephemeral media. Where plaintiffs or defendants are minors, the standard rules under the Courts of Justice Act respecting litigation guardians shall apply. The province may wish to develop youth-specific court guidance and prioritize injunctive relief over damages in youth-to-youth cases.

Rationale: This recommendation provides a structured and trauma-informed civil remedy for one of the most rapidly growing forms of gender-based and technology-facilitated violence. By addressing gaps in the common law, building on the strengths of Manitoba and BC statutes, and improving on their limitations, Ontario can position itself as a national leader in image-based abuse response. The tort supports safety planning, reputational repair, and accountability for synthetic harms, and provides pathways to justice even where criminal thresholds are not met. This recommendation reinforces Ontario’s broader strategy of integrated, early, and victim-centred legal reform.

5.4.4. Recommendation 4: Create a Modern Civil Protection Order Framework in Ontario

Context and Purpose: Victims of IPV, SV, stalking, coercive control, and technology-facilitated violence (TFV) often require immediate, enforceable protection that is not contingent on criminal charges or family court involvement. While Ontario courts can issue restraining orders under the Family Law Act and peace bonds under the Criminal Code, these mechanisms are procedurally limited, inconsistently enforced, and not always well-suited to cases involving non-intimate parties or digital harms.

Ontario previously passed the Domestic Violence Protection Act, 2000 (DVPA), which would have allowed for emergency civil protection orders issued by Justices of the Peace. The Act was never proclaimed into force. More recently, other jurisdictions—including Alberta and the federal government—have taken steps to expand access to civil protection orders outside the criminal and family contexts. These models provide clear legislative authority, enforceability under section 127 of the Criminal Code, and streamlined access to urgent remedies.

A modern Ontario framework is needed to bridge protection gaps, support early intervention, and provide a procedurally accessible option for victims of relational and technology-based violence. This framework should integrate learnings from the DVPA and reflect contemporary risks, including threats involving pets, image-based abuse, online impersonation, and stalking by acquaintances or strangers.

Jurisdiction and Legislative Authority: Ontario has constitutional jurisdiction over civil procedure and the administration of justice under sections 92(13) and 92(14) of the Constitution Act, 1867. The new civil protection order framework would be enacted as Part IV of the proposed Violence Prevention and Civil Accountability Act, under the authority of the Ministry of the Attorney General.

The province can also rely on its residual authority to ensure public safety and support early intervention in violence prevention. The proposed orders would operate alongside—but independent from—orders available under the Criminal Code and family law statutes.

Recommendation: The Government of Ontario should establish a modern civil protection order regime as Part IV of the Violence Prevention and Civil Accountability Act. The framework should:

• Enable victims to apply for protection orders without requiring criminal charges or family court proceedings;
• Provide 24/7 emergency access to Justices of the Peace for urgent interim orders;
• Be relationship-neutral—applicable to current/former partners, acquaintances, peers, or unknown persons;
• Authorize orders based on IPV, SV, stalking, coercive control, TFV, threats to animals, and other serious relational harms;
• Include the following potential terms:
  • No-contact and non-communication conditions;
  • Geographic restrictions (e.g., stay-away zones);
  • Exclusive possession of the residence (regardless of legal title);
  • Firearm surrender and prohibition conditions;
  • Protection of pets or animals in the applicant’s care;
  • Monetary compensation for relocation, lost income, or emergency expenses;
  • Restrictions on digital or online contact, surveillance, or publication.
• Ensure that all orders:
  • Are issued in standardized, machine-readable formats;
  • Are enforceable under section 127 of the Criminal Code;
  • Are automatically shared with police-accessible systems such as CPIC;
  • Are entered into a real-time, centralized protection order registry hosted or coordinated by the Ministry of the Attorney General.
• Direct the Ministry of the Attorney General to:
  • Develop and maintain a provincial protection order registry that permits real-time digital transmission from courts to police;
  • Enable secure, read-only access for authorized frontline service partners (e.g., shelters, VWAP);
  • Design for compatibility with Ontario’s proposed Safekeeping platform and digital bail dashboard initiatives.
• Permit pseudonymous applications and sealing of records where safety or privacy requires;
• Allow for 24/7, remote, virtual, or telephone-based applications;
• Authorize alternative service methods, including digital or third-party service;
• Require that all police officers receive training on their duties to enforce civil protection orders and understand their authority under LE-024 (Policing Standards Manual);
• Mandate the development of plain-language application forms, information materials, and public education tools.

Implementation Considerations: The Ministry of the Attorney General should coordinate with the Ontario Court of Justice, Justices of the Peace, and police services to develop protocols for real-time protection order transmission, enforcement, and verification. The provincial registry should support downstream interoperability with Ontario’s broader justice data modernization strategy.

This protection order framework is intended to serve as a primary Ontario mechanism. A separate legislative provision (see Recommendation 5) will address the recognition and enforcement of protection orders issued in other Canadian jurisdictions. Ensuring clear differentiation between domestic and extra-provincial enforcement mechanisms will support accurate data tracking, registry function, and public-facing guidance.

In cases involving Indigenous applicants or respondents, the province should consult with Indigenous communities to determine whether and how civil protection orders intersect with Indigenous justice systems. While orders can be made available province-wide, participation of Indigenous Child and Family Well-Being Agencies or other Indigenous service providers must remain voluntary and culturally appropriate.

Rationale: This recommendation provides a flexible, procedurally accessible protection mechanism for victims whose safety needs are not adequately met by family or criminal court. It modernizes and operationalizes key features of the unproclaimed Domestic Violence Protection Act, 2000 while addressing emergent harms such as TFV, coercive control, and animal threats. By creating a clear, enforceable, and accessible pathway to civil protection orders, Ontario can reduce system gaps, support early intervention, and improve victim safety without requiring contact with the criminal justice system.

5.4.5. Recommendation 5: Recognize and Enforce Protection Orders from Other Canadian Jurisdictions

Context and Purpose: Victims of IPV, SV, stalking, and coercive control often relocate across provincial boundaries to escape abuse or to seek safety and support. In such cases, protection orders issued in another Canadian province or territory may be critical to victim safety and planning. However, Ontario currently lacks a dedicated statutory mechanism for the recognition and enforcement of extra-provincial civil protection orders.

Other provinces, including British Columbia and Manitoba, have enacted legislation that allows protection orders issued elsewhere in Canada to be automatically recognized and enforced as if they were local orders. These frameworks enhance cross-jurisdictional safety, reduce the administrative burden on victims, and ensure consistent police enforcement through integration with the Canadian Police Information Centre (CPIC). Ontario’s absence of a comparable provision leaves a gap in legal continuity and can undermine the effectiveness of protection orders when victims cross provincial borders.

A standalone legislative mechanism is required to ensure that Ontario consistently and reliably recognizes valid protection orders from other Canadian jurisdictions, including civil emergency orders issued by Justices of the Peace. This would complement Ontario’s internal protection order regime and align the province with national best practices.

Jurisdiction: The recognition and enforcement of Canadian civil protection orders may be implemented through a dedicated Part of the Violence Prevention and Civil Accountability Act, or through a parallel statute akin to BC’s Enforcement of Canadian Judgments and Decrees Act or Manitoba’s Enforcement of Canadian Judgments Act.

The Ministry of the Attorney General would be responsible for implementation, in coordination with the courts, police services, and CPIC administrators.

Recommendation: The Government of Ontario should enact a statutory mechanism to recognize and enforce protection orders issued in other Canadian jurisdictions. The statute or statutory Part should:

• Define a “Canadian civil protection order” as any order made by a court or tribunal in another province or territory of Canada that:
  • Protects a person from violence, harassment, stalking, or coercive control; and
  • Contains terms such as non-contact, geographic restrictions, residence exclusion, or firearm prohibition.
• Provide that such orders:
  • May be filed with an Ontario court by the protected party or their representative;
  • Are deemed enforceable in Ontario upon filing as if issued under Ontario law;
  • Are enforceable by police under section 127 of the Criminal Code;
  • Are entered into Ontario’s protection order registry and transmitted to CPIC.
• Clarify that Ontario courts:
  • Do not have jurisdiction to vary or terminate an out-of-province order;
  • May issue additional Ontario orders where necessary but must not alter the original.
• Require that court clerks:
  • Accept filings without requiring re-litigation of the facts;
  • Provide guidance and support for unrepresented victims seeking to register an order.
• Mandate public education materials and frontline partner training to ensure awareness of rights, responsibilities, and enforcement procedures.

Implementation Considerations: Implementation will require updates to the court registry, CPIC data entry protocols, and police verification systems. Ontario should adopt a streamlined filing process that allows for remote or in-person filing of certified copies of protection orders, with accompanying declarations or affidavits if needed.

Training for court staff, police, and frontline service providers should emphasize that valid Canadian protection orders must be treated with the same urgency and authority as Ontario-issued orders. MAG should develop an internal directive confirming that the province recognizes out-of-province protection orders for the purposes of enforcement, CPIC entry, and victim support.

The province should ensure that orders issued in Indigenous courts or tribunals, where recognized by the originating province, are also eligible for recognition under this framework, subject to consultation and alignment with Indigenous justice principles.

Rationale: This recommendation ensures that protection orders do not lose their protective value when victims move across provincial boundaries. It enhances national consistency, supports police enforcement, and reduces administrative burdens on victims. By aligning with statutory models in BC and Manitoba, Ontario can close a serious safety gap while reinforcing its commitment to early intervention and coordinated justice responses.

5.4.6. Recommendation 6: Call for the Criminalization of Deepfake Sexual Abuse and Synthetic Image-Based Harm

Context and Purpose: The non-consensual creation, distribution, or possession of synthetic sexual imagery—including AI-generated “deepfake” pornography—has become an increasingly common and devastating form of technology-facilitated sexual violence (TFV). These materials often depict real individuals, including minors, in fabricated or simulated sexual acts. While Ontario’s proposed statutory tort of intimate image abuse provides civil redress, there is currently no clear offence in the Criminal Code that captures the creation or dissemination of such synthetic sexual content where the image is not real or was not captured from an actual event.

This legal gap prevents law enforcement from laying charges, excludes victims from protection under the Canadian Victims Bill of Rights, and hinders the ability of courts to impose meaningful consequences. It also limits provincial enforcement and victim support tools, which are often tied to criminal proceedings. Jurisdictions such as the United Kingdom have already introduced targeted reforms to criminalize deepfake pornography, and other common law countries are considering similar legislative action.

Jurisdiction: The Parliament of Canada has exclusive jurisdiction over the creation of criminal offences, including amendments to the Criminal Code under section 91(27) of the Constitution Act, 1867. While Ontario cannot unilaterally create criminal offences, the province may formally request federal legislative reform and communicate its support through formal intergovernmental channels.

This recommendation falls within the scope of Ontario’s violence prevention and digital safety priorities and supports the province’s efforts to modernize TFV response infrastructure, including civil remedies, education, and online takedown mechanisms.

Recommendation: The Government of Ontario should formally call on the Government of Canada to amend the Criminal Code to criminalize the non-consensual creation, use, possession, or distribution of synthetic sexual images, including:

• Digitally altered images, videos, or media files that depict a real identifiable person engaged in sexually explicit conduct that did not actually occur;
• AI-generated or deepfake content designed to simulate sexual acts or nudity involving a real person, regardless of whether real footage or photographs were used as the base image;
• Non-consensual synthetic content involving minors, public figures, or individuals targeted as a form of harassment, coercion, or reputational harm.

The offence should:

• Be drafted to align with existing intimate image and child pornography provisions in the Criminal Code;
• Permit prosecution even where the depicted act is fictional or simulated;
• Apply regardless of the platform or medium of distribution, including social media, encrypted messaging apps, and cloud storage.

The Government of Ontario should further request that any Criminal Code offence in this area:

• Trigger eligibility under the Canadian Victims Bill of Rights;
• Be added to the list of designated offences for victim services eligibility and risk flagging;
• Support the issuance of no-contact orders, removal orders, and forfeiture of devices or accounts used in the commission of the offence.

Implementation Considerations: Ontario’s formal request to the federal government may be advanced through the Federal-Provincial-Territorial Ministers Responsible for Justice and Public Safety table, or through a direct submission from the Attorney General or Premier. The request should be supported by examples of known harm, civil system limitations, and the inability of current Criminal Code provisions to capture synthetic image-based abuse.

Rationale: This recommendation addresses a critical and emerging gap in the Criminal Code that leaves victims of synthetic image-based sexual abuse without access to justice. Criminalization would create an avenue for law enforcement response, strengthen deterrence, and ensure victims qualify for protection and support. It also complements Ontario’s proposed civil tort of intimate image abuse and reinforces a consistent, cross-jurisdictional approach to digital sexual violence.

5.4.7. Recommendation 7: Call for Federal Legislation Establishing a Victim-Initiated National Takedown Regime for Intimate Images

Context and Purpose: Victims of image-based sexual abuse—including non-consensual image distribution, synthetic pornography, and sextortion—frequently prioritize rapid removal of the content over criminal charges or civil damages. Despite this, Canada lacks a statutory mechanism enabling victims to submit takedown requests through a centralized, rights-bearing national platform.

The Canadian Centre for Child Protection’s Project Arachnid automates detection and removal of child sexual abuse material (CSAM), but it is limited in scope and function. It does not support adult victims, does not operate on a victim-initiated basis, and does not provide legislative guarantees of removal rights or coordinated federal oversight. As a result, victims of non-criminal, synthetic, or adult image abuse must navigate fragmented, platform-specific procedures with no central authority or legislative backing.

By contrast, the United States introduced federal legislation that facilitated the development of the “Take It Down” system—an anonymous, hash-based takedown platform available to minors and adult victims, supported by voluntary industry compliance but underpinned by national policy goals. Canada has no equivalent legislation empowering the creation or governance of a comparable system. Ontario should advocate for such a framework.

Jurisdiction: The federal government holds legislative jurisdiction over criminal law, telecommunications, privacy, and matters related to national digital infrastructure (Constitution Act, 1867, s. 91). A statutory takedown regime could be created through new federal legislation focused on intimate image abuse, online harms, or digital violence, or through amendments to existing acts governing telecommunications, online safety, or child protection.

While Ontario cannot enact this legislation itself, it can call on the federal government to do so and provide technical or policy support during design and implementation. This complements Ontario’s efforts to modernize civil remedies, support technology-facilitated violence victims, and expand access to justice.

Recommendation: The Government of Ontario should formally call on the Government of Canada to enact federal legislation establishing a victim-initiated, national takedown regime for intimate images. The legislation should:

• Create a legal mandate for a centralized, secure platform through which victims can submit hashed images (including real, synthetic, or AI-generated) for removal across participating platforms;
• Provide a statutory foundation for victim anonymity, procedural fairness, and platform accountability;
• Mandate participation by federally regulated telecommunications and digital service providers;
• Establish clear authorities for coordination, governance, and oversight by an independent, privacy-compliant national agency;
• Apply to all forms of intimate image abuse, including sextortion, deepfakes, voyeuristic captures, and coercive distribution by peers, strangers, or intimate partners;
• Include procedural safeguards for due process and privacy;
• Require public reporting on platform compliance, response times, and takedown volume;
• Include protections against retaliatory misuse or false reporting;
• Provide mechanisms for youth participation and non-parental access in cases of family-based abuse.

Ontario should offer to:

• Support federal consultations through victim-informed policy expertise;
• Align provincial victim service resources and education campaigns with the national tool;
• Provide implementation insights from its civil redress infrastructure.

Implementation Considerations: Ontario should ensure that its own legal, digital, and victim services infrastructure is ready to support and integrate with the national takedown system once created. This includes:

• Ensuring frontline service providers (e.g., VWAP, VAW shelters, clinics) are equipped to help victims access the system;
• Updating educational and public-facing materials to include guidance on takedown submission;
• Reviewing interoperability with Ontario’s civil torts, protection orders, and digital evidence procedures.

Rationale: A legislated national takedown regime would fill a structural gap in Canada’s online safety and image abuse response. It would provide victims with an authoritative, victim-initiated pathway for content removal, backed by legal obligations and oversight. By calling for legislation modeled on the intent and public infrastructure of the U.S. “Take It Down” initiative—but adapted for Canada’s constitutional and privacy framework—Ontario can drive national coordination, reduce harm, and support system-wide accountability in the digital abuse space.

Section 6: The Role of Family Court

6.1 Introduction/Background

Family court is often the most sustained point of legal contact for victims of intimate partner violence (IPV) in Ontario. While criminal courts may intervene around discrete offences, it is family court that determines parenting time and decision-making, restraining orders, and the long-term safety and stability of both victims and children. As such, the family justice system plays a central role in either mitigating or entrenching the harms of IPV.

In recent years, the Ontario government has made important progress in improving court access and modernization. The shift to virtual and remote proceedings during the COVID-19 pandemic—undertaken at unprecedented speed—allowed family matters to proceed safely and with reduced delay during a period of global crisis. More recently, Ontario has taken steps to increase financial eligibility for legal aid, helping more low-income residents access legal services. Amendments to Ontario’s Children’s Law Reform Act, and to the federal Divorce Act, have clarified, for the court, the importance of considering family violence as part of children’s best interests criteria. These measures reflect a broader commitment to strengthening access to justice.

At the same time, evidence before the committee makes clear that significant structural challenges remain—particularly for IPV-related cases. Ontario’s family justice system is procedurally complex, resource-constrained, and often disconnected from other parts of the legal system. Victims attempting to navigate family court often face prolonged litigation, conflicting court orders, inadequate representation, and continued exposure to coercive control tactics through the court process itself.

These are not just social or safety concerns—they are operational and fiscal ones. Prolonged custody battles, repeated motions, and self-represented litigants place enormous strain on court infrastructure, judicial time, and legal aid budgets. Cases that might be resolved early—through timely legal support, coordinated court responses, or trauma-informed decision-making—often escalate unnecessarily, consuming scarce public resources.

Addressing these systemic issues is not simply a matter of improving outcomes for individual victims—it is essential to the broader effectiveness of Ontario’s justice system. When family court processes are prolonged, duplicative, or adversarial by default, public confidence erodes, court resources are diverted, and critical infrastructure is tied up in avoidable litigation. Ensuring that victims can resolve matters earlier, with clarity and appropriate support, enhances both safety and system performance, and represents a more efficient use of taxpayer-funded institutions.

6.1.1. Siloed Legal Systems in Ontario’s Response to Intimate Partner Violence

Ontario’s legal response to IPV operates across three distinct and siloed court systems:

• Criminal courts, which address charges, bail conditions, peace bonds, and probation orders under the Criminal Code;
• Family courts, which handle parenting time and decision-making, support, separation, and restraining orders under the Children’s Law Reform Act and the Divorce Act; and
• Child protection courts, where the Children’s Aid Society (CAS) may seek to supervise or restrict a parent’s contact with their children under the Child, Youth and Family Services Act.

These systems operate independently, with their own legislation, legal standards, and case timelines. There is no formal mechanism for coordinating orders or evidence across them—even in cases involving the same parties, households, or incidents. As a result, one court may impose a no-contact condition while another, unaware of that order, grants parenting time. A child protection proceeding may be underway based on allegations of violence, but neither the family nor criminal court may be aware. These gaps are not hypothetical: testimony before this Committee and extensive research demonstrate that fragmented proceedings frequently result in contradictory rulings, enforcement challenges, and increased risk for victims and children.⁷⁰⁹

These inconsistencies also burden the broader justice system. Litigants are often forced to duplicate disclosures, refile evidence, or appear before multiple courts. Police may be unsure which order to enforce. Judges, lacking complete information, may issue rulings that are procedurally correct but practically unsafe.

Victims, particularly those without legal representation, are frequently left to act as the only bridge between these systems—repeating traumatic disclosures to different judges, navigating conflicting orders, and coordinating their own safety planning without institutional support.

While some locations in Ontario operate Unified Family Courts that integrate family matters from both the Ontario Court of Justice (OCJ) and the Superior Court of Justice (SCJ), these do not extend to child protection or criminal proceedings. There is no provincewide framework to ensure information-sharing, coordinated case management, or consistent safety planning across the criminal, family, and child protection systems.⁷¹⁰

6.1.2. Understanding Ontario’s Family Law Framework: Key Statutes and Their Functions

Ontario’s family court system operates under a complex blend of provincial and federal laws. Different statutes apply depending on whether the parents are married or unmarried, whether divorce is being sought, and whether child protection services are involved. This legal complexity contributes to the siloed experiences that many families—and service providers—encounter when navigating Ontario’s family justice system.

6.1.2.1. Children’s Law Reform Act (CLRA) — Ontario

The CLRA governs decision-making responsibility, parenting time, and guardianship for parents who are not divorcing under the federal Divorce Act. It sets out the legal test for determining the best interests of the child under Section 24 and authorizes the court to order independent parenting assessments under Section 30.⁷¹¹ This is the statute most commonly used when parents are separated, but not legally married. The Act was amended in 2021 to bring it into alignment with changes to the federal Divorce Act, leading to significant updates on criteria relevant to family violence.

6.1.2.2. Child, Youth and Family Services Act (CYFSA) — Ontario

The CYFSA governs child protection services, including the roles and responsibilities of CAS. It defines when a child is in need of protection and sets out the legal framework for investigations, supervision orders, temporary care, and adoption.⁷¹² Cases under the CYFSA are typically heard in the OCJ. This Act operates independently of whether parents are married or unmarried.

6.1.2.3. Divorce Act — Federal

The Divorce Act applies only to legally married spouses who are seeking a divorce. It governs parenting arrangements (formerly custody and access), child support, spousal support, and relocation.⁷¹³ The Act was amended in 2021 to incorporate a definition of family violence, including coercive and controlling behaviour, and to require courts to consider the impact of such violence on the best interests of the child.

6.1.2.4. Family Law Act (FLA) — Ontario

The FLA provides the provincial framework for property division, support, and domestic contracts.⁷¹⁴ It applies to both married and unmarried spouses, although certain provisions (e.g., equalization of net family property and exclusive possession of the matrimonial home) are limited to legally married couples. The FLA is frequently used alongside the CLRA or Divorce Act, depending on the nature of the dispute.

6.1.3. Intersections and Overlap

Many families are involved in more than one legal proceeding under different statutes. For example, a married couple may be divorcing under the Divorce Act while also dealing with child protection concerns under the CYFSA. An unmarried couple might be litigating decision-making under the CLRA while also contesting support under the FLA. These overlapping legal regimes contribute to Ontario’s siloed system and create significant navigation challenges—especially for unrepresented parties and those facing intimate partner violence.

6.1.4. Siloed Family Court Structures: Unified Family Courts

One aspect of Ontario’s multi-tiered family court system that illustrates broader system complexity is the variation in access to Unified Family Courts (UFCs). A UFC is a branch of the SCJ that handles all family law matters in a single forum. This includes divorce, parenting time and decision-making, child protection, property division, adoption, and restraining orders—issues that would otherwise require litigants to appear in multiple courts with overlapping or conflicting jurisdiction.

Calls for a unified court model began as early as 1974, when the Law Reform Commission of Canada recommended the creation of a single, integrated family court.⁷¹⁵ Ontario launched its first UFC pilot in Hamilton in 1977.⁷¹⁶ The model was made permanent in 1982 and widely expanded in 1999, when 17 new UFC sites were launched with federal support. UFC judges are federally appointed and hear matters under both federal and provincial statutes. The legal foundation for the UFC is found in Section 21.1 of the Courts of Justice Act, which formally establishes the Family Court branch of the Superior Court.⁷¹⁷

UFCs consolidate all family proceedings in one court and are typically staffed by judges with expertise in family law. Where implemented, they reduce procedural duplication, shorten wait times, and provide greater consistency for families. For victims of IPV, the UFC model can reduce the trauma of navigating multiple legal proceedings across two or more separate court systems. A victim seeking decision-making and parenting time, child protection, and divorce, for example, may benefit from having those matters heard by a single judge within a unified court, allowing for more coherent orders and minimizing repetitive disclosures of abuse.

In May 2019, the current Ontario government significantly expanded UFC access by launching eight new sites in Belleville, Cayuga, Kitchener, Pembroke, Picton, Simcoe, St. Thomas, and Welland. This brought the total number of UFC sites in Ontario to 25, covering approximately half of Ontario’s judicial districts.⁷¹⁸

UFC access is not yet universal across Ontario. In the remaining regions—including fast-growing areas like Peel and York—families must still navigate both the OCJ and the SCJ to resolve related matters. This structure can create duplication of effort, longer timelines, and added strain on litigants and the courts.

Though the UFC model was not designed specifically with IPV in mind, it offers potential benefits in IPV and child protection cases. A single court forum allows for more consistent orders, reduces the need to repeat traumatic disclosures, and can support more coordinated safety planning. The presence of judges who specialize in family law is a particular strength of the model, although—as with all areas of the family justice system—ongoing training on IPV, trauma, and coercive control remains essential.

The expansion of UFCs involves both federal and provincial coordination. Judicial appointments are federally funded, while the province must invest in courthouse infrastructure and administrative support. The Auditor General of Ontario has noted that facility limitations remain a challenge in several regions, and has flagged that a needs assessment of remaining sites is still underway.⁷¹⁹ As of 2024, UFCs remain one of several court structures operating in parallel across the province.

6.1.5. Related Pilot Model: Integrated Domestic Violence Court (Toronto)

Ontario also hosts a limited scope Integrated Domestic Violence Court (IDVC) pilot, located in Toronto at the 311 Jarvis Street courthouse. This model seeks to streamline criminal and family law proceedings involving the same family where IPV is present. Where jurisdiction permits, one judge hears both the family and criminal matters to promote continuity, reduce confusion, and enable better-informed decisions.⁷²⁰

Several studies have identified the IDVC pilot as a promising step toward improved coordination in IPV cases.⁷²¹ It was noted that when criminal and family proceedings occur simultaneously, outcomes can be delayed or conflicting unless there is integrated oversight. The IDVC model allows the same judge to consider bail or sentencing decisions in light of parenting time and decision-making, and safety issues, reducing the risk of inconsistent orders and enhancing victim safety.

Additional commentary from violence against women advocates in 2011 supported the idea that greater integration between criminal and family courts may be a step in the right direction. However, these groups also raised concerns: for example, that abusers could use the integrated process as another venue for harassment.⁷²²

While mentioned in some written submissions, the Committee did not receive in-depth or evaluative testimony regarding the operation or impact of the IDVC pilot. Public information on the pilot also appears to be limited. As of 2025, the court continues to operate exclusively at 311 Jarvis in Toronto and hears cases on a limited basis, reportedly every second Friday. The pilot remains restricted in scope and is not available to most Ontarians.

6.1.6. Parenting Assessments in Ontario: Section 30 and the Office of the Children’s Lawyer

Ontario’s family courts rely on two distinct mechanisms to obtain independent assessments of children’s needs and parental capacity in contested parenting matters: (1) reports from professionals appointed under Section 30 of the CLRA, and (2) reports prepared by clinicians from the Office of the Children’s Lawyer (OCL). While both processes aim to assist judges in determining the child’s best interests, they differ significantly in structure, funding, oversight, and accessibility.

6.1.6.1. Section 30 Assessments

Section 30 of the CLRA permits a family court judge to appoint “a person who has technical or professional skill” to assess and report on the needs of a child and each parent’s ability and willingness to meet those needs.⁷²³ These assessments are most often conducted by privately retained psychologists, social workers, or other mental health professionals. The assessor interviews the parents and children, observes interactions, speaks to collateral contacts (such as teachers or doctors), and—if qualified—conducts psychological testing. The resulting report is filed with the court and becomes admissible evidence.⁷²⁴ Either party may cross-examine the assessor⁷²⁵, though judicial decisions often align closely with the report’s conclusions.

Section 30 assessments are not publicly funded. The court may apportion costs between the parties or relieve one party of payment in cases of financial hardship, but the expense may range from a few thousand dollars to $20,000 or more.⁷²⁶ This cost presents a significant barrier for many litigants, particularly victims of IPV who may be economically destabilized.

A further concern raised in Committee testimony and expert submissions was the absence of regulated standards or mandatory training for Section 30 assessors. Although assessors are governed by professional colleges that prohibit practice outside of an individual’s area of competence, and although poor reports can be challenged in court or excluded, there remains no centralized roster, no formal system of public accountability, and no requirement that Section 30 assessors receive IPV-specific training. Most professionals conducting Section 30 assessments follow well-established best practices and guidelines, including those issued by the Association of Family and Conciliation Courts (AFCC).⁷²⁷ However, because training in coercive control, trauma, or IPV-specific risk factors is not mandated, even well-intentioned assessments may vary in how such factors are identified, interpreted, or weighted. These reports can carry considerable persuasive weight in judicial decision-making, especially where no other child-focused evidence is available.

Although Section 30 assessments are relatively rare in Ontario, they tend to appear in high-conflict or high-risk cases—precisely where the consequences of inaccurate or incomplete assessments are most serious. However, presenters to the Committee remain concerned that in the absence of a roster, standardized IPV-specific training, or formal review structures, there is limited guidance available to courts or litigants—particularly unrepresented parties—when selecting, reviewing, or challenging these assessments. While Section 30 and OCL assessments serve similar legal functions, their underlying structures diverge significantly. Section 30 assessments are privately retained, with no standardized roster or centralized oversight. By contrast, the OCL maintains an internal roster of vetted clinicians who operate within a defined institutional framework. This includes internal policies, access to legal support, and mechanisms for quality review. Although it appears that the OCL’s training standards are not publicly disclosed, the existence of an internal panel makes it more feasible to implement system-wide IPV training requirements. The absence of similar infrastructure for Section 30 assessments presents practical challenges for any future attempt to standardize training or mandate competencies. The Committee heard that this disparity—one system publicly funded and internally managed, the other private and decentralized—has real implications for consistency, accountability, and access.

Some experts have called for more visibility into the structure of these reports—not the conclusions, but the bones: What kinds of questions are being asked? How is risk assessed? How are trauma responses interpreted? Without clarity on these baseline elements, it is difficult to ensure that evolving understandings of coercive control, post-separation abuse, or IPV-related risks—such as threats to pets or misuse of animals—are being adequately addressed in the assessment process.

6.1.6.2. OCL Reports and Assessments

By contrast, the OCL—a publicly funded division of the Ministry of the Attorney General—maintains a formal roster of lawyers and clinicians (usually social workers) who conduct child-focused assessments or represent children in family court proceedings.⁷²⁸ These services are provided at no cost to the parties. The court may request OCL involvement, but the office has discretion over which cases to accept and will only do so where the child’s legal interests or voice require independent representation.

OCL clinicians prepare clinical investigation reports that assess parenting capacity and the child’s views and preferences. While not as lengthy or psychologically detailed as a Section 30 assessment, OCL reports provide a structured analysis, informed by interviews, observations, and collateral contacts. Clinicians operate within internal policy guidelines and their work is subject to structured legal oversight and internal review. While the specific content of training is not publicly disclosed, the OCL’s internal roster and policy framework offer a more structured approach to assessor selection, oversight, and case documentation than is available for Section 30 appointments. Panel clinicians must meet application standards, and many participate in ongoing education through organizations such as the Association of Family and Conciliation Courts (AFCC).⁷²⁹

Information about whether all OCL clinicians receive IPV- or coercive control-specific training does not appear to be publicly available. However, because OCL clinicians operate within a centralized system, there is infrastructure in place that could support the implementation or monitoring of such training in future. Both Section 30 and OCL assessments are widely used in Ontario’s family courts. Each plays a valuable role—but the differences in oversight, standardization, cost, and training create divergent pathways to what is nominally the same goal: determining the best interests of the child. These gaps do not mean either system is broken, but they underscore the need for transparency and consistency, particularly in high-risk cases. If Ontario is to ensure that assessments do not inadvertently perpetuate harm, future training, regulation, and implementation planning must address not only what is assessed, but how assessments are designed, reviewed, and updated.

The OCL appears to provide a useful precedent for structured oversight of independent professionals in Ontario’s family justice system. At least as of 2011, the OCL maintained a provincial panel of independent clinicians who operated on a fee-for-service basis under a structured framework to conduct parenting investigations under Section 112 of the Courts of Justice Act. Although these clinicians are not government employees, they operate under a formal framework that includes empanelment criteria, mandatory orientation, performance evaluation, and supervisor-approved reporting protocols.

As of 2013, OCL clinicians were empanelled for three-year terms, required to meet minimum qualifications, comply with policy agreements, and participate in ongoing training and internal review. Performance evaluations were conducted regularly, and training attendance was tracked. It is unclear whether these structures remain unchanged, but they provide a potential model for other areas of family court practice. However, it is important to note that OCL reports are not immune from criticism: many are contested by parents, and concerns about report accuracy, methodology, or bias can arise in both systems. While the OCL model is not without limitations—and some aspects may have evolved since their introduction—its structural features illustrate that Ontario has previously implemented a centralized framework for oversight and assessor accountability. It provides a conceptual model for how independent professionals might be subject to consistent expectations without undermining service flexibility or autonomy. This structure—while not immune to challenges—may offer a useful precedent for developing standardized, accountable approaches to parenting assessments conducted under Section 30 of the Children’s Law Reform Act.

Ontario could also look to external jurisdictional models when considering how to regulate Section 30 parenting assessments. In California, for example, courts may not appoint custody evaluators unless they have completed a minimum of 16 hours of specialized training in family violence, trauma, and coercive control, followed by 4 hours of annual update training.⁷³⁰

The curriculum includes content on structuring safe evaluations, controlling for bias, and understanding the impact of domestic violence on children. Ontario does not currently impose any equivalent training requirement. Adopting a similar standard—either on its own or as part of a future roster-based model—could provide a clear, evidence-informed foundation for screening assessors in high-risk cases.

6.1.7. Systemic Risk and Legal System Misuse in IPV Cases

6.1.7.1. Parallel Legal Proceedings: Navigation and Risk Exposure

For many victims of IPV, involvement in more than one legal proceeding is not an exception—it is the norm. It is common for a single family to be simultaneously engaged in criminal court (for bail or assault charges), family court (for parenting and access disputes), and child protection court (responding to concerns raised by the CAS).⁷³¹ Each of these proceedings follows a different legal framework, pace, and set of assumptions. Yet there is no standardized mechanism to align timelines, evidence, or protective measures across them.

One of the most significant challenges in these overlapping processes is the mismatch in evidentiary standards. Criminal courts operate on the standard of proof beyond a reasonable doubt and are focused on the guilt or innocence of the accused. Family courts, in contrast, apply the balance of probabilities and are mandated to assess the best interests of the child.⁷³² Despite this, there is concern among IPV advocates that family court judges often treat the absence of a criminal charge or conviction as evidence that abuse did not occur. This reflects not only a misunderstanding of the higher standard of proof in criminal law, but also a failure to account for the many reasons why criminal proceedings may not move forward—reasons that often have nothing to do with the truth of the allegations. Cases may be withdrawn due to lack of police resources, Crown discretion, procedural errors, the victim’s unwillingness to testify, or concerns for the victim’s safety or stability. In reality, many victims make a rational and self-protective decision not to pursue criminal charges at all. Yet when family courts rely on the criminal system’s silence as a proxy for truth, they risk dismissing legitimate safety concerns and exposing children and victims to ongoing harm.

These proceedings also differ in pace and procedural dynamics. Criminal matters tend to move more quickly, often through the Crown’s initiative, and may result in immediate protective measures such as bail conditions. In contrast, family law proceedings can span many months or even years, and require a higher level of personal organization, evidence-gathering, and participation.

When these systems operate in parallel but without coordination, the burden of alignment falls entirely on the victim. Victims are often forced to relay safety concerns and past abuse in multiple formats to multiple decision-makers—none of whom may have a complete picture. Testimony before the Committee described how victims are frequently required to advocate for their own safety while navigating a complex system with no legal counsel, minimal trauma-informed support, and no assurance that protective conditions in one proceeding will be recognized in another.

These gaps do not only impact victims; they also impose inefficiencies on the broader justice system. Court time is spent re-litigating known facts. Police and CAS workers must interpret contradictory orders. Abusive ex-partners may exploit these inconsistencies to delay proceedings, reassert contact, or challenge parenting restrictions. In short, parallel legal processes with conflicting timelines, standards, and mandates place an unsustainable burden on both victims and the justice system. These vulnerabilities are not only accidental—they can be weaponized. In some cases, abusers actively exploit legal fragmentation as a tool of coercive control.

6.1.7.2. Coercive Control and Legal System Misuse in Family Court Proceedings

In recent years, the justice system has begun to recognize that IPV does not always take the form of physical assaults. Many abusive relationships are characterized by patterns of intimidation, isolation, surveillance, and control—what experts and legislation increasingly refer to as coercive control.⁷³³ This concept describes a course of conduct that deprives a person of autonomy, dignity, and safety, even in the absence of physical violence. It includes tactics such as restricting access to money or transportation, limiting contact with friends or family, humiliating or degrading the victim, or using legal processes and parenting disputes as tools of punishment or control.

Coercive control can occur in any type of relationship, across all demographic groups. Testimony in Phase 3 of the Committee’s proceedings included many professionally accomplished, highly educated women who described being victims of prolonged coercive control. For these witnesses, the experience was compounded by the shame and dissonance of being perceived—by themselves and others—as strong, competent women while privately enduring abuse. The disconnect between their public identity and private reality created additional barriers to disclosure, compounded feelings of isolation, and delayed access to protection.⁷³⁴

The justice system’s growing awareness of coercive control is reflected in federal legislation, including the 2021 amendments to the Divorce Act, which direct judges to consider family violence in all its forms—including coercive control—when making parenting orders.⁷³⁵ Ontario’s own Schedule 1 of the Strengthening Safety and Modernizing Justice Act, 2023, aligns with these principles by requiring new judges to receive training in IPV and coercive control.⁷³⁶ Internationally, jurisdictions such as England and Wales, Scotland, and parts of Australia have adopted specific offences or statutory definitions recognizing coercive control as a form of abuse that often precedes lethal violence.⁷³⁷

For courts and justice system actors, the relevance of coercive control is not philosophical—it is practical. A growing body of evidence links patterns of control to post-separation escalation, litigation misuse, and long-term risks to victims and children. Recognizing coercive control early in family law proceedings is essential not only for safety, but for efficiency, risk management, and judicial accuracy.

In the aftermath of separation, IPV does not always end with the cessation of physical contact. For many victims, the abuse continues through legal processes, particularly in the family court system.⁷³⁸ This dynamic, often described as post-separation coercive control, can manifest through repeated and strategic use of court mechanisms to maintain dominance or prolong the abusive relationship under the guise of litigation.

Testimony before the Committee made clear that abusers may file successive motions, pursue unnecessary case conferences, submit affidavits filled with inflammatory or irrelevant content, and bring legal actions in multiple jurisdictions. Some engage in “paper abuse,” deliberately generating costs and procedural stress to exhaust or intimidate the other party. Others use litigation as a means of surveillance—forcing the victim to appear in person, disclose their location, or maintain contact under the guise of legal obligation. In some cases, the abusive party exploits self-representation to communicate directly with the victim in ways that would otherwise be filtered more appropriately through mutual legal counsel.

These behaviours are often framed as legitimate litigation activity. Without training in coercive control or abuse dynamics, legal professionals—including judges, lawyers, and custody assessors—may fail to recognize these patterns as continuations of prior abuse. Instead, they may interpret the victim’s resistance as obstruction or label the case as “high conflict” without appreciating the power imbalance driving the dispute. In this context, even efforts to protect children can be reframed as hostility or alienation.

Victims described feeling punished by the legal system for raising safety concerns, or silenced for fear that continued advocacy would be interpreted as unwillingness to co-parent. The financial burden can be significant. While abusers may fund litigation through employment income or marital assets, victims often face depleted resources, loss of legal aid eligibility, or a lack of representation altogether. The longer the process drags on, the greater the pressure to concede in order to end the ordeal.

From a systems perspective, this misuse of the legal process creates substantial inefficiencies. Judicial time is consumed by repeated appearances on marginal issues. Court staff must process excessive filings. Self-represented litigants require more procedural guidance. In cases where children are involved, assessments, OCL reports, and school or health system engagement may all be triggered unnecessarily. None of this serves the best interests of the child, the efficiency of the system, or the safety of the victim.

Addressing this issue does not require limiting access to the courts, but it does require increased awareness of how coercive control operates within legal proceedings. With proper training and screening, judges and legal professionals can better distinguish between genuine disagreement and patterns of coercive control. A more trauma-informed approach to assessing litigation behaviour—meaning an approach that recognizes how abuse affects memory, demeanour, emotional regulation, and trust in institutions—combined with improved case management and early identification protocols, would better serve both public safety and judicial economy.

6.1.7.3. The Rights and Voices of Children in Family Court

In cases involving IPV, children are often the least visible participants in legal proceedings—and the most affected. While both the Divorce Act and Ontario’s Children’s Law Reform Act require courts to consider the best interests of the child, these determinations are often made without directly hearing from the child or fully understanding their experience. In high-conflict or abuse-related cases, children’s voices may be filtered through the affidavits of parents, the impressions of professionals, or the assumptions of the court—rather than presented in their own right.

Under the United Nations Convention on the Rights of the Child (UNCRC), to which Canada is a signatory, children have the right to participate in decisions affecting them, the right to be protected from violence, and the right to have their best interests be a primary consideration in all legal actions.⁷³⁹ While these principles are reflected in Canadian legislation, implementation remains inconsistent. Ontario does not guarantee that children will have legal representation or a neutral avenue to express their views in family court. The Office of the Children’s Lawyer (OCL) may become involved in a case, but this is discretionary and subject to limited resources. In many cases involving IPV, children’s perspectives are never directly solicited or formally represented.

This absence can have serious consequences. Children’s resistance to contact with a parent may be viewed as irrational or the result of manipulation, rather than a protective response to trauma. Children may be ordered into reunification programs or compelled into access arrangements that ignore their stated fears or wishes. Testimony before the Committee emphasized that courts often assume that maintaining a relationship with both parents is inherently beneficial, even in situations where one parent has caused significant harm.

In some cases, children are not even informed of the legal outcomes that shape their lives. While protection from undue pressure is essential, a blanket approach that sidelines children’s voices risks violating their rights, retraumatizing them, and making court outcomes less effective.

Former Justice Donna Martinson and others have argued for a more consistent, child-centred approach⁷⁴⁰ which could include, for example, direct judicial engagement with children when appropriate, improved access to OCL representation, and clearer frameworks for understanding children’s resistance in the context of IPV. These changes would not only enhance child safety, but also improve the fairness, transparency, and credibility of family court processes.

Since 2016, Ontario has increasingly used Voice of the Child (VOC) reports to ensure that children’s views and preferences are directly heard in family proceedings. VOC reports are distinct from full clinical investigations or parenting assessments: they aim solely to convey a child’s perspective in a developmentally appropriate, neutral format. These reports are typically prepared by clinicians on the OCL panel and do not include recommendations.⁷⁴¹ Courts may request a VOC report under Section 112 of the Courts of Justice Act, but the OCL retains discretion over whether to accept the case, based on internal criteria, suitability of the referral, and available resources.⁷⁴² As a result, VOC reports are not universally available across Ontario, and there is no guarantee that a child’s voice will be formally heard—even when developmentally appropriate and relevant to the outcome. Although legislative amendments in 2021 clarified that OCL clinicians may prepare such reports under Section 112,⁷⁴³ access appears to remain uneven and highly dependent on discretionary referral and acceptance processes.

6.1.7.4. Parental Alienation: Origins and the Need for Guardrails

“Parental alienation” is a recognized concept in Ontario family courts. It refers to situations where one parent is alleged to have intentionally undermined the child’s relationship with the other parent. Ontario courts have recognized and addressed alienating conduct where the evidence supports it, and case law demonstrates that the legal framework does allow for intervention when justified. However, in cases involving family violence or coercive control, the challenge lies in distinguishing protective behaviour from manipulation—particularly in the absence of clear screening protocols.⁷⁴⁴

Parents who intentionally turn a child against the other parent without justification do exist—and such conduct can and has been found by the courts in certain contexts. However, when abuse or coercive control is also present, it may be difficult to distinguish manipulative behaviour from a child’s protective instincts or trauma response. Research has shown that when alienation claims are raised, courts may minimize or ignore concerns related to family violence.⁷⁴⁵ This does not invalidate the alienation concept itself, but it reinforces the need for rigorous screening where family violence is alleged. In IPV-related cases, protective actions—such as limiting contact, requesting conditions, or advocating for safety—may be reframed as alienating behaviour. In such instances, victims may be perceived as obstructive, and their advocacy for the child interpreted as manipulation.

The risk of misuse is not merely theoretical. The misuse of parental alienation was the subject of a recent report by the UN Special Rapporteur on violence against women and girls, which analyzed this problem across multiple countries. A 2022 empirical study by legal scholar Joan S. Meier found that U.S. courts disproportionately disbelieve mothers’ abuse claims when cross-alleged with parental alienation, and that court-appointed assessors often reinforce this dynamic.⁷⁴⁶ The study underscores the systemic nature of this problem and the difficulty survivors face when trying to protect their children while also defending their own credibility.

Several witnesses before the Committee described being advised not to disclose abuse in court, out of concern that doing so would lead to counter-allegations of alienation. These accounts—while not representative of all litigants—were consistent and credible and were supported by submissions from legal and clinical experts. These dynamics can create an environment where victims feel silenced, and where children’s fear may be attributed to influence rather than experience. In some cases, this may allow a coercive controlling parent to reposition themselves as the alienated party, seek increased access, or challenge protective measures. Without adequate screening, alienation frameworks may contribute to pressure to reverse custody, reduce supervision, or mandate reunification therapy—even in cases where abuse has not been fully assessed.

Caution is also warranted because of the concept’s controversial origins. “Parental Alienation Syndrome” (PAS), coined by U.S. psychiatrist Richard Gardner in the 1980s, was never accepted as a mental disorder by the Diagnostic and Statistical Manual of Mental Disorders (DSM) and has been criticized by many mental health professionals.⁷⁴⁷ Nevertheless, some of its assumptions—that abuse disclosures are often fabricated, or that rejection of a parent is more likely to reflect influence than harm—continue to inform how some assessors or litigants present parenting disputes.

Some of Gardner’s broader writings also raise serious ethical and moral concerns. His published views on child sexual abuse have been widely condemned and are irreconcilable with child protection principles. These statements reinforce the need for caution when citing his early work as clinical authority.⁷⁴⁸

Allegations of parental alienation can have serious consequences. Mothers are disproportionately accused of alienation in abuse-related cases and may lose custody or be subject to parenting restrictions despite a history of caregiving. Children may be separated from a protective parent and placed into reunification programs or other court-ordered interventions. Research has documented that forced reunification can have negative psychological outcomes for children.⁷⁴⁹

While the UN Special Rapporteur on violence against women and girls has called for legislation prohibiting the use of parental alienation and related allegedly pseudo-scientific concepts in family court,⁷⁵⁰ this report does not propose or recommend banning the concept. Alienating behaviour does occur—particularly in high-conflict cases not involving abuse—and courts must retain the ability to address it. However, the current framework lacks the safeguards needed to prevent misuse in cases involving IPV or coercive control.

Whether through appellate clarification or legislative review, Ontario may need to reassess how alienation theory is used in law. In the meantime, courts should ensure that any alienation claims are subject to rigorous evidentiary thresholds, trauma-informed analysis, and meaningful assessment for IPV and coercive control.

6.1.8. Judicial Education, Independence, and System Accountability

6.1.8.1. Why Judicial Training Matters

In Ontario, judges are not required to have prior experience in family law or IPV before appointment. While federally appointed judges receive training through the National Judicial Institute (NJI) and provincially appointed judges through internal court education bodies, the depth, consistency, and content of that training varies. Prior to the implementation of Keira’s Law, there was no mandatory requirement that either level of judge receive specific training in coercive control, IPV dynamics, or trauma-informed practice.⁷⁵¹

Ontario’s family courts operate under a divided jurisdiction. Provincially appointed judges in the Ontario Court of Justice (OCJ) preside over child protection, custody, support, and restraining order matters under provincial statutes. Federally appointed judges in the Superior Court of Justice (SCJ), including Unified Family Courts (UFC), adjudicate divorce, property, and many parenting disputes. In either setting, there has historically been no requirement that appointees have experience in family law, IPV, or child development, nor that they secure such experience. Judges may rotate from criminal, civil, or administrative chambers and be assigned to hear high-stakes custody trials with limited prior expertise.

This gap exists in a justice system where family court judges preside over complex, emotionally fraught matters with potentially life-altering consequences for litigants and children. Family cases are often characterized by non-physical abuse, post-separation control, and legally nuanced risk factors. Judges who are unfamiliar with coercive control dynamics may misinterpret a survivor’s distress as instability or mistake protective behaviour for obstruction. Witnesses to this Committee emphasized that in some cases, protective parents are labelled as uncooperative or alienating simply for raising safety concerns.

As Dr. Jennifer Kagan testified to the Committee, professionals involved in family law cases may be making “life-or-death decisions” in cases involving IPV or coercive control “without an iota of specialized training.”⁷⁵² These problems are not unique to judges. Family justice professionals such as custody assessors, OCL counsel, mediators, and CAS workers are often central to how a case unfolds. Yet many receive little or no formal education on coercive control or trauma, even as they shape recommendations and outcomes with lasting effects on children and families. Witnesses emphasized that court actors at every level must be trained to recognize how IPV manifests—including its legal, psychological, and systemic impacts.

6.1.8.2. Keira’s Law: A Constitutional Model for Judicial Education

In 2022, the federal government passed Bill C-233—commonly known as Keira’s Law—which amended the Judges Act to allow for the establishment of seminars for federally appointed judges on domestic violence and coercive control, as well as social context, including systemic racism and systemic discrimination.⁷⁵³ Ontario followed suit in 2023, following a Private Member’s Motion brought by MPP Effie Triantafilopoulos, enacting Schedule 3 of the Strengthening Safety and Modernizing Justice Act. This amendment introduced similar training opportunities for newly appointed provincial judges.⁷⁵⁴ These reforms mark an important shift: prior to these changes, such education was discretionary.

Crucially, these laws respect judicial independence. They do not prescribe the content of that training. The design and delivery of curriculum is delegated to judicial education bodies—including the Canadian Judicial Council and the NJI at the federal level, and the Ontario Court Education Secretariat at the provincial level—in consultation with legal and subject-matter experts. The material is not disclosed publicly, and this confidentiality is appropriate given its status as internal professional development.

Keira’s Law is a constitutional model for judicial education reform: it ensures that judges are informed without telling them how to decide. It does not create binding interpretations of the law. It does not override judicial discretion. It equips judges with deeper insight into abuse dynamics, coercive control, and child safety—so that their decisions, when made, are grounded in current knowledge and reflect the complexity of the cases before them.

6.1.8.3. Defining and Protecting Judicial Independence

Judicial independence is a foundational principle of Canada’s constitutional democracy. It ensures that judges are free to decide cases impartially, based on the law and evidence, without interference from political actors or public opinion.⁷⁵⁵ This principle extends not only to rulings, but to judicial education. While it is legitimate for governments to require judges to receive training in certain subject areas, they must not prescribe or approve the specific content of that training. To do so would risk undermining the institutional independence of the judiciary, and by extension, public confidence in the justice system.

As the Canadian Bar Association, the Canadian Judicial Council, and the Supreme Court of Canada have all affirmed, judicial independence exists not to insulate judges from accountability, but to protect the integrity of the court as a neutral decision-maker.⁷⁵⁶ The public rightly expects judges to be knowledgeable about complex issues such as IPV, trauma, and coercive control—but training must be developed and delivered by the judiciary itself, free from political influence or public pressure.

6.1.8.4. Legislative Parameters Without Content Interference

Several witnesses suggested that Ontario could go further in structuring judicial education without violating independence. Options include setting minimum numbers of hours, and requiring that certain training modules be delivered in-person or in interactive formats, rather than through self-directed study.

These measures would preserve content autonomy while reinforcing public accountability. Importantly, any such framework must be crafted cooperatively—for example, in consultation with the Chief Justices of the Ontario Court of Justice and Superior Court. The legislature has the authority to set procedural parameters; what it cannot do is interfere with curriculum content or evaluative discretion.

6.1.8.5. Judicial Leadership and System Accountability

The Committee encourages Ontario’s judiciary to demonstrate leadership in this area. True judicial independence carries with it a responsibility: judges must ensure that they remain informed about the legal and social context of the cases they hear. Several members of the judiciary have acknowledged that while they are experts in law, they are not always experts in the psychology of abuse, the mechanisms of coercive control, or the impacts of trauma on memory and demeanour.

Ontario’s judiciary is uniquely placed to internally champion trauma-informed, IPV-specific, and evidence-based education—and to do so voluntarily and proactively, beyond the minimum expectations of Keira’s Law. By strengthening internal training through the Ontario Court Education Secretariat or NJI and engaging with experts and survivor advocates in curriculum design, the judiciary can demonstrate both independence and responsiveness.⁷⁵⁷

Judicial independence is not a shield against improvement. It is the foundation from which the judiciary can lead reform, on its own terms, in its own voice. Public confidence will be strengthened—not eroded—when the judiciary takes further ownership of its educational direction and affirms its commitment to safety, competence, and justice for families across Ontario.

6.1.8.6. Training for Other Family Justice Professionals

While much of this discussion has focused on the judiciary, the Committee notes that training is urgently needed for all professionals in the family justice system. This includes Children’s Aid Society workers, Office of the Children’s Lawyer counsel, family mediators, custody assessors, and social workers. These professionals often make critical recommendations or decisions in high-risk cases, yet few are required to undergo IPV-specific or trauma-informed training.

As of 2013, the OCL had revised its panel agent agreements to include mandatory training obligations, with attendance monitored and factored into agent performance reviews. Agents who missed required sessions were contacted and expected to attend make-up sessions.⁷⁵⁸ Although it remains unclear whether this training consistently covers IPV or coercive control, the existence of this infrastructure reinforces the feasibility of mandating such content in future. In contrast, assessors appointed under Section 30 of the CLRA are not required to complete any standardized training or professional development, nor is there a mechanism to track or enforce it.

A coordinated, system-wide education framework would improve safety, consistency, and efficiency. It would reduce bias and confusion, improve inter-professional trust, and ensure that survivors and children encounter a system that understands the complexity of abuse—not one that misinterprets it. Additional details and policy options are provided in the recommendations section of this report.

But as witnesses noted, training must be comprehensive, routinely updated, and expanded to all professionals in the family justice system.

Victims’ advocates repeatedly stressed that when judicial and court professionals lack trauma-informed awareness, survivors are more likely to be perceived as “hysterical,” hostile, or uncooperative. This can distort risk assessments and lead to parenting time and decision-making orders that ignore warning signs or misinterpret legitimate fears as manipulation. Strengthening education on IPV, coercive control, and child-centred approaches is a foundational requirement for safety and fairness in Ontario’s family courts.

6.1.9. Barriers for Victims in Family Court

6.1.9.1. Structural Complexity and Procedural Burden

Navigating Ontario’s family court system is difficult for anyone—but for victims of IPV, it is often insurmountable without support. The legal process is lengthy, complex, and emotionally taxing, and it unfolds at a time when victims are also dealing with trauma, unstable housing, childcare disruptions, and safety concerns.

The procedural architecture of family court is daunting: it includes a labyrinth of forms, rules, and timelines, with multiple appearances, motions, and case conferences that can stretch over months or years. Each appearance brings fresh risk of exposure to the abusive ex-partner. Victims often must sit in shared waiting areas or attend mediation sessions with the person who harmed them. As one Committee witness noted, repeated adjournments and procedural delays “prolong their trauma” and leave them feeling trapped in ongoing litigation.

For unrepresented victims, the court process is opaque and unforgiving. Self-represented litigants must prepare affidavits, respond to motions, and present evidence under complex evidentiary rules. Even highly capable litigants struggle without legal training—but trauma, fear, and exhaustion compound the difficulty. One misstep (such as missing a filing deadline or failing to object properly) can seriously jeopardize the case. In some instances, victims are required to cross-examine their abuser or be cross-examined by them. While this has been limited in criminal court, it still occurs in family matters.

6.1.9.2. Legal Representation and Financial Disparity

Access to legal representation is one of the most significant barriers for victims. Protracted family law disputes are prohibitively expensive, and many victims fall into the “justice gap”—ineligible for Legal Aid Ontario (LAO) due to modest earnings, yet unable to afford private counsel. As of 2024, LAO compensates family lawyers at approximately $135–$150 per hour⁷⁵⁹; market rates for similarly experienced lawyers are $300–$400 per hour. Many experienced lawyers decline to accept legal aid certificates due to low tariffs and administrative burdens.

Even when victims do qualify for legal aid, finding a lawyer may be difficult—and legal aid certificates often do not cover full proceedings. Abusers, by contrast, often have greater capacity to retain private counsel using personal income or via their control of marital assets. The result is a stark imbalance of power. In courtroom settings, the represented party is often better equipped to marshal evidence, frame arguments, and influence tone. This imbalance can subtly or overtly shape judicial outcomes—especially in high-conflict or credibility-sensitive cases.

Victims who are self-represented face profound disadvantages in evidentiary and procedural matters. They may struggle to introduce police records or medical documentation in admissible form, or to challenge improper questions. Without a lawyer, their voice—and their safety—can be lost in the process.

6.1.9.3. Systemic Bias and Myths in Family Court

Despite increased awareness, persistent misconceptions about IPV continue to influence family court culture. Some decision-makers still assume that abuse must have been exaggerated if a victim stayed, or that it has no bearing on parenting if the children were not directly harmed. As previously discussed, concepts like parental alienation are sometimes invoked in ways that discredit protective parents—particularly mothers—shifting the court’s focus away from abuse and toward perceived non-cooperation or hostility. This occurs in a context where many courts appear to start from an expectation of shared parenting or equal time, even in high-conflict or IPV-related cases.

In this environment victims must not only prove the abuse, but also prove that they are not manipulative, alienating, or emotionally unstable. The adversarial nature of family court compounds the challenge. Trauma can impact memory, demeanour, and presentation—factors that may be misread as evasiveness or irrationality. As multiple advocates testified, courts sometimes mistake trauma symptoms for poor credibility.

6.1.9.4. Safety, Accessibility, and Language Barriers

Even basic courtroom logistics can be unsafe for victims. Many courthouses lack separate waiting areas or staggered scheduling, meaning victims may encounter their abuser repeatedly throughout the day. Travel to court can be difficult if the victim is living in a shelter or without stable transportation. Language is also a barrier: proceedings are often conducted in formal English or French, and interpretation is not always available at every stage. Victims with limited literacy, disability, or different first languages may face added hurdles in understanding and participating fully in their own case. As the Barbra Schlifer Commemorative Clinic and others noted, navigational support is necessary⁷⁶⁰, and many give up or settle for inadequate arrangements just to escape the court ordeal.

6.1.9.5. The Role of Family Court Support Workers (FCSWs)

One program that has proven effective in supporting IPV victims is the Family Court Support Worker (FCSW) Program. Ontario’s FCSW Program was launched in 2011 by the Ministry of the Attorney General to provide victims of IPV with practical, emotional, and procedural support during family court proceedings.⁷⁶¹ It funds community-based victim service agencies across the province to hire and supervise support workers who operate alongside but independently from the court system, helping victims navigate legal processes safely and effectively. It has received $2 million dollars a year since its inception, initially funded through the Victims’ Justice Fund. The program continues to be funded by the Ontario government, with allocations directed through the Ministry of Children, Community and Social Services. There have been no documented increases to this funding.

FCSWs assist with a range of functions, including explaining the court process, reviewing legal documents, helping victims prepare for court dates, providing safety planning related to court appearances, coordinating with shelters or legal aid, and attending court as support when appropriate.⁷⁶² They also help clients understand protection options, debrief outcomes, and link them with other services such as housing or trauma counselling. The service is free and universally accessible to victims, regardless of income or immigration status.

Luke’s Place was instrumental in pioneering the FCSW model. Prior to 2011, it operated Ontario’s first stand-alone family court support centre for abused women, developing the legal support model that eventually shaped the provincial program.

The FCSW Program is currently delivered through over 40 local victim services agencies. Training is centralized and coordinated by Luke’s Place, which has been the lead training provider since the program’s inception.⁷⁶³ Luke’s Place offers a province-wide training curriculum (updated annually), a secure online portal for peer support and resource sharing, and direct technical assistance to workers and their supervisors. French-language training is provided in partnership with Action ontarienne contre la violence faite aux femmes. Despite its success, FCSWs are often overstretched. Many agencies are funded for 0.5 or 0.25 of a full-time position, leaving large rural or northern catchment areas underserved.⁷⁶⁴

Most FCSWs are recruited through the community or victim services sector and trained in-house. There is no dedicated college credential or certification path for the role. However, graduates of related diploma programs—such as Court Support Services, Social Service Worker, or Community Worker programs—often possess transferable skills.⁷⁶⁵ These programs are offered at institutions such as Fanshawe College, Humber College, George Brown College, and Centennial College, and include instruction in trauma, law, and advocacy work.⁷⁶⁶ Recruitment for FCSWs remains challenging, particularly in rural or remote areas, where legal familiarity, trauma training, and cultural competency must all converge in a single hire.

Although no formal outcome evaluation framework exists at present, anecdotal and service-level reporting indicates that FCSWs have a measurable impact on both victim outcomes and system performance. They reduce re-victimization risk, improve legal comprehension, and contribute to more organized, less adversarial court processes. The Committee heard multiple testimonies confirming that FCSWs improve survivor safety, reduce re-traumatization, and support system efficiency—all while operating on very modest funding.

6.1.9.6. Legal Aid and FCSWs as Efficiency Infrastructure

The resource limitations facing Legal Aid Ontario (LAO) and the geographic and staffing constraints of the Family Court Support Worker (FCSW) Program are not only issues of access or fairness—they are structurally linked to the performance of Ontario’s family court system.

Self-representation in IPV-related family law matters contributes to court delays, increased demands on judicial time, and inefficient use of legal resources. The Department of Justice Canada report, Making the Links in Family Violence Cases reviewed a study estimating the total cost of spousal violence to the Canadian justice system in 2009 at $545.2 million.⁷⁶⁷ Adjusted for inflation, that figure would now exceed $780 million annually in Canadian justice system costs alone—without accounting for healthcare, social services, or lost productivity.

The report also notes that unrepresented litigants often assume judges are aware of criminal convictions or no-contact orders from parallel proceedings—when in reality, such information may never be entered into the family court record.⁷⁶⁸ This gap can lead to orders that inadvertently place victims or children at risk, or create conflicting legal directives that must be resolved at further expense to the system.

Additional research has linked access to legal assistance with a range of improved outcomes for victims, including lower rates of repeat violence, greater housing and employment stability, and reduced reliance on emergency services, shelters, and police interventions. Committee testimony and written submissions emphasized that victims who receive early, comprehensive support—whether through legal aid, FCSWs, or both—are more likely to resolve their cases efficiently, without protracted motion practice, discovery disputes, or repeated court attendance.

These findings support the conclusion that legal aid and FCSWs are not merely access-to-justice tools—they are part of Ontario’s justice system efficiency infrastructure. Where they are available and adequately funded, they reduce burdens on judges and court staff, streamline proceedings, and enable faster, more consistent resolution of family disputes. In a justice system where court time is finite and backlogs affect all users, the benefits of early support extend well beyond individual litigants.

6.1.9.7. FCSWs and Legal Aid: Complementary, Not Substitutes

Even with expanded access to legal aid, the role of FCSWs remains indispensable. Legal aid lawyers manage legal strategy and represent clients before the court—but FCSWs provide the wraparound, day-to-day support that lawyers are neither mandated nor resourced to deliver. This includes emotional support, assistance with organization and documentation, accompaniment to court, coordination with shelters or child services, and help managing the non-legal consequences of the family court process.⁷⁶⁹

FCSWs are also critical for victims who decline legal representation due to trauma, distrust, fear of reprisal, or cultural and language barriers. These victims—who may still need to attend court, respond to filings, or prepare evidence—rely on FCSWs as navigators and stabilizers in an unfamiliar and high-risk system.

No other province currently operates a program identical to Ontario’s FCSW model. While other jurisdictions have introduced pilot roles (such as family violence navigators or integrated court-based victim supports), Ontario’s model is uniquely structured as a community-delivered but court-facing system, anchored in training partnerships with Luke’s Place and Action ontarienne contre la violence faite aux femmes.

Ontario’s FCSW program is included in the national Inventory of Government-Based Family Justice Services as an example of court-related victim assistance infrastructure. This positions Ontario not only as a provincial leader in victim-centred family justice, but also as a jurisdiction with the potential to model replicable systems for other provinces and territories.

6.1.9.8. Legal Aid: Balance and Screening in Family Law

Ontario’s legal aid system provides legal representation in both criminal and family law matters through a certificate program administered by Legal Aid Ontario (LAO). However, the legal obligations and operational structures underpinning these areas differ substantially.

In criminal proceedings, access to publicly funded legal counsel is constitutionally protected. In R. v. Rowbotham, the Ontario Court of Appeal held that if an accused person is unable to afford a lawyer, and if legal representation is necessary to ensure a fair trial, the court has jurisdiction to stay proceedings until the state provides counsel.⁷⁷⁰ This principle has been affirmed in numerous criminal cases across Canada and frequently appears in practice as a Rowbotham application when legal aid has been declined.

No equivalent right exists in family law. Family disputes, however high-stakes or complex, are treated as private civil matters. There is no constitutional obligation to provide legal representation, even where the outcome may determine where a child resides, how parenting responsibilities are divided, or whether a victim of IPV must co-parent with an abusive former partner.

Ontario funds both criminal defence and family law services through LAO’s certificate program. In both cases, compensated rates are substantially below private market rates. Family law lawyers working under LAO certificates also typically earn between $135 and $150 per hour—compared to private market rates of approximately $300 to $400 per hour.⁷⁷¹

There are, however, other aspects of billing that make working under LAO certificates more feasible in the criminal court system than the family court system. LAO permits block billing in many criminal cases, allowing lawyers to receive a fixed fee for defined legal tasks—such as conducting a bail hearing, resolving a case with a guilty plea, or completing a trial. This model improves predictability and financial viability for lawyers, particularly in high-volume practices where the time required to prepare and administer each case might otherwise exceed the available compensation. By contrast, family law lawyers working under LAO certificates must bill hourly for nearly all tasks, including disclosure review, client meetings, motion preparation, and court appearances. There is no equivalent block billing structure. LAO imposes strict limits on the number of billable hours per certificate depending on case type, with some family law matters capped.⁷⁷² In complex matters—particularly those involving IPV, coercive control, or safety planning—this structure becomes financially unsustainable for the lawyer providing representation.

As a result, it has become increasingly difficult to find qualified family law lawyers willing to accept legal aid certificates, especially in rural and remote regions. These billing structures reflect the institutional realities of each system. Criminal law is anchored in constitutionally protected liberty interests and a long-standing infrastructure for publicly funded defence. Family law, by contrast, lacks any equivalent framework—even where the stakes include child safety, housing stability, and protection from ongoing abuse.

While Rowbotham remains foundational to criminal legal aid, it has no application to civil or family proceedings. This report does not suggest otherwise, nor does it endorse the creation of new entitlements. Rather, it observes that the same legal system which guarantees state-funded counsel to those accused of violence does not guarantee equivalent assistance to those navigating the consequences of it. That distinction is legally justified but sits uncomfortably next to more modern public policy objectives around victim rights and safety, fairness, system efficiency, and cost containment.

The rationale for legal aid in family law need not rely on constitutional grounds. In IPV-related family proceedings, publicly funded representation may offer a demonstrable return on investment. Without counsel, victims may be unable to present evidence, respond to motions, or enforce orders—leading to prolonged litigation, repeated court appearances, and increased reliance on emergency supports such as shelters or social assistance. These are public costs, even if they are not counted within the legal aid budget. Ensuring early access to competent legal help can reduce downstream expenditures, promote court efficiency, and improve safety outcomes.

LAO does provide several free supports related to family law⁷⁷³:

1. A two-hour advice lawyer program, available free to anyone experiencing domestic violence, regardless of income;
2. A network of community legal clinics, which serve the general public and may assist with family law or provide referrals;
3. Family Law Information Centres (FLICs) at courthouses, which also serve the public and offer basic legal information or connections to services.

These services are valuable but do not replace full representation. Moreover, awareness of them remains inconsistent. Victims often turn to police, shelter staff, or court personnel—many of whom may not know about available supports. Courthouse signage is often absent or outdated. Means by which to improve referral and awareness will be addressed in the forthcoming section on the Ontario Integrated Violence Prevention and Response Network.

Testimony before the Committee focused on the need for expanded legal aid access for IPV victims. However, most submissions emphasized funding needs without offering detailed guidance on intake models, eligibility thresholds, or screening tools. These components are critical to any future investment. There are multiple policy mechanisms available to the province—including raising the eligibility threshold for IPV victims, increasing the hourly billing rate for family law lawyers, and exploring whether block billing models can be adapted to the structure of family law. Any one or more of these steps would represent a significant increase in public expenditure. While this report notes that targeted legal aid investment for IPV victims may deliver long-term system savings, such investment must be accompanied by careful screening to ensure that assistance is directed to those at highest risk.

The Committee acknowledges that LAO has developed a Domestic Violence Strategy, which identifies IPV as a core area of service and outlines commitments to screening, client support, and partnerships.⁷⁷⁴ However, no public documentation describes current screening protocols, nor the process by which intake staff are trained or evaluated. This may be intentional. Some degree of confidentiality in the screening process may help preserve the integrity of intake assessments and reduce the risk of tailoring responses. While there is no evidence that this is occurring at scale, it remains a consideration in any system that seeks to balance access with fiscal accountability.

However, the lack of insight into screening procedures limited the Committee’s ability to assess how eligibility thresholds, training models, or intake processes could be amended to support targeted legal aid expansion for IPV-related family law matters.

Of note, Ontario benefits from leading expertise in this area. Luke’s Place and the Barbra Schlifer Commemorative Clinic have provided training, screening, and legal support for IPV victims for decades. Luke’s Place is widely recognized for its role in developing the Family Court Support Worker Program and has partnered with successive governments to advance IPV-responsive legal services. However, both organizations are largely based in urban centres. Any future screening framework will require geographic and cultural adaptability, including input from rural, remote, Indigenous, and newcomer communities.

Additionally, the Centre for Research and Education on Violence Against Women and Children (CREVAWC), based at Western University, has been instrumental in advancing family court responses to IPV. Through its Family Violence & Family Law (FVFL) initiative, CREVAWC has developed resources and guides to support best practices for family courts in recognizing and considering family violence. This includes promoting standardized screening tools and providing learning opportunities to build the capacity of family law professionals to respond effectively to family violence.⁷⁷⁵

6.2 Recommendations

6.2.1 Recommendation 1: Establish a Legislative Subcommittee on Family Law and Court Modernization

Context and Purpose: Ontario’s family court system has been the subject of repeated study, audit, and reform recommendations over more than two decades. Despite this sustained attention, no single body has been responsible for tracking the implementation of past recommendations, coordinating modernization efforts, or ensuring public accountability for the pace and direction of reform.

A legislative subcommittee—struck under the Standing Committee on Justice Policy or its equivalent—would provide a dedicated, transparent, and democratically accountable mechanism for reviewing family court operations, identifying structural barriers, and recommending phased improvements. This would be established through the House Leaders’ Office and Standing Orders. No legislative change is required. The model follows the successful structure used by this Committee, with clerical and research support from the Assembly and public accountability through elected members.

Recommendation Details: The Government of Ontario should create a legislative subcommittee on Family Law and Court Modernization with a mandate to:

1. Review all outstanding, partially implemented, or untracked recommendations from major family law reports and audits, including those related to court operations, legal services, and access to justice;
2. Identify where implementation has occurred, where efforts have stalled, and where circumstances have evolved since the original recommendations;
3. Gather testimony from experts, ministries, service providers, and families to assess practical barriers and new challenges post-pandemic;
4. Identify opportunities to improve longitudinal data collection and information-sharing protocols between family and criminal courts in IPV cases, in support of better risk assessment, coordination, and policy development;
5. Recommend a phased, cost-conscious roadmap that aligns with operational realities, regional disparities, modernization priorities, and return on investment.

Hearings and Process Design: The subcommittee should follow a phased model:

• Phase 1 – Expert Testimony: Academics, legal professionals, victim advocates, and service providers;
• Phase 2 – Victim and Litigant Testimony: Modeled after this Committee’s Phase 3, with opportunity for confidentiality;
• Phase 3 – Ministerial and Operational Witnesses: Including the Ministry of the Attorney General, the Ministry of Children, Community and Social Services, LAO, the judiciary (as appropriate), and OCL.

A hybrid appearance model should be used. In addition to direct invitations, the subcommittee should open applications to appear via a public portal. Applications should be reviewed and approved by vote for a set number of slots, supported by legislative clerks.

Scope of Study: While the committee should retain flexibility in setting its own agenda, the subcommittee’s core focus should be on structural and operational questions that fall outside the mandate of this report. This includes:

• Implementation Tracking: Reviewing which recommendations from past audits, consultations, and strategy documents have been completed, which remain outstanding, and which require reassessment in light of post-pandemic realities;
• Modernization Alignment: Evaluating whether current family court modernization efforts—such as digital transformation, UFC expansion, and service integration—are being implemented effectively and equitably across regions;
• System Navigation and Role Clarity: Identifying opportunities to simplify and streamline how families, legal professionals, and service providers interact with overlapping court systems and statutes;
• Governance and Accountability: Clarifying lines of responsibility across ministries, agencies, and levels of court, particularly in relation to program oversight, performance metrics, and cross-sector coordination;
• Infrastructure and Workforce Planning: Assessing long-term needs for courthouse infrastructure, judicial and staff capacity, and regional service equity—especially in fast-growing or under-served areas.

The purpose of this review is not to repeat subject-matter analysis already conducted by this Committee, but to develop a system-wide map of Ontario’s family justice landscape: what has changed, what remains fragmented, and what reforms will yield the greatest return on public investment.

Implementation Considerations:

• The subcommittee should be struck during the current legislative session;
• A preliminary report outlining the implementation status of past recommendations should be tabled within 12 months of the subcommittee’s first meeting;
• A final report should include costing scenarios, phased reform options, and accountability mechanisms;
• Work should be supported by Legislative Assembly research staff and clerks, as is standard.

Rationale: Ontario’s family court reform efforts have been sustained but disjointed. Some initiatives are complete, others were never fully implemented, and many lack ongoing tracking. The absence of a clear, system-wide modernization plan leaves ministries without a unified direction and contributes to resource strain, inefficiencies, and gaps in public accountability.

This subcommittee offers a low-cost, governance-focused way to bring clarity to what has been tried, what has worked, and what remains undone. It avoids duplication, empowers elected officials to drive modernization, and delivers a coherent map for the future—rooted in democratic accountability, operational effectiveness, and responsible stewardship of public funds.

6.2.2 Recommendation 2: Expand and Stabilize the Family Court Support Worker Program

Context and Purpose: The Family Court Support Worker (FCSW) Program provides essential assistance to victims of IPV navigating the family court system. Support workers offer safety planning, court accompaniment, procedural guidance, and referrals to legal and community resources. The service is low-barrier, trauma-informed, and widely praised by victims and service providers for improving safety and reducing court-related stress.

While the program operates province-wide through more than 40 delivery agencies, coverage remains uneven—particularly in rural and remote regions. In many jurisdictions, victims are served by the equivalent of only 0.25 or 0.5 of a full-time worker. Waitlists and triaging are common, and some communities receive services only on an itinerant basis. These gaps are especially acute in areas where legal aid is also scarce.

The program is funded by the Ministry of Children, Community and Social Services (MCCSS), primarily through the Victims’ Justice Fund. However, its annual funding allocation has remained effectively flat at approximately $2 million since its inception in 2011. Adjusted for inflation and population growth, current funding levels fall significantly short of demand.

The Committee believes that stabilizing and expanding the FCSW Program is an urgent and cost-efficient step toward improving both survivor outcomes and overall court system efficiency.

Jurisdiction: This recommendation falls under provincial jurisdiction. The FCSW Program is currently administered by MCCSS and funded through the Victims’ Justice Fund, a special purpose account derived from provincial victim fine surcharges.

Recommendation Details: The Government of Ontario should:

• By the next budget cycle, increase the annual base funding for the FCSW Program to $3.47 million, reflecting both inflation and population growth since the program’s 2011 $2 million benchmark. This figure represents a stabilized funding floor, not a one-time top-up, and should serve as the revised annual baseline while further regional needs and access gaps are assessed;⁷⁷⁶
• Ensure this inflation-adjusted base funding becomes a permanent recurring allocation;
• Commit to indexing FCSW funding to inflation in future years;
• Explore whether the Victims’ Justice Fund remains the most appropriate long-term funding mechanism, or whether additional funding sources should be considered (e.g., Ministry base funding or other justice reinvestment models);
• Begin working with service providers and the proposed Ontario Integrated Violence Prevention and Response Network (OIVPRN) to conduct a province-wide access and equity gap analysis and develop a standardized funding formula. This funding formula should:
  • Link resource allocations to population size within each OIVPRN-defined geographic catchment;
  • Include standardized rurality and remoteness modifiers to apply to the funding formula, to account for delivery costs in low-density or fly-in regions;
• Support long-term workforce stability by ensuring that staffing levels reflect local need, geography, and service capacity.

Implementation Considerations:

• Adjusted base funding should be reflected in MCCSS allocations within the next provincial budget cycle;
• Catchment-based planning and requisite population data should be coordinated with the development of OIVPRN;
• MCCSS should collaborate with MAG to clarify expectations around FCSW roles, data practices, and coordination with legal sector partners—including FLICs, duty counsel, and other courthouse-based services;
• Ongoing stakeholder engagement should prioritize consistency, role clarity, and cross-sector alignment (e.g., legal clinics, victim services, FLICs).

Rationale: The FCSW Program offers a high return on investment. When victims receive support in navigating court documents, preparing for hearings, and connecting to legal and community services, cases move more efficiently, adjournments are reduced, and safety outcomes improve. For many victims—especially those without legal representation—an FCSW may be the only consistent source of court navigation support.

FCSWs are not a substitute for legal representation. Their role is complementary: providing practical, emotional, and procedural assistance that improves system navigation and enables survivors to participate more effectively in legal processes.

Expanding and stabilizing this program reduces strain on court resources, increases access to justice, and enhances safety—all while maintaining a lower cost profile than more intensive interventions such as legal aid or shelter use.

6.2.3 Recommendation 3: Improve Judicial Education on Intimate Partner Violence and Coercive Control

Context and Purpose: Judicial independence is a foundational principle of Ontario’s legal system. Judges must be free to interpret the law and make decisions without external influence. But independence does not preclude accountability. Like all professionals, judges are expected to stay informed on the issues most likely to affect the people before them.

In family law, this includes the dynamics of IPV, coercive control, trauma, and post-separation risk. Without current, evidence-informed education, there is a risk that abuse may be misunderstood or minimized—particularly in cases involving litigation misuse, parenting disputes, or non-physical forms of control.

Keira’s Law (federal Bill C-233) and its provincial counterpart under the Strengthening Safety and Modernizing Justice Act, 2023, established an expectation that new judicial appointees receive training in IPV and coercive control. But the current legislative framework is limited. There are no formal expectations for refresher training, no defined timeframes, and no requirement to report on participation rates. This recommendation proposes a measured legislative update to strengthen structural consistency while fully preserving judicial independence and judicial discretion over training content.

Jurisdiction: The Courts of Justice Act governs provincially appointed judges in Ontario. The Ministry of the Attorney General cannot dictate training content but can set participation parameters by statute. Federally appointed judges are governed by the Judges Act and the Canadian Judicial Council. While Ontario cannot legislate federal judges, it can encourage parallel federal reforms to ensure province-wide consistency.

Recommendation Details: The Government of Ontario should:

• Amend section 43.1 of the Courts of Justice Act to include structural parameters for judicial education on IPV and coercive control. These should include:
  • A requirement that training be completed within 120 days of appointment;
  • A requirement that refresher training be made available to all sitting judges at least once every three years;
  • A requirement that anonymized participation statistics be published annually by the Chief Justice of the OCJ;
• Ensure that any amendment developed is crafted in consultation with the judiciary and clearly distinguishes participation structure from content development;
• Encourage the judiciary to continue offering both in-person and online formats, tailored to the needs of judges, justices of the peace, and per diem appointments;
• Support institutional leadership by calling on the Chief Justices to expand access to IPV-focused education across all court levels, including family, child protection, and criminal chambers.

Federal Alignment:

• The Government of Ontario should formally call on the federal government to amend the Judges Act in parallel, ensuring that federally appointed judges in Ontario are subject to the same structural expectations for IPV training;
• This request should include: timeframe requirements for initial training; development of refresher training cycles; a commitment from the Canadian Judicial Council to publish anonymized participation data.

Implementation Considerations:

• The proposed amendment to the Courts of Justice Act must be narrowly scoped to avoid encroaching on judicial discretion;
• Language should mirror frameworks already accepted by the judiciary, such as the reporting model under Bill C-3 (sexual assault training);
• Annual reporting can be embedded in the Chief Justice’s Annual Report or equivalent judiciary-led publication.

Rationale: Mandatory education for new appointees is an important step—but it is not enough. Victims and families must have confidence that all judges hearing family, child protection, or IPV-related matters are equipped with current knowledge about abuse dynamics and coercive control. Structured expectations around timing and participation will ensure consistency without interfering in judicial decision-making.

By proposing a narrow, principled amendment to the Courts of Justice Act, Ontario can strengthen transparency, reinforce judicial independence through self-directed leadership, and position itself as a national leader in IPV-responsive justice reform. A parallel federal amendment to the Judges Act would extend these benefits to all judges sitting in Ontario courts, creating clarity and coherence across the family justice system.

6.2.4 Recommendation 4: Establish IPV-Specific Training Requirements for Section 30 Parenting Assessments and Implement a Public Roster of Approved Assessors

Context and Purpose: Parenting assessments under Section 30 of the Children’s Law Reform Act can significantly shape the outcome of custody and access disputes. These assessments are often treated as expert evidence and may influence judicial decision-making on parenting time, decision-making authority, and even allegations of abuse or alienation. Ontario currently does not require that assessors under Section 30 receive specific training in IPV, coercive control, trauma, or child development in violence-exposed families. Courts may appoint “any person who has technical or professional skill,” but there is no statutory requirement for specialized competencies in these domains. While Section 30 assessments are relatively uncommon, testimony before the Committee emphasized that this lack of baseline requirements may lead to inconsistent assessments—particularly in high-conflict or abuse-related matters. Misinterpretation of trauma responses, protective behaviour, or coercive control dynamics can significantly impact risk assessment and parenting recommendations.

Ontario already has a viable structural model for oversight of family court clinicians: the Office of the Children’s Lawyer (OCL) maintains a panel of independent social workers and psychologists who conduct parenting investigations under Section 112 of the Courts of Justice Act. Although not government employees, these clinicians are vetted, trained, supervised, and periodically reviewed. Their reports cannot be filed without approval. While not perfect, this model demonstrates that Ontario has previously implemented centralized infrastructure that could inform a longer-term approach to public oversight of assessors.

Jurisdiction: Section 30 of the Children’s Law Reform Act is provincial legislation. The Ontario government has full authority to amend it in order to set qualifications, mandate training, and define appointment conditions. Mandatory training standards may also be implemented through regulation/legislation.

Recommendation Details: The Government of Ontario should adopt a two-phase implementation strategy to improve the quality, safety, and consistency of Section 30 assessments.

Phase 1: Mandate IPV-Specific Training

Amend the CLRA (or associated regulations) to require that no person may be appointed under Section 30 unless they have completed specialized training. Specialized training should include a minimum of 16 hours focused on domestic violence and trauma-informed child assessment, to be completed within a 12-month period. Training should include instruction on:

• Structuring the evaluation process to maximize safety for all participants, maintain objectivity, and ensure impartial fact-gathering from both parties;
• The effects of IPV, coercive control, and post-separation abuse on children and parenting dynamics;
• Recognizing the relationship between child physical abuse, child sexual abuse, and IPV;
• Understanding intergenerational transmission of family violence;
• Identifying manifestations of PTSD and trauma responses in children exposed to violence;
• Conducting separate parent interviews or sessions at different times;
• Strategies to control for bias and balance information gathering.

An additional 4 hours of annual update training thereafter, focused on changes in local court practices, case law, and legislation related to family violence and parenting evaluations; updates to social science research and theory regarding the impact of family violence on children. Courts should confirm that any assessor appointed under Section 30 has completed these training requirements.

Phase 2: Explore a Public Roster Model

Following the implementation of training standards, the government should explore the establishment of a public provincial roster of Section 30 assessors who meet the required qualifications and training obligations. This roster should be searchable by region and professional designation; be made available through court offices, FLICs, and a publicly accessible, searchable webpage or directory; and be maintained by the Ministry or its designate, with renewal every three years. Explore assigning responsibility for roster administration to the OCL, building on its existing infrastructure for clinician screening, training, and supervision.

Implementation Considerations:

• Training providers should be approved by the Ministry of the Attorney General or a delegated accreditor (e.g., professional college, judicial training body, or designated NGO with relevant expertise);
• Certificates of completion should be required prior to court appointment and subject to renewal through update training;
• A one-year grace period should be provided to allow current assessors to complete the required training without disruption to services;
• Training delivery should prioritize pedagogical quality and incorporate interactive components (e.g., case study analysis, trauma-informed interviewing);
• The Ministry should explore partnership models with existing providers (e.g., Luke’s Place, CREVAWC, Barbra Schlifer Commemorative Clinic) to scale delivery and ensure subject-matter integrity;
• Roster management will require modest but dedicated funding to support intake, renewal, database maintenance, and compliance tracking;
• A publicly accessible website listing approved assessors, searchable by region and profession should be live within one year of the assessor approval process coming into force;
• Legal Aid Ontario may need to update its certificate eligibility rules and billing protocols to reflect the new training requirement for Section 30 assessors.

Rationale: Section 30 assessments are among the most influential forms of evidence in Ontario’s family courts—yet assessors currently operate without regulatory oversight, training mandates, or public accountability. This lack of structure has allowed wide variability in quality, increased risk to vulnerable parties, and undermined public trust in family court outcomes.

Ontario’s existing model for OCL clinical investigations shows that it is entirely feasible to hold independent professionals to consistent standards while preserving their autonomy. Extending this model to Section 30 assessments would improve quality, safety, and transparency without interfering with judicial discretion. It would also support party choice by providing a clear, vetted list of qualified professionals—particularly critical for self-represented litigants who currently have no way to assess assessor credibility.

This recommendation strikes a balance between flexibility and accountability. It ensures that anyone tasked with evaluating a family’s most sensitive dynamics meets a transparent, consistent, and publicly known threshold of professional readiness.

6.2.5 Recommendation 5: Develop a Standardized IPV Training Framework for Family Law Professionals and Court-Appointed Assessors

Context and Purpose: Throughout its hearings, the Committee heard consistent and credible concerns about the lack of IPV-specific training among professionals who operate in or adjacent to family court. These include court-appointed assessors, mediators, parenting coordinators, Office of the Children’s Lawyer (OCL) clinicians, and others whose actions influence high-stakes decisions about child safety and parenting arrangements. Without consistent training, even well-intentioned professionals may misinterpret trauma responses, overlook patterns of coercive control, or contribute to unsafe outcomes.

While calls for “mandatory training” are common, the Committee recognizes that implementing a training regime across multiple sectors and professional regulatory bodies is far from simple. Different roles are governed by different authorities, and implementation mechanisms must respect judicial independence, professional self-regulation, and sectoral variation. This recommendation reflects those constraints while offering a clear, structured approach to building a scalable, system-wide IPV training framework.

Jurisdiction: This recommendation falls within provincial jurisdiction but must be co-developed across sectors. Key stakeholders include the Ministry of the Attorney General; Legal Aid Ontario (LAO); the Law Society of Ontario (LSO); the Office of the Children’s Lawyer (OCL); and any entity responsible for approving or appointing mediators, assessors, or clinicians in family court contexts.

The government may have authority to mandate training for some roles (e.g., through rosters or procurement conditions), but in many cases, implementation will rely on cooperation with professional regulators and delegated bodies.

Recommendation Details: The Government of Ontario should work with expert partners to develop a standardized IPV-specific training framework that includes:

• Mandatory baseline training for professionals who are appointed or approved by government-related processes (e.g., Section 30 assessors, OCL clinicians);
• Role-specific content covering IPV, coercive control, trauma-informed practice, intersectional risk factors, and case law developments;
• Refresher modules available at regular intervals (e.g., every three years);
• Delivery options that include both online and facilitated components, with attention to engagement and quality—not just check-the-box compliance.

The Committee further recommends that the Ministry of the Attorney General:

• Investigate whether a centralized mechanism is needed to coordinate delivery and track completion of IPV training for relevant professionals (e.g., assessors, mediators, court-connected clinicians). This mechanism could involve leveraging existing systems—such as the LSO Continuing Professional Development portal, Ontario Victim Services Learning Portal, or OCL infrastructure—rather than developing a new platform;
• Convene a working group to identify delivery partners, develop credentialing protocols, and determine what, if any, legislation or regulation is required to support implementation;
• Use regulatory levers only where appropriate and feasible, such as through roster inclusion criteria, procurement agreements, or funding conditions.

Implementation Considerations:

• Training for Section 30 assessors should be linked to the roster and quality framework proposed in Recommendation 4;
• The Ministry should avoid defaulting to passive online modules unless paired with interactive or evaluative components. The goal is engagement, not checkbox compliance;
• The government should retain oversight of training standards, but delivery may be contracted to qualified expert organizations, such as Luke’s Place, CREVAWC, or the Barbra Schlifer Commemorative Clinic;
• The question of long-term delivery infrastructure, credentialing, and evaluation should be referred to the proposed legislative subcommittee on family law and court modernization (see Recommendation 1);
• Implementation will be iterative and must account for professional governance structures, cost-effectiveness, and evolving case law.

Rationale: Training is often presented as a simple solution to complex institutional failures. It is not. Meaningful training requires thoughtful design, credible delivery, regular updating, and built-in quality control. The Committee does not underestimate these challenges. But in a system as high-stakes as family court, failure to train consistently is no longer acceptable.

Rather than proposing a single “training mandate” imposed across all professions, this recommendation offers a structured approach that is principled, pragmatic, and feasible. It encourages government leadership, sector engagement, and respect for professional governance, while ensuring that system-appointed professionals meet a baseline understanding of IPV, coercive control, and trauma dynamics.

3.2.5.1 Sub-Recommendation: Encourage the Law Society of Ontario to Provide Complimentary IPV-Focused Continuing Professional Development Programs

Context and Purpose: Lawyers play a pivotal role in family law proceedings involving IPV. While mandating training for lawyers may fall outside the government’s direct authority, the LSO can be encouraged to take proactive steps in this area.

Recommendation Details: The LSO is encouraged to develop and offer free, accredited Continuing Professional Development (CPD) programs focusing on IPV, coercive control, and trauma-informed practices. These programs should be:

• Developed in Collaboration with Experts: Partner with IPV specialists to create comprehensive and up-to-date training materials;
• Accessible Online: Host the training on the LSO’s existing online platform to facilitate easy access for all members;
• Eligible for CPD Credits: Ensure that participation in these programs counts towards the mandatory CPD requirements for lawyers and paralegals.

Rationale: The LSO has the financial capacity to support this initiative. As of 2025, the LSO’s annual fees are: Lawyers: $2,038.92 plus HST; Paralegals: $996.00 plus HST. With a membership comprising over 57,000 lawyers and 10,000 paralegals, the LSO’s annual revenue from membership fees is substantial. Allocating a portion of these funds to develop and provide free CPD programs on IPV is both feasible and aligns with the LSO’s mandate to ensure high standards of learning and competence among its members.

6.2.6 Recommendation 6: Introduce Evidentiary Safeguards Around the Use of Parental Alienation Claims in Family Law Proceedings

Context and Purpose: Parental alienation claims are increasingly raised in Ontario family court proceedings involving parenting time and decision-making. In some cases, these claims reflect legitimate concerns about one parent manipulating the child against the other. But in family law cases involving IPV or coercive control, the dynamic is often far more complex. Victims who act to protect their children may be mischaracterized as “alienating,” leading to custody reversals, court-ordered reunification therapy, or even total loss of contact.

The Committee heard repeated and credible testimony about the chilling effect of alienation claims on abuse disclosure. Stakeholders including Luke’s Place and the Barbra Schlifer Commemorative Clinic documented cases where courts appeared to accept alienation claims without screening for family violence. Academic research supports these concerns. A 2022 study by legal scholar Joan S. Meier found that courts disproportionately disbelieve mothers’ abuse claims when alienation is cross-alleged by fathers.⁷⁷⁷

Jurisdiction: This recommendation falls under provincial jurisdiction. The CLRA governs parenting determinations in Ontario, and the province has authority to amend the Act to introduce evidentiary safeguards. Additional reforms may be implemented through procedural changes to the Family Law Rules—particularly Rule 20.1 (duty of experts) and Rule 20.2 (expert opinion evidence).⁷⁷⁸

Recommendation Details: The Government of Ontario should introduce evidentiary safeguards that require courts to screen for family violence, coercive control, and justified estrangement before admitting or relying on parental alienation evidence in parenting proceedings under the CLRA. These safeguards should not prohibit alienation claims, but should ensure that:

• Where IPV has been alleged or documented, courts must first determine whether the child’s rejection is consistent with justified estrangement or a protective response;
• Expert opinion evidence on alienation must be treated with caution and screened for qualifications and impartiality, especially where the expert has not demonstrated IPV-specific training or regulatory accountability;
• The evidentiary threshold for admitting alienation claims is clear, consistent, and proportionate to the risk of misuse in abuse-related proceedings.

In addition:

• The proposed Family Court Subcommittee (see Recommendation 1) should study the use and misuse of parental alienation claims in Ontario, including the scientific reliability of alienation theory, the role of unregulated experts, and appropriate safeguards under both provincial and federal law;
• The Government of Ontario should consider amending the CLRA and/or the Family Law Rules to clarify when and how alienation evidence may be admitted, and under what expert standards;
• Federal engagement may be pursued following the subcommittee’s review to ensure consistency across UFC proceedings involving the Divorce Act.

Implementation Considerations:

• The Committee recommends a “screen-first” model, in which courts consider family violence and estrangement before admitting or relying on alienation claims;
• The Family Law Rules already provide a foundation through Rule 20.1 (duty of experts) and Rule 20.2 (expert opinion evidence), but may need enhancement to address IPV competence and regulatory standards;
• Legislative or regulatory pathways should be carefully considered with judicial input and sector consultation, recognizing the balance between evidentiary control and judicial discretion;
• This issue should be a priority area of study for the proposed Family Court Subcommittee.

Rationale: Parental alienation, when substantiated, can have serious consequences for children and parents alike. But when alienation claims are raised inappropriately—particularly in the context of IPV or coercive control—they can retraumatize victims, override legitimate safety concerns, and lead to unjust parenting outcomes. Ontario’s current legal framework does not require courts to screen for family violence before admitting or acting on alienation evidence.

This recommendation does not call for banning the concept of alienation, nor does it restrict courts from addressing real cases of manipulation. It simply ensures that such claims are rigorously tested, responsibly contextualized, and not weaponized against protective parents. This is a matter of procedural fairness, evidence-based practice, and child safety.

6.2.7 Recommendation 7: Protecting Children’s Participation Rights in Custody and Access Decisions

Context and Purpose: Children involved in family court proceedings—particularly those affected by IPV—are often sidelined by legal processes that prioritize parental rights, litigation efficiency, or therapeutic interventions over the child’s voice. Ontario is bound by the United Nations Convention on the Rights of the Child (UNCRC), including the obligation to give children the opportunity to be heard in matters affecting them (Article 12), to protect them from violence (Article 19), and to make their best interests a primary consideration (Article 3). But the Committee heard that these rights are not consistently operationalized—especially in cases involving allegations of abuse, parental alienation claims, or proposed changes to a child’s residential placement.

Testimony before the Committee documented instances where children were removed from safe, bonded caregivers or compelled into reunification therapy without having their views meaningfully considered. While courts must retain discretion in parenting matters, the current legal framework does not require courts to assess whether a child’s resistance may reflect trauma, protective instincts, or justified estrangement—rather than alienation or manipulation. This gap undermines both child safety and procedural fairness.

Jurisdiction: This recommendation falls within provincial jurisdiction. Parenting determinations for non-divorcing parents are governed by the Children’s Law Reform Act (CLRA). The Ontario government may amend Section 24 (best interests of the child) to clarify the limits on overriding a child’s refusal or removing them from a bonded caregiver. Courts applying the federal Divorce Act must also consider the child’s best interests under Section 16, but there is currently no equivalent provision requiring courts to inquire into resistance before compelling reunification or overriding a child’s views.

To avoid inconsistency, Ontario should engage the federal government to explore harmonization of language and intent between the CLRA and Divorce Act frameworks, particularly in Unified Family Court jurisdictions where both statutes may be applied.

Recommendation Details: The Government of Ontario should amend section 24 of the Children’s Law Reform Act, RSO 1990, c C.12, to include a provision that limits the court’s ability to override a capable child’s participation rights in parenting and reunification decisions. Specifically, where a child is capable of forming and expressing their views and resists or refuses contact with a parent, the court should not—solely in order to improve a deficient relationship:

• Remove the child from a bonded caregiver who has not engaged in family violence and is capable of providing care;
• Restrict reasonable contact between the child and a bonded, non-violent caregiver;
• Compel the child’s participation in reunification treatment or therapy;

unless the court makes specific findings of harm, risk, or developmental necessity that justify such action.

Suggested Legislative Language (to add to Section 24):

Children’s Law Reform Act, RSO 1990, c C.12

24(x) Child participation and limits on court-ordered separation

In determining the best interests of the child, the court shall not, for the purpose of improving a deficient relationship between a child and a parent,

1. remove the child from a parent or caregiver with whom the child is bonded, who has not engaged in family violence, and who is capable of providing care;
2. restrict reasonable contact between the child and a parent or caregiver with whom the child is bonded, who has not engaged in family violence, and who is capable of providing care;
3. compel the child’s participation in reunification treatment or therapy;

unless the court finds that the child is not capable of forming and expressing their views, or that such action is necessary to prevent demonstrable harm to the child.

Ontario should also initiate dialogue with the federal government to explore amendments to Section 16 of the Divorce Act to ensure that similar protections are available in proceedings involving married, divorcing parents. This will be particularly important in UFC jurisdictions, where both the CLRA and Divorce Act may be applied depending on the litigants.

Implementation Considerations:

• Legislative drafting should align with UNCRC Article 12 language (i.e., “capable of forming and expressing their views”) and relevant case law;
• Courts should retain discretion, but be required to provide written reasons when overriding a capable child’s stated views on contact or therapeutic participation;
• This provision should be supported by accompanying guidance for the judiciary and for court-appointed clinicians, assessors, and reunification therapists;
• Consideration should be given to creating a presumption in favour of continuity of caregiving, subject to safety and risk assessment;
• This recommendation should be coordinated with other report sections, including those on Voice of the Child Reports, parental alienation, and assessor qualifications;
• The Government of Ontario’s engagement with the federal government on this issue should be sequenced after internal legislation is introduced, ideally with input from the Family Court Subcommittee proposed in Recommendation 1.

Rationale: A child’s resistance to contact with a parent may stem from a wide range of experiences, including fear, trauma, or a sense of loyalty to a safe caregiver. But when courts default to reunification or override the child’s voice without adequate inquiry, the result can be destabilizing and dangerous. The child may be forced to sever bonds with a safe parent, participate in therapy they do not understand or trust, or comply with contact that violates their sense of safety and autonomy.

This recommendation does not prohibit courts from ordering reunification or therapeutic contact. It simply establishes a floor—a requirement that courts meaningfully consider the child’s voice, assess risk and trauma, and avoid automatic remedies that presume alienation without examining cause. Ontario cannot meet its legal and ethical obligations to children unless their views are heard, respected, and considered with the same seriousness as those of adults.

6.2.8 Recommendation 8: Conduct a Region-by-Region Review of Unified Family Court Expansion

Context and Purpose: Ontario’s Unified Family Courts (UFCs) were developed to streamline family law proceedings by consolidating jurisdiction under a single branch of the Superior Court of Justice. Where available, UFCs allow families to resolve parenting, divorce, support, and child protection issues in one forum—rather than navigating fragmented, overlapping proceedings across multiple court levels. The UFC model has been widely credited with improving judicial continuity, reducing delay, and minimizing the procedural trauma often experienced by families in crisis.

For victims of IPV, court fragmentation is not just inconvenient—it can be dangerous. Separate proceedings in different courts, before different judges, can result in conflicting orders, repeated retellings of traumatic experiences, and delays in safety planning. UFCs help de-silo family justice and promote a more trauma-informed, survivor-focused system.

In 2019, the current Ontario government expanded UFC access by launching eight new sites, a major step toward eventual province-wide coverage. But as of 2025, UFCs remain unavailable in nearly half of Ontario’s judicial regions. This creates operational challenges and geographic inequities. While the benefits of UFCs are well established, full provincial implementation involves complex jurisdictional, infrastructure, and judicial resource considerations—including the availability of federally appointed judges and the physical capacity of existing courthouses.

The Committee recognizes that any effort to expand UFCs must be informed by careful regional planning, cost modeling, and exploration of interim solutions where full implementation is not immediately feasible.

Jurisdiction: This recommendation falls under shared jurisdiction. The Ontario Ministry of the Attorney General (MAG) manages courthouse infrastructure, court scheduling, and administrative staffing. The federal government is responsible for appointing judges to the Superior Court of Justice. Any plan to expand UFCs province-wide must be developed collaboratively, with clear regional business cases, data-driven infrastructure planning, and proactive engagement with federal counterparts.

Recommendation Details: The Government of Ontario should conduct a structured, region-by-region review of UFC access and expansion readiness, with a mandate to:

• Identify which judicial districts do not currently have access to a Unified Family Court;
• Assess courthouse infrastructure and physical capacity for hosting UFC operations;
• Determine the number of additional federally appointed judges required to support UFC expansion in each region;
• Consult with court services, judiciary, and local bar associations to identify operational and scheduling barriers;
• Explore whether interim UFC models can be piloted in underserved regions using shared or leased facilities.

Implementation Considerations:

• The review should be led by the Ministry of the Attorney General, in coordination with federal officials, Superior Court leadership, and relevant judicial planning bodies;
• A public report summarizing regional UFC readiness and barriers should be released within 18 months;
• Where readiness is high, the province may consider pursuing early implementation or phased pilot models prior to full rollout;
• Ontario should proactively prepare region-specific business cases and courthouse utilization plans to support future requests for federal judicial appointments;
• This review may be integrated into the proposed Family Court Subcommittee’s mandate (see Recommendation 1), particularly if the committee is tasked with examining structural modernization and access equity.

Rationale: Unified Family Courts offer a proven model for consolidating family justice, improving judicial continuity, and reducing the trauma and inefficiencies associated with parallel court processes. The benefits are especially clear in cases involving IPV and child protection, where families must often navigate multiple, disconnected legal pathways. But expansion requires infrastructure, planning, and coordinated judicial resources—not just commitment.

Ontario has already taken meaningful steps toward broader UFC access. This recommendation builds on that momentum by calling for a transparent, operationally grounded assessment of regional UFC readiness. It allows the province to move forward without overcommitting, while laying the foundation for equitable and efficient family justice reform across all regions of Ontario.

6.2.9 Recommendation 9: Expand Legal Aid Access for IPV Victims in Family Court

Context and Purpose: Victims of IPV frequently navigate family court proceedings that are complex, high-risk, and consequential—including parenting orders, restraining orders, and financial stability. Effective legal representation in these matters is often critical for personal safety, procedural fairness, and the protection of children. While Ontario provides legal aid certificates for family law matters, current eligibility thresholds, tariff rates, and billing models limit both access and uptake.

Legal Aid Ontario (LAO) does not operate under a constitutional obligation to provide counsel in family proceedings, as family law is classified as civil litigation and not tied to liberty rights. By contrast, criminal defence counsel is constitutionally mandated through R. v. Rowbotham, 1988 CanLII 147 (ON CA), where courts may stay proceedings in certain circumstances unless publicly funded counsel is provided. While this legal distinction is clear, the disparity between criminal and family law legal aid is increasingly difficult to reconcile from a public interest and infrastructure efficiency standpoint.

In IPV-related cases, lack of representation may delay resolution, increase court time, and force victims to self-navigate highly adversarial processes. This can result in poorer outcomes, heightened trauma, and greater downstream reliance on publicly funded systems such as shelters, income supports, housing programs, and crisis mental health services. There is a compelling fiscal and public safety rationale for targeted legal aid expansion in this domain.

Jurisdiction: This recommendation falls under provincial jurisdiction. Legal Aid Ontario (LAO) operates as an arm’s-length agency, but receives core funding from the Ministry of the Attorney General and is subject to the province’s budgetary and policy frameworks.

Recommendation Details: The Government of Ontario should invest in targeted legal aid expansion for IPV victims in family court by directing Legal Aid Ontario to:

• Raise the financial eligibility threshold for family law certificates where IPV is present;
• Increase the hourly tariff paid to lawyers providing family law representation in IPV-related matters, to ensure that qualified counsel are available and that lawyers are not financially penalized for taking on complex, time-intensive cases;
• Explore whether block billing models can be introduced for defined case stages (e.g., urgent motions, restraining order applications), where appropriate and cost-efficient, to improve predictability and reduce administrative burden for both lawyers and Legal Aid Ontario;
• Implement a screening and intake model to prioritize access for victims at highest risk, while minimizing administrative burden and maximizing equity.

This expansion should be supported by structured protocols that define eligibility, risk-based intake, and ongoing case management. Screening tools should be developed in partnership with expert legal organizations such as Luke’s Place and the Barbra Schlifer Commemorative Clinic, and may include both clinical indicators and legal documentation.

Implementation Considerations:

• Any change to financial thresholds, tariffs, or billing models will represent a significant budgetary investment, but should be assessed alongside court efficiency gains and reduced downstream system strain;
• LAO should consider piloting regional or phased implementation in areas with high IPV incidence or severe access barriers;
• Screening processes should be designed to protect both safety and system integrity—ensuring that supports are directed to those at highest risk, while avoiding overextension or unintended misuse. Protocols must strike a balance between confidentiality, fairness, and responsible program stewardship;
• LAO may wish to tie tariff eligibility or priority access to optional IPV-focused continuing legal education, in alignment with the training strategy outlined in Recommendation 6;
• Ongoing evaluation should track cost-efficiency, equity of access, and downstream system impacts across sectors.

Rationale: Expanding legal aid access for IPV victims is not an act of entitlement—it is a cost-efficient investment in safety, procedural integrity, and public infrastructure. Family law cases involving IPV are frequently prolonged and procedurally complex. When victims are unrepresented, proceedings may be delayed, adjourned, or improperly resolved—resulting in greater court backlog and higher downstream system use.

Targeted investment in legal representation for IPV victims can reduce litigation timelines, minimize crisis escalation, and support better outcomes for children and families. It also ensures that Ontario’s legal aid system remains responsive to modern public safety needs and evolving legal understandings of coercive control, financial abuse, and post-separation risk.

Section 7: Animal Cruelty and the Link

7.1. Background and Context

7.1.1. Introduction: The Overlooked Predictor of Violence

Animal cruelty is an empirically substantiated risk factor for future interpersonal violence, including intimate partner violence (IPV), child abuse, and homicide. Across multiple jurisdictions, including Canada, the United States, and Australia, evidence has consistently demonstrated that individuals who engage in acts of animal cruelty—particularly as part of a broader pattern of coercion, punishment, or emotional sadism—are statistically more likely to perpetrate violence against humans.⁷⁷⁹ Despite the strength and longevity of this research base, Ontario’s justice system does not structurally recognize animal cruelty as a predictor of future risk. Police records systems do not flag it as a risk marker, Crown screening practices do not prompt its consideration, and judicial or family court orders do not systematically incorporate animal protection as a public safety issue. There are no mandated pathways for information sharing between animal welfare services and violence prevention systems, and no statutory mechanism for courts to consider a person’s history of cruelty toward animals when assessing dangerousness or recidivism.

The omission is not benign. Repeated coroners’ inquests, meta-analyses, and sectoral reports have documented cases in which animal cruelty—particularly in the form of pet targeting, mutilation, or control—preceded homicide, stalking, and serious child abuse.⁷⁸⁰ In some cases, animal cruelty has also been linked to the production of child sexual abuse materials (CSAM—formerly known as “child pornography”) and to contact sexual offences involving children. Multiple studies have documented that individuals involved in sexually exploitative behaviour—including the creation of CSAM—frequently have prior histories of cruelty to animals. These patterns often reflect a broader orientation toward domination and the objectification of vulnerable beings. In many such cases, the presence of animal harm could have served as an early intervention trigger or risk escalation flag but was dismissed as incidental or irrelevant.

An Australian study found that women whose partners had threatened pets were five times more likely to belong to the group of study participants who had experienced domestic violence.⁷⁸¹ Similar findings have been recorded in Canadian studies⁷⁸², and pet abuse may be used as a tactic of control and intimidation, and that women experiencing violence frequently delay leaving abusive relationships due to fears for the safety of their animals.

There is also emerging evidence that animal cruelty correlates not only with interpersonal violence, but with a general pattern of antisocial offending. Animal cruelty, particularly when paired with violence against women or sexualized entitlement, has been flagged in multiple retrospective threat assessments as an early and visible indicator of escalating public risk. As with domestic violence, it is often reported but not systematically tracked, resulting in lost prevention opportunities even in cases that later result in multiple deaths. Other researchers have emphasized that the strongest predictive value arises when animal cruelty occurs in a coercive or relational context—particularly where the animal is used to threaten, isolate, or emotionally destabilize a partner or child.

In Ontario, there is no legal requirement for risk assessment tools, protection orders, police reports, or probation conditions to incorporate this evidence. Although the Provincial Animal Welfare Services Act, 2019, S.O. 2019, c. 13 and Criminal Code contain provisions prohibiting cruelty to animals, these are not accompanied by cross-sectoral obligations to treat animal harm as a risk indicator. Where pet-related harm is disclosed in family court or child protection settings, it is often excluded from evidentiary records or considered irrelevant to the matter at hand. The failure to recognize animal cruelty as a legally and procedurally meaningful risk flag contributes to systemic blind spots in violence prevention and undermines Ontario’s ability to act on known predictors of escalation and harm.

7.1.2. The Link: Empirical Foundations

Over the past two decades, researchers across multiple disciplines have identified animal cruelty not merely as a co-occurring feature of violent households, but as a statistically significant predictor of increased frequency, severity, and complexity of interpersonal violence. The phenomenon, often referred to as “the violence link,” encompasses a growing body of evidence associating animal maltreatment with elevated risk of physical assault, sexual violence (SV), coercive control, and homicidal behaviour—particularly in the context of IPV. In a 2017 Canadian study of women accessing shelter services, researchers found that victims who reported frequent or severe animal maltreatment also experienced significantly higher levels of psychological, physical, and SV themselves.⁷⁸³

A 2008 Australian comparative study found significantly higher rates of partner pet abuse, partner threats of pet abuse, and pet abuse by other family members were found in the violent families compared with the nondomestic violence group.⁷⁸⁴

Some researchers have argued that early animal cruelty serves as a form of rehearsal or desensitization, preparing offenders for future human-directed aggression.⁷⁸⁵

More specialized studies have further observed links between animal cruelty and contact sexual abuse, including the production of child sexual abuse materials (CSAM). Researchers have identified a strong correlation between animal cruelty and the perpetration of sexual offences involving minors, suggesting that cruelty to animals may be part of a broader pattern of boundary violation and exploitation. This has been corroborated by law enforcement intelligence assessments, which note that in some cases, animals are not only harmed as part of coercive control but are incorporated into the production or distribution of exploitative materials.

Research has also documented the presence of animal cruelty in the developmental profiles of school shooters and mass violence perpetrators. A study of school massacres noted that animal abuse often precedes broader antisocial escalation and may serve as a visible but under-responded warning sign. Incorporating animal cruelty into risk infrastructure is not only a child protection or family violence issue—it is a community safety imperative.

Still, the most consistent and policy-relevant findings emerge in contexts where animal cruelty is instrumentalized as part of a strategy of control, isolation, or punishment directed at a human victim. A 2019 study found that some forms of animal abuse, including emotional abuse or threats, were often perceived by a survivor as an attempt to intimidate or coerce them.⁷⁸⁶ Similarly, other studies have documented how victims delayed leaving abusive partners, returned to unsafe homes⁷⁸⁷, or compromised their own safety due to the lack of safe alternatives for animals left behind.

Despite the breadth of available evidence, Ontario’s legal and institutional frameworks do not currently treat animal cruelty as a risk-relevant indicator of future interpersonal violence. While provisions exist under both the Criminal Code and the PAWS Act to prohibit cruelty to animals, these offences are not operationalized as part of the province’s risk identification infrastructure. Police services, Crown offices, probation supervision, and judicial decision-making processes are not structurally required to assess or respond to animal harm in the context of violence prevention. As a result, a growing body of validated predictive evidence remains excluded from systems responsible for public safety and case management. This reflects a system design that continues to treat animal harm as incidental rather than a validated indicator of elevated risk that should be routinely integrated into violence prevention systems.

7.1.3. Ontario’s Legal and Enforcement Structure: Fragmented and Incomplete

Ontario’s legal and enforcement response to animal cruelty is governed by a multi-layered statutory framework involving the Criminal Code, the Provincial Animal Welfare Services Act, 2019 (PAWS), and various municipal bylaws. Each framework applies different legal standards and is enforced by different actors. While these laws collectively provide the tools to address a wide range of animal-related harm, enforcement practices remain highly fragmented. Operational responsibility is dispersed across agencies without centralized protocols, consistent intake standards, or shared thresholds for action. As a result, cases involving serious risk to animals and humans are frequently misclassified, referred outside jurisdiction, or not acted upon.

7.1.3.1. Legal Offences Involving Animals

a) Criminal Code Offences

The Criminal Code sets out a series of criminal offences related to animals in sections 160 and 445 through 447.⁷⁸⁸ These offences require intent, recklessness, or knowing neglect. They are investigated by police and prosecuted by the Crown. Injury or suffering is required in some—but not all—offences.

• Causing unnecessary suffering (s. 445.1(1)(a)): Applies where a person wilfully causes, or being the owner, wilfully permits to be caused, unnecessary pain, suffering or injury. Requires proof of pain or injury.
• Killing or injuring animals without lawful excuse (s. 445(1)): Applies to animals kept for lawful purpose. Injury or death must occur.
• Injuring or killing law enforcement animals (s. 445.01): Includes service animals, police dogs, and horses. Requires injury or death.
• Neglecting to provide care (s. 446(1)(b)): Wilful failure to provide suitable and adequate food, water, shelter, and care. Suffering is not required.
• Abandoning an animal in distress (s. 446(1)(a)): Leaving an animal in a situation likely to cause suffering or danger. Applies regardless of outcome.
• Animal fighting offences (s. 447): Owning, training, or profiting from animals for fighting, or keeping a fighting arena. No harm to animals required to establish offence.
• Bestiality and animal fighting (s. 160): As per Bill C-84 amendments in 2019, bestiality is defined in the Criminal Code as “any contact, for a sexual purpose, with an animal.” Bill C-84 also added new animal prohibition and restitution court order provisions. The amended legislation aims to protect animals from violence and cruelty, and to protect children and other vulnerable individuals who may be compelled by another person to commit or witness sexual acts with animals.

Examples (Criminal Code)

The following examples illustrate conduct that may constitute criminal offences under Part XI of the Criminal Code. While some offences require evidence of pain, injury, or suffering (e.g., s. 445.1(1)(a)), others—such as wilful neglect to provide care (s. 446(1)(b)) and abandonment in distress (s. 446(1)(a))—are complete upon the act or omission itself, regardless of outcome.

• A person leaves a dog locked in an apartment for 10 days without food or water, knowing or being reckless as to the likelihood that no one will attend. — Wilful neglect to provide care (s. 446(1)(b)); the offence is complete based on the deprivation and mental state, even if injury or death has not yet occurred.
• A box of kittens is left in a ditch in freezing weather with no expectation of retrieval. — Abandonment in distress (s. 446(1)(a)); offence is complete based on foreseeable risk, even if the animals are later found unharmed.
• A person threatens to shoot their partner’s dog if they attempt to leave the relationship. — Uttering threats (s. 264.1), where the threat is made to intimidate or control another person.
• Police execute a warrant at a rural property and locate multiple injured dogs, heavy chains, treadmills, and a fighting pit. The owner is found to have trained the dogs for combat and arranged matches. — Animal fighting offences (s. 447(1)); includes training animals to fight, keeping premises for fighting, and permitting fighting to occur.
• A person coerces a child into engaging in sexual activity involving an animal, bestiality in the presence of a child, or includes an animal in the production of child sexual abuse material. — Bestiality (s. 160); frequently prosecuted alongside child sexual abuse, coercion, or CSAM offences.
• A person breaks their partner’s dog’s leg with a bat during an argument. — Causing unnecessary suffering (s. 445.1(1)(a)); this type of intentional harm to a companion animal is commonly associated with coercive control in IPV contexts.

Animal cruelty offences under ss. 445.1 and 446 of the Criminal Code require proof of intent, recklessness, or “wilful neglect.” Wilful neglect means that a person knew—or was deliberately indifferent to the likelihood—that their failure to act would cause harm to an animal. It is a subjective standard that requires prosecutors to show what the accused was actually thinking or aware of at the time. This is different from offences based on “gross negligence,” such as criminal negligence causing death, which rely on what a reasonable person would have done. In gross negligence cases, the Crown does not need to prove what the accused actually knew—only that their conduct showed a marked and significant departure from what would be expected of someone in their position.

The requirement to prove wilful neglect creates a higher evidentiary bar in cruelty cases. In situations where an animal suffers or dies due to prolonged deprivation, abandonment, or untreated illness, prosecutors must still prove that the person was aware of the risk and chose not to act. This can be difficult when intent is denied, the accused offers an alternative explanation, or the failure to act was prolonged but not overtly acknowledged. As a result, conduct that appears serious—such as starvation, untreated injuries, or confinement—may not lead to conviction if subjective awareness cannot be proven.

The Government of Ontario should consider encouraging the federal government to review whether the current mens rea requirements for Criminal Code animal cruelty offences appropriately capture the full spectrum of harm. Parliament may wish to examine whether certain offences—such as failure to provide care under section 446(1)(a)—could be amended to allow prosecution on a gross negligence standard, while preserving wilfulness for the most serious conduct. This review would support better alignment between provincial and federal enforcement regimes and reduce the structural gap in prosecuting neglect-based harm.

b) PAWS Act Offences (Ontario)

The Provincial Animal Welfare Services Act, 2019 (PAWS) sets provincial standards for animal care.⁷⁸⁹ These are strict liability offences: intent does not need to be proven. The provincial prosecutor must only show that a care standard was breached, and that the breach was not reasonably avoidable. This threshold is low, by design—many PAWS offences are established solely by showing that adequate food, water, shelter, or veterinary care was not provided. In practice, the difference between PAWS and Criminal Code offences is often a matter of context and documentation. Where there is evidence of knowing inaction, recklessness, or deliberate harm, the same conduct may also support reasonable and probable grounds for a criminal charge. As a result, many incidents that are initially treated as regulatory breaches under PAWS actually meet the legal threshold for Criminal Code prosecution.

• Causing or permitting distress (s. 15): Applies where an animal is in pain, suffering, or neglect, regardless of cause. Suffering must be shown.

Examples (PAWS)

The examples below illustrate common enforcement scenarios under the PAWS Act. In each case, the same factual conduct may also support reasonable and probable grounds (RPG) for a Criminal Code offence, depending on the observed condition of the animal and the presence of intent, recklessness, or knowing neglect.

• A dog is left tethered outdoors overnight in sub-zero temperatures without shelter or access to water. — Permitting distress (s. 15, PAWS Act); may also support RPG for causing unnecessary suffering under s. 445.1(1)(a) of the Criminal Code, depending on the animal’s condition.
• A cat has an untreated infected wound for several days. — Permitting distress (s. 15, PAWS Act); may also support RPG for wilful neglect under s. 446(1)(b) of the Criminal Code where the owner was aware and failed to act.
• A dog is confined in a crate for multiple days without food or water, and the owner is aware but does not intervene. — Permitting distress (s. 15, PAWS Act); may also support RPG for wilful neglect under s. 446(1)(b) of the Criminal Code.

c) Municipal Bylaw Provisions

Municipal bylaws regulate:

• Licensing;
• Leash laws;
• Tethering duration;
• Pet ownership caps;
• Noise (e.g., barking).

These are administrative in nature. Enforcement is typically by bylaw officers or contracted animal control. Officers have no powers under the Criminal Code or PAWS. Penalties may include fines or warnings.

Examples (Municipal)

• A resident owns six dogs where the bylaw limit is three. — Excess pet ownership (bylaw).
• A complaint about excessive barking. — Noise complaint (bylaw).
• A dog is walked off-leash in a park where leashing is mandatory. — Leash bylaw violation.

7.1.3.2. Reasonable and Probable Grounds (RPG)

In Canada, reasonable and probable grounds (RPG) is the legal standard for arrest or charge. It exists when the facts and circumstances would lead a reasonable person to believe that an offence has been committed. RPG does not require certainty, evidence of motive, or completion of an investigation. It is a preliminary evidentiary threshold based on credible, objective information. Police officers are not required or authorized to assess whether the case will result in conviction⁷⁹⁰ or whether prosecution is in the public interest. Those determinations are solely the prerogative and responsibility of Crown counsel.⁷⁹¹

7.1.3.3. Systemic Undercharging of Criminal Offences

Although PAWS inspectors play a vital role in non-criminal enforcement, many cases currently referred to AWS involve conduct that is likely to meet the threshold for Criminal Code charges. These include:

• Abandonment of animals in remote areas;
• Prolonged food and water deprivation;
• Beatings or injuries consistent with intent or recklessness;
• Threats to kill or harm animals used to intimidate partners or children.

These are not hypothetical scenarios. They are regularly reported by veterinarians, shelters, neighbours, and victims. In many cases, despite meeting the legal threshold for a Criminal Code offence, no charges are laid. Files are diverted to PAWS, or closed without action, even where injury, intent, or coercive dynamics are evident.

7.1.3.4. Fragmented Enforcement Responsibilities

Ontario’s enforcement responsibilities are distributed across:

• Police officers (authorized under both the Criminal Code and PAWS);
• AWS inspectors (authorized under PAWS only);
• Municipal bylaw officers (administrative role only).

No shared intake standard or triage mechanism exists. Officers may attend or defer based on internal policy, perceived capacity, or prior practice. There is no province-wide direction regarding co-response, escalation, or documentation of possible coercive control or IPV.

AWS inspectors are not required to consult with police where criminal conduct is suspected, nor are police routinely involved in PAWS enforcement unless specifically requested. By contrast, police have authority to lay both Criminal Code and PAWS charges and are positioned to assess broader risk factors—including threats, intimidation, and coercive control dynamics.

7.1.3.5. Consequences for Risk Recognition

In the absence of centralized intake, shared thresholds, or standardized documentation, animal-related complaints are frequently handled as discrete events. Conduct that may be linked to coercive control, child exposure, or escalating interpersonal violence is not flagged for follow-up. Each responding agency—whether police, animal welfare inspectors, or municipal bylaw officers—may interact with different aspects of a case, but there is often no mechanism to ensure continuity or coordinated response.

This fragmentation results in systemic information loss. Without cross-reporting protocols or integrated databases, incidents that meet legal thresholds or suggest elevated risk remain isolated within separate service streams. Opportunities to identify patterns—such as repeat complaints, escalating severity, or multi-domain harm—are not systematically captured.

Ontario’s legal framework for addressing animal cruelty already captures a wide range of conduct, including intentional harm, wilful neglect, abandonment, threats to animals used in coercive contexts, and prohibited practices. The current challenge is not a lack of legal authority. It is the absence of coordinated risk-informed enforcement.

7.1.4. Investigative and Prosecutorial Capacity: Gaps in Training, Tools, and Trial Readiness

Ontario’s legal framework criminalizes a range of animal-related offences under both federal and provincial law. However, enforcement of those provisions depends on the practical capacity of police and prosecutors to identify relevant conduct, prepare appropriate files, and proceed with charges. At present, Ontario lacks dedicated investigative protocols, training infrastructure, and case-building supports for animal cruelty offences. These capacity gaps contribute directly to low enforcement, underprosecution, and lost opportunities to identify risk in both animal and human contexts.

7.1.4.1. Police Investigations: Technical Gaps and Structural Limitations

Police officers receive little or no formal training in how to investigate animal cruelty or assess whether a criminal or provincial offence has occurred. Officers may be unfamiliar with the relevant offence sections, unaware that they have authority to lay charges under both the Criminal Code and PAWS, or uncertain how to distinguish between neglect, cruelty, and distress. Animal-related complaints are often treated as nuisance calls or civil issues, with minimal documentation or no report generated.

Teena Stoddart, a retired sergeant with the Ottawa Police Service and subject matter expert on the violence link, has testified that many frontline service providers, including police, are not well trained to identify and respond to animal abuse, and lack awareness about its connection to other offences.⁷⁹²

Police are also generally untrained in how to gather forensic or veterinary evidence. Where photos or statements are taken, they are often insufficient to support a charge under the existing legal standard, even if the factual conduct appears to meet the threshold.

These challenges are compounded by a lack of familiarity with the regulatory framework. Officers may not know how to lay PAWS charges, when PAWS provisions apply, or whether they must involve an AWS inspector. This uncertainty contributes to procedural fragmentation, inconsistent referrals, and a high likelihood that no enforcement action will occur.

7.1.4.2. Crown Prosecution: Low Exposure, High Complexity

Crown attorneys rarely receive animal cruelty files, and when they do, the files are often incomplete, underdeveloped, or missing essential documentation. Humane Canada and NCPAC report that it is common for animal files to be received with no veterinary report, no reference to risk escalation, and no linkage to other charges on file. Statements from victims or complainants are often absent, and where the incident occurs in the context of IPV or coercive control but does not result in an IPV charge, the link may not be articulated in the synopsis or disclosure.

There is no guidance in the Crown Prosecution Manual on how to proceed with an animal cruelty charge, how to triage cases where cruelty co-occurs with violence or intimidation, or how to structure sentencing submissions that reflect either aggravating factors or public safety concerns. Animal cruelty offences are not identified in policy as a public protection issue and are not flagged for escalation in risk-linked cases.

Crown attorneys are also unlikely to have access to sentencing precedents, sample factums, or internal resource tools. The result is that files proceed on a case-by-case basis, without reference to national databases, emerging case law, or known violence link indicators.

7.1.4.3. Absence of Institutional Supports and Specialization

Ontario has no designated animal cruelty unit within the Crown system. There is no prosecutor assigned to develop expertise, track case law, or serve as a knowledge resource to others. The Crown Law Office—Criminal does not provide centralized support for animal files, nor does it maintain a repository of sample sentencing materials, agreed statements of fact, or risk-linked case summaries. Police likewise lack internal guidance documents, checklists, or training modules addressing animal-related investigations.

The NCPAC maintains a public case law database, sentencing summaries, and violence link case profiles, all of which are freely available to prosecutors and law enforcement across Canada.⁷⁹³ However, these resources are not integrated into training or practice in Ontario. Most prosecutors and officers are unaware they exist.

7.1.4.4. Comparative Model: Calgary’s Integrated Approach

In contrast to Ontario’s fragmented system, Calgary has developed a collaborative model involving the Calgary Police Service (CPS), the Calgary Humane Society (CHS), and specialized Crown prosecutors. This partnership emphasizes the recognition of the violence link—the connection between animal abuse and interpersonal violence—and facilitates comprehensive investigations and prosecutions.⁷⁹⁴

A notable example of this model’s effectiveness is the case of Aleeta Raugust, who was convicted of torturing and killing multiple cats. Raugust was sentenced to 6.5 years in custody, the longest custodial sentence ever imposed in Canada for animal cruelty.⁷⁹⁵

Calgary’s model includes:

• Routine Collaboration: Regular coordination between police, humane society officers, and prosecutors from the outset of an investigation;
• Specialized Training: Access to violence link education and case law for all participants;
• Use of Forensic Veterinary Evidence: Integration of veterinary assessments, necropsy reports, and trauma evidence into prosecution briefs;
• Public Messaging: Sentencing outcomes that are clearly linked to public safety objectives and acknowledged as such in judicial commentary.

Ontario does not currently have a comparable integrated approach.

7.1.4.5. Consequences for Enforcement, Risk Management, and Public Perception

The absence of training, specialization, and integrated resources across Ontario’s justice system limits the state’s ability to detect, charge, and monitor individuals whose conduct may indicate elevated risk. Where charges are not laid, or are pursued under regulatory rather than criminal frameworks, potential indicators of escalation are not recorded in risk databases, and opportunities for further monitoring—such as through probation, prohibition orders, or risk assessment—are lost.

Where animal cruelty is prosecuted successfully, it can support the imposition of meaningful supervisory tools. Courts may order animal prohibition conditions, compliance monitoring, and terms of probation that provide police with lawful access for checks. These measures offer a practical mechanism to supervise individuals who may present risk to others, but whose behaviour has not yet triggered conventional interpersonal violence charges. In this sense, prosecution of animal cruelty functions not only as a form of accountability, but also as an early public safety intervention.

Prosecutions also shape public understanding. Where police, Crowns, and the courts are seen to take animal cruelty seriously—particularly in cases involving patterns of harm or coercive control—the broader cultural message is one of condemnation and deterrence. This aligns with the policy objectives underlying Parliament’s 2008 creation of s. 445.1.

7.1.5. Risk Assessment Failures: Invisible in Every Tool

Although Ontario’s legal framework prohibits cruelty to animals and recognizes various forms of harm as criminal offences, its major risk assessment and case planning tools do not include animal cruelty as a formal indicator. The omission spans both interpersonal violence risk instruments and child protection documentation systems. As a result, conduct that may indicate coercive control, escalation, or multi-domain harm remains unflagged, even when known to multiple agencies. This absence of standardized documentation contributes to fragmented case histories, missed prevention opportunities, and incomplete risk profiles.

7.1.5.1. Interpersonal Violence Risk Tools

Ontario law enforcement and correctional agencies routinely use actuarial or structured professional judgment tools to assess violence risk. These include:

• ODARA (Ontario Domestic Assault Risk Assessment);
• DVRM (Domestic Violence Risk Management tool);
• B-SAFER (Brief Spousal Assault Form for the Evaluation of Risk);

None of these tools contain structured questions, scoring items, or fields for animal cruelty. ODARA and B-SAFER rely on empirically validated correlates of recidivism, but do not ask about known violence against animals, threats to animals, or use of animals in controlling behaviour.

Animal cruelty is also not included as a risk factor in standard police occurrence reports unless it results in a standalone charge. Where cruelty co-occurs with IPV, threats, or breach conditions, it may be described narratively but will not appear in any structured field used to calculate risk or flag escalation.

7.1.5.2. Child Protection Documentation and Planning

Ontario’s child protection sector does not systematically assess for animal harm in the context of family violence, neglect, or child exposure. The Eligibility Spectrum, which guides threshold decisions for investigation, does not contain any reference to animal cruelty or animal-based coercive control.⁷⁹⁶ Nor is animal harm included in structured safety plans, risk assessment checklists, or CPIN intake prompts. Where information about cruelty or distress is disclosed by a child or caregiver, there is no requirement that it be documented in a standardized format or shared with police, CAS supervisors, or relevant clinical staff.

This omission persists despite longstanding research linking childhood exposure to animal abuse with elevated aggression, impaired empathy, and antisocial behaviour. Where children report witnessing animal abuse or threats to pets, that information can help contextualize family dynamics, assess danger to non-custodial parents, and inform safety planning. However, in the absence of CPIN fields or mandated intake questions, these disclosures are often lost or excluded from case documentation.

7.1.5.3. Implications for Case Management and Prevention

When animal harm is not treated as a structured indicator of risk, it does not inform:

• Bail decisions and conditions;
• Child custody or safety planning;
• Probation or parole conditions;
• Situational assessment at Situation Tables or equivalent panels.

Cases involving coercive control, IPV, or multi-domain abuse may be evaluated without full visibility into the controlling dynamics present. Threats to pets or acts of cruelty may suggest a pattern of manipulation or punishment, particularly when used to intimidate children, retaliate against a partner, or enforce compliance. Yet those behaviours are not formally coded or flagged, and thus do not enter the information streams used to trigger secondary review or inter-agency response.

The lack of documentation also undermines rehabilitative planning. Animal cruelty is associated with aggression, low empathy, and antisocial traits that may be targeted through programming—if known. When this information is not recorded, youth or adult offenders may be diverted to general programming or may be assessed as low-risk despite conduct that suggests otherwise.

7.1.6. Judicial Education and Sentencing Tools: Conditions, Interpretation, and Institutional Blind Spots

Although Parliament has established a framework of hybrid offences and increased sentencing maximums for animal cruelty, Ontario courts, Crown offices, and corrections have not consistently integrated animal harm into bail hearings, probation management, or sentencing submissions. At present, there is no province-wide training, policy, or standard directive guiding how animal harm should be interpreted by justices of the peace (JPs), judges, or Crown attorneys in the context of violence prevention or risk-based decision-making. As a result, animal-related conditions are rarely sought, imposed, or enforced—even when disclosures have been made, or charges are before the court.

7.1.6.1. Absence of Structured Guidance for Conditions

The Crown Prosecution Manual does not currently flag animal cruelty, threats to animals, or animal-based coercive control as public safety factors to be considered when proposing bail or probation conditions.⁷⁹⁷ In files where animal cruelty charges are laid, Crowns may seek prohibition orders under s. 447.1(1) of the Criminal Code, but such orders are not mandated and are often omitted in routine plea resolutions. In files where no animal-related charge is laid—such as cases involving IPV or stalking where the victim discloses threats to a pet—there is no standard practice of seeking conditions that would bar the accused from accessing, harming, or removing the animal.

Although bail and probation orders may include conditions related to property or contact, animal-specific conditions are not systematically requested or tracked. JPs and judges are not required to receive education on the role of animal harm in coercive control or its predictive value in violence-linked cases. In the absence of training or structured guidance, animal-related disclosures may be considered anecdotal or extraneous, and are unlikely to influence judicial decision-making.

7.1.6.2. Predictive Relevance and File Assignment

Animal cruelty and associated offences are not consistently recognized in Ontario as a behavioural risk flag warranting enhanced scrutiny. Ontario’s current police charging standards do not require or direct charges in high-risk animal cruelty cases, even where coercive dynamics or violence-linked conduct are present.⁷⁹⁸ Where cruelty or related animal offences are charged under the Criminal Code, the file may be assigned to general case management teams rather than domestic violence or SV units. Similarly, where police lay cruelty charges unrelated to a known IPV file, the matter may be investigated by general detectives or front-line officers, rather than by a domestic violence or specialized risk investigator.

Research linking animal cruelty to interpersonal violence, child abuse, and sexual offending has been documented by both Canadian and international studies. In the context of file triage, this evidence may support assigning such matters to violence-focused teams—regardless of whether the current charges involve a known victim.

At present, there is no protocol or directive requiring that animal cruelty charges be screened or managed by violence-linked teams. Police reports may not flag the case for DV triage, and Crown intake systems may default such files to general stream. As a result, cases with high predictive value may be overlooked, under-prosecuted, or resolved without full contextual consideration.

7.1.6.3. Judicial Education and Public Protection Logic

Ontario has no mandatory judicial education requirement regarding the violence link, the role of animal harm in coercive control, or the use of animals in threat-based intimidation and there is no indication of any structured training modules addressing s. 447.1 prohibition orders, the crafting of appropriate bail and probation conditions related to animals, or the impact of harm to pets on victims and children.

Parliament and Ontario’s legislature may, in limited capacity, require the courts to provide education on specified topics through legislated direction. However, the format, length, scope, and specific content of those materials are determined internally, consistent with the principle of judicial independence. Federally, education for judges is developed by the National Judicial Institute. In Ontario, education for provincially appointed judges and justices of the peace is coordinated by the Judicial Education Secretariat, which operates independently of the Ministry of the Attorney General.

Keira’s Law has now been enacted at both the federal and provincial levels, mandating judicial education on intimate partner violence and coercive control. Federally, Bill C-233 amended the Judges Act to require education for federally appointed judges.⁷⁹⁹ Ontario subsequently enacted its own version of Keira’s Law in Bill 102, which applies to provincially appointed judges and justices of the peace.⁸⁰⁰ Both amendments were designed to ensure that courts are equipped to recognize patterns of coercive behaviour. Where animal harm is used to control, intimidate, or punish, it may serve the same risk-signalling function as other coercive or psychologically violent acts. However, because animal harm does not currently appear in Ontario’s risk assessment tools, prosecutorial policies, or bail screening frameworks, there is no reason to expect that it would be included in judicial education materials—unless specifically legislated.

Judicial education frameworks that do not address these issues may limit the state’s ability to act on Parliament’s intent or protect individuals exposed to multi-domain abuse.

7.1.7. Animals as Property and Legal Protection Gaps

Ontario’s legal framework treats animals as property. This classification applies across civil, family, and criminal contexts and shapes how courts interpret possession, ownership, and harm. The property status of animals has significant implications for victims of IPV, particularly where safety planning involves pets or where an abusive partner uses animal harm as a coercive or retaliatory tool. Despite growing recognition of the relational and risk-based significance of companion animals, Ontario’s current laws do not support exclusive possession orders, non-criminal protection orders, or housing policies responsive to animal-related barriers.

7.1.7.1. Animals as Property in Ontario Law

Under Ontario law, animals are classified as personal property. This status applies to disputes under the Family Law Act and common law litigation. In family court, animals are not treated as dependents, and Ontario courts do not apply best-interest standards or custodial logic in pet-related decisions. Ownership is typically determined based on purchase, registration, or care evidence, and disputes are resolved through general property division rules.

In Coates v. Dickson, the Ontario Superior Court confirmed that while pets may have emotional value, the court’s task is not to determine what is best for the animal, but rather to determine ownership and resolve possession accordingly.⁸⁰¹ Courts do not have authority to award shared possession, parenting-style time, or exclusive interim control over a pet unless property law or tort principles support it.

7.1.7.2. British Columbia: Structured Possession Factors in Family Law

In January 2024, British Columbia amended Section 97 of its Family Law Act to provide a structured framework for resolving post-separation disputes over companion animals.⁸⁰² Section 97(4.1) directs the court to consider, inter alia:

• The risk of family violence;
• The wellbeing of the animal;
• The ability and willingness of each spouse to care for the animal;
• The relationship between the animal and any children;
• The history of care;

While pets remain legally classified as property, the court is now required to consider relational and safety-based factors beyond legal title. The Family Law Act defines “family violence” in Section 1 to include conduct such as physical abuse, emotional or psychological abuse, as well as coercion, intimidation and threats (including towards pets or property).⁸⁰³ Although “coercive control” is not named explicitly, it is functionally captured by the statutory definition.

The law does not permit orders for joint possession or shared parenting of animals. While some commentators have criticized the statute for failing to contemplate joint arrangements, no shared possession orders are authorized under the current amendment, though some cases (in BC) have implemented a shared arrangement regardless. Ontario has no comparable provision requiring courts to consider family violence or child impact when determining possession of a companion animal after separation. The BC model is limited to separation disputes. It does not address intestate estates, probate litigation, or pet-related trusts. In Ontario, animals continue to be treated as property in estate matters unless a specific bequest or instruction is made in a will. No Canadian jurisdiction has yet extended the relational logic of BC’s s. 97(4.1) to estates law.

7.1.7.3. U.S. Civil Protection Order Models

42 U.S. states allow for the inclusion of animals in protection orders issued in domestic violence cases.⁸⁰⁴ These orders typically authorize the court to, for example, award temporary possession of a pet or assist with the removal of a pet from a home. This approach differs from Ontario’s current framework, where protection orders are available only upon criminal charge or under family law provisions. There is no statutory mechanism to grant temporary possession or protection of a pet in a standalone order, nor any authority to issue animal-related terms unless the underlying offence involves direct threats or cruelty. Bail and probation conditions may include animal-related terms, but these are not standardized and are often absent from plea resolutions or pre-trial orders.

7.1.7.4. Observations and Structural Constraints

While BC’s 2024 amendments provide a new family law model, they remain narrow in scope. Shared possession or “custody-style” orders are explicitly disallowed, and the framework does not apply outside separation proceedings. The statute does not provide a mechanism for protective possession orders, interim possession during family violence proceedings, or property-related conditions in estates. Ontario’s current system does not provide any comparable mechanism. There is no framework for awarding exclusive possession of an animal to a victim in family court, no way to incorporate pets into civil protection orders outside criminal charge, and no recognized legal route for securing pet-related safety planning unless reframed through property or tort law. The NCPAC Case Law Database has begun tracking family law disputes involving animals.⁸⁰⁵ Review of cases finds that judges vary in whether they permit debate about the status of a companion animal in their proceedings. Opportunities for improvement may include the development of structured criteria, clearer intake and documentation guidance, and legislative clarification of when and how animals may be addressed in family proceedings or non-criminal protective orders.

7.1.8. Geographic Enforcement Challenges in Underserviced Regions

Ontario’s animal welfare and cruelty laws are enforced uniformly across the province. However, these laws presume access to veterinary infrastructure, containment mechanisms, and population control tools that may not exist in northern, rural, or remote communities. In areas where veterinary access is limited or seasonal, the ability to comply with existing statutes may be legally required but logistically unattainable. This presents a structural enforcement challenge.

7.1.8.1. Veterinary Access and Legal Compliance

Under both the Provincial Animal Welfare Services Act, 2019 (PAWS) and the Criminal Code, animal-related offences may arise from prolonged suffering, untreated injury or unmanaged illness. In serviced communities, these expectations are supported by access to clinics, mobile treatment, and containment facilities. In underserviced areas, they are not.

In many fly-in or seasonal-access communities, veterinary care is unavailable or occurs only through short-duration fly-in clinics operated by charities or volunteers. There may be no accessible transport to southern facilities, no local capacity for spay/neuter or emergency care, and no formal support system to respond to illness, outbreak, or injury. Preventive population management is not structurally supported.

Despite this, there is no exemption under PAWS or the Criminal Code for geographic remoteness. The law does not distinguish between owners with full access to care and those in areas that lack services or have limited access to services. Enforcement officers have no discretion to consider veterinary access when determining whether to lay charges, and no alternative framework exists to support compliance where treatment is unavailable.

7.1.8.2. Enforcement Disparity and Structural Invisibility

There is no policy framework within Ontario’s enforcement system to address geographic variability in compliance capacity. Communities with no clinics may still be subject to enforcement. Others may never be inspected. Enforcement is either absent or unworkable, but the underlying legal obligation remains the same.

Where inspections do occur, there are no standing links to support services. Fly-in veterinary clinics are not integrated into the animal welfare enforcement model. Officers do not coordinate with mobile spay/neuter programs and have no access to follow-up care or relocation options. In cases where charges are laid, there may be no lawful means of resolving the underlying problem.

In other cases, no enforcement occurs. The result is not equity, but a patchwork of omitted risk. There is no provincial inventory of unserviced communities, no integration of dog population issues into public health or education, and no routine system for documenting when or where animal-related trauma may occur.

7.1.8.3. Potential Pathways for Structural Support

While full parity of services across all communities is not within the scope of this report, the current enforcement framework operates without any structural pathway for lawful compliance in remote or fly-in areas. Where the law imposes obligations, but no compliant option exists, charges may be legally valid but structurally unresolvable. In other cases, public safety concerns or unmanaged trauma are invisible to any provincial system.

Some jurisdictions maintain sectoral infrastructure funds to support compliance in underserviced regions, such as agricultural disease management, pest control, or wildlife health. Veterinary population management does not currently fall under such mandates. A limited, discretionary fund—coordinated through an existing ministry or delivered through partnerships—may provide fly-in clinics or surgical support to communities that request population control services.

A program of this nature would not be a guaranteed service, but a tool to prevent structural noncompliance and reduce the risk of unmanaged harm. It would not assign responsibility to any individual actor or community, but would offer a practical mechanism for coordinated, lawful intervention where no alternative exists.

7.1.9. Rural Coercive Control and the Use of Livestock in Violence Dynamics

While many legal and service frameworks addressing IPV, SV, and coercive control emphasize urban and companion animal contexts, parallel dynamics exist in rural and agricultural settings involving livestock and farm animals. These settings introduce unique vulnerabilities due to the economic and logistical interdependence of partners within farm operations. Livestock are not only animals of relational or emotional significance; they are also capital assets, income sources, and instruments of daily labour. As such, they may be used as tools of coercive control in ways that Ontario’s current legal, enforcement, and support structures do not recognize or accommodate.

7.1.9.1. Coercive Control Involving Livestock

In rural settings, livestock are not only sources of income but also hold emotional value. Abusers may threaten harm to livestock, neglect their care, or sabotage farm operations to intimidate and control their partners.⁸⁰⁶ Such tactics exploit the victim’s attachment to the animals and their dependence on the farm for livelihood, making the prospect of leaving the abuser daunting. Studies have highlighted that concern for animal welfare can significantly impact a victim’s decision to leave an abusive relationship, especially in rural areas where resources are scarce.

7.1.9.2. Economic Dependence and Barriers to Exit

The economic implications of leaving a farm or losing livestock can be significant. Survivors may fear financial ruin, loss of their home, and the inability to care for their animals if they leave. This economic dependency is a powerful deterrent, often trapping victims in abusive situations. The intertwining of economic abuse and animal maltreatment exacerbates the challenges faced by victims in rural communities.⁸⁰⁷

7.1.9.3. Enforcement and Support System Blind Spots

Ontario’s enforcement and victim service systems do not currently treat livestock-related coercion as a distinct or recognized IPV tactic. While the PAWS Act and Criminal Code provide general prohibitions against cruelty and neglect, these frameworks do not address the economic dynamics of livestock control or the ways in which animal welfare may be strategically weaponized.

Law enforcement agencies and Crown attorneys have few directives or screening tools to identify livestock-based risk. Service providers may not know how to document or escalate these issues, and animal welfare inspectors may be uncertain how to coordinate with IPV agencies.

Rural IPV shelters and services also lack tailored supports. Transportation challenges, geographic isolation, and the absence of temporary farm assistance or veterinary emergency services make it difficult for rural victims to access safety without abandoning or losing their animals.

7.1.9.4. Implications for Risk Assessment and Safety Planning

The use of livestock in coercive control presents a distinct enforcement and service design challenge. Unlike cruelty to pets, which is often emotional or relational in its impact, livestock-related abuse may be framed as operational failure, economic sabotage, or management conflict. Without structural recognition of these dynamics, victims may not be believed, and the conduct may not be flagged as indicative of risk.

These gaps affect not only victim safety and financial independence, but also trust in police, Crown, and protective services in rural areas. Victims who report livestock-related harm and receive no effective response may disengage from the system, contributing to underreporting and isolation.⁸⁰⁸ At present, Ontario’s legal, enforcement, and shelter systems do not include livestock within IPV frameworks. This omission limits prevention, response, and victim engagement across agricultural communities.

7.1.10. Public Education, Professional Recognition, and Cultural Dismissal

Despite the legal classification of animal cruelty as a hybrid offence and its documented association with interpersonal violence, the conduct is frequently minimized or reframed by both the public and professionals as a nuisance issue, an emotional upset, or a civil matter. This cultural and institutional dismissal has implications for risk recognition, enforcement practice, and victim support. The perception that animal harm is unfortunate but not dangerous contributes to systemic under-response and obstructs efforts to integrate cruelty into risk-informed decision-making.

7.1.10.1. Public Framing of Cruelty as Non-Risk

In general discourse, cruelty to animals is more likely to be described as morally upsetting than as criminologically relevant. Media coverage, public policy discussion, and public reactions tend to frame animal harm as an ethical concern, a sign of social incivility, or a breach of community standards—not as an indicator of elevated violence risk. This framing affects the allocation of resources, the types of cases pursued, and the public’s willingness to view cruelty as a matter of public protection.

Research has documented that public perceptions of cruelty vary significantly depending on species, context, and perceived intent. Companion animals harmed in interpersonal violence contexts may evoke greater empathy but are still rarely understood as potential precursors to human-directed violence. Animal cruelty is often categorized as “not real crime,” a perception that may reduce the likelihood of investigation or escalation.

7.1.10.2. Professional Minimization in Enforcement and Social Services

Institutionally, animal cruelty is often deprioritized in policing, Crown screening, and social work triage. Police officers may respond to cruelty complaints as civil disputes or disturbances, particularly when the conduct involves property damage or unclear ownership. Child protection workers may disregard animal-related disclosures unless they relate to immediate risk to the child. In legal practice, cruelty files may be assigned to general stream Crowns, rather than domestic violence teams—even where the conduct occurs within an IPV context.

In clinical contexts, cruelty is rarely integrated into structured risk assessments or mental health evaluations. Animal-related disclosures may be described as incidental or emotionally upsetting, rather than as behavioural indicators with predictive value.

7.1.10.3. Consequences for Risk Recognition and Institutional Design

The minimization of cruelty as a criminological factor affects every stage of system response. Risk assessments that do not include cruelty fail to flag escalation. Occurrence reports that exclude cruelty prevent pattern recognition. Victim statements that describe pet threats may not be documented in a way that allows them to inform safety planning. Probation conditions may not restrict animal contact unless the underlying charge involved direct cruelty. Child welfare investigations may not account for harm to pets as part of the child’s experience of violence.

This is not a gap in knowledge, but in institutional framing. The link between animal harm and interpersonal violence has been documented in multiple studies, and the association is well established in violence prevention literature. The absence of integration is not due to lack of awareness, but due to the perception that animal cruelty is a low-stakes offence—not something that warrants structural adaptation.

Where cruelty is treated as incidental or emotional, risk-informed systems cannot fully operate. The omission affects triage, training, policy design, and interagency collaboration. Cultural dismissal functions as a form of institutional blind spot. Addressing it requires not only legal tools but also reframing of what the behaviour means.

7.1.11. Cost of Inaction: Lost Opportunities for Prevention and System Waste

Ontario’s failure to integrate animal cruelty into violence prevention and risk recognition systems has cumulative consequences for public safety, fiscal efficiency, and interagency coordination. When cruelty-related conduct is not documented, investigated, or interpreted as risk-relevant, it cannot inform decisions about supervision, safety planning, or intervention. The result is a system that responds only when violence escalates—despite early warning signs that were present, observable, and legally actionable.

This omission is not theoretical. Research has repeatedly shown that cruelty to animals is a known correlate of interpersonal violence, child abuse, coercive control, and psychological harm. When this domain is excluded from police reports, risk assessments, Crown screening, probation files, or family court proceedings, system actors are deprived of relevant behavioural evidence that could alter risk tiering, supervision intensity, or service referrals. The consequence is that harm occurs—not because it could not have been predicted, but because a known predictor was structurally invisible.

7.1.11.1. Missed Opportunities for Early Intervention

In child protection contexts, exposure to animal cruelty—whether direct or witnessed—has been linked to emotional desensitization, empathy disruption, and later externalizing behaviours. These indicators are not routinely screened for or documented in CPIN, risk assessment tools, or intake protocols. They do not inform placement decisions, parenting assessments, or safety planning unless a worker independently identifies the concern. In the absence of system guidance, this type of risk is left to individual discretion, resulting in inconsistency and under-recognition.

Youth-based prevention models such as the SNAP program have demonstrated that early intervention in conduct problems may yield significant fiscal and public safety benefits. Cost modeling presented by Child Development Institute estimates that a single youth diverted from a high-risk trajectory through targeted prevention may avoid more than $2 million in cumulative social and system costs over a lifetime.⁸⁰⁹ These figures include justice system involvement, child protection, health care, and social assistance. Where cruelty to animals occurs in childhood or adolescence and is not flagged, opportunities for targeted prevention may be lost.

7.1.11.2. Escalation, Re-entry, and System Cost

Adult perpetrators who engage in cruelty to animals are more likely to have histories of coercive control, breach of conditions, or repeat offending. Where cruelty is not documented, it does not inform Crown screening, bail decisions, or sentencing submissions. Conditions that might have been appropriate—such as animal prohibition, GPS monitoring, or elevated probation—are not imposed. Police may not recognize the need for risk escalation. Community services may not triage the file as high-risk. The result is that enforcement, supervision, and prevention mechanisms are underutilized or misapplied. This omission contributes to a broader system problem: the tools to intervene may exist, but they are only activated when the wrong risk signals are prioritized.

7.1.11.3. Cost of Unused Legal Tools

Ontario’s legal framework permits prosecutors to lay animal cruelty charges under both the Criminal Code and the PAWS Act. These charges can support the imposition of prohibition orders, probation supervision, and judicial monitoring. However, in practice, such charges are often not laid or are downgraded to regulatory infractions. Where cruelty is prosecuted under PAWS alone, it may result in a fine but no supervision. Where no charge is laid, the conduct remains legally unacknowledged.

This limits the system’s ability to:

• Track individuals with cruelty histories;
• Impose behavioural conditions;
• Prevent future escalation.

The Crown Prosecution Manual contains no directive on when or why to proceed by indictment in cruelty cases, and there is no policy guidance on integrating animal harm into Crown file screening. Without direction, high-risk conduct may be resolved through summary disposition, with no monitoring, no risk escalation, and no documentation of the conduct that preceded future violence.

7.1.11.4. System Waste and Missed Prevention

Ontario currently funds a range of post-harm responses, including emergency shelter, criminal prosecution, child protection involvement, mental health intervention, and policing. Each of these responses is significantly more expensive than early prevention or targeted supervision. When animal cruelty is not flagged, the state absorbs downstream costs associated with untreated risk: breach of bail, reoffending, probation failure, harm to victims, recidivism, or re-entry into shelter or care systems.

7.2. Recommendations

7.2.1. Recommendation 1: Update Police and AWS Training to Support Criminal Enforcement of Animal Cruelty and Identify Associated Risk

Context and Purpose: Police officers and Animal Welfare Services (AWS) inspectors are the primary first responders in cases involving suspected animal cruelty in Ontario. Police are authorized to investigate and lay charges under both the Criminal Code and the Provincial Animal Welfare Services Act (PAWS Act), while AWS inspectors are limited to provincial enforcement. Despite the availability of criminal charging frameworks, many cases that meet the legal threshold for prosecution are not investigated or triaged through the criminal system. Current training does not ensure consistent understanding of the violence link, enforcement roles, or procedural thresholds for referral. Certain animal cruelty offences—such as dog fighting—may also intersect with organized crime, weapons offences, or trafficking-related activity. Clarifying investigative authorities, improving file development practices, and aligning operational training across agencies would support more consistent enforcement, early identification of co-occurring risk, and better alignment with Ontario’s existing domestic violence response infrastructure.

Jurisdiction: The Ministry of the Solicitor General holds direct responsibility for police training delivered through the Ontario Police College and for oversight of provincial Animal Welfare Services. The Ministry also issues LE-024, Ontario’s domestic violence charging directive, and retains full authority to amend the directive or update its supporting training content. AWS operational procedures and role-based policies fall under the Ministry’s jurisdiction.

Recommendation: The Ministry of the Solicitor General should ensure that updated core training is delivered through the Ontario Police College, and that parallel training is developed for all AWS field inspectors. This training should include:

• Instruction on the documented association between animal cruelty and elevated risk of IPV, coercive control, sexual violence, child maltreatment, and other forms of interpersonal violence (the “violence link”);
• Operational guidance on investigative authorities under the Criminal Code and the PAWS Act, including search powers, offence elements, and the legal indicators that distinguish a PAWS offence from conduct that may meet the threshold for Criminal Code prosecution;
• Best practices in evidence gathering and file development, including use of photo documentation, forensic veterinary records, necropsy reports, and coordination with Crown prosecutors;
• Procedures for determining investigative lead based on agency mandate, offence classification, and associated enforcement authority;
• Clarification of enforcement roles and statutory limits, including when police involvement is required due to the nature of the offence or associated public safety risk;
• Training content should reflect the expectation that police will be the primary responders in cases where criminal conduct is suspected or where enforcement under the Criminal Code may be appropriate.

AWS inspectors should be trained to recognize potential indicators of coercive control, child risk, or IPV-related dynamics when attending complaints involving animal neglect or harm, including cases that initially appear unrelated to interpersonal violence. Operational policy should reinforce the expectation that such cases be flagged and referred to police when risk is identified.

When LE-024 is next reviewed, the Ministry should ensure that current evidence on animal cruelty as a risk factor for intimate partner violence, child maltreatment, and coercive control is reflected in the directive. The Ministry may wish to consult with subject-matter experts on whether:

• Extending the mandatory charging framework to include animal cruelty offences would address enforcement gaps and mirror the original policy rationale for mandatory charging in domestic violence cases—namely, to overcome cultural minimization, attitudinal bias, and inconsistent application of legal thresholds.

Animal-related content should also be incorporated into future refresher training modules for serving officers, consistent with the recommendations on IPV-related training modernization set out elsewhere in this report.

Implementation Considerations:

• Some training related to the violence link may already be included in existing Ontario Police College curricula; however, the content is not publicly defined and may not include core legal, investigative, or risk recognition elements required for coordinated enforcement.
• LE-024 has been subject to public attention in the past, and any revision may require internal preparation and communication across police and Ministry leadership. The Ministry should consider coordinating implementation with related Crown and judicial training updates to ensure consistency across justice sector partners.
• Any update to AWS operational policy should be supported by supervisory training and incorporated into routine case review procedures to ensure consistent application across regions.
• Refresher training delivery timelines should be aligned with broader IPV-related modernization efforts across justice sector partners.

Rationale: Ontario’s existing legal framework already supports criminal prosecution of serious animal cruelty. However, enforcement remains inconsistent, and frontline role confusion may result in undercharging or misclassification of conduct. Improving basic training and operational alignment between police and AWS would enhance early detection of escalating risk, improve enforcement consistency, and support more coherent public safety response.

Given that a significant amount of enforceable cruelty conduct falls under the Criminal Code, police services are best positioned to act as the primary responders in these cases. Where such conduct overlaps with known risk domains, the case for structured or mandatory intervention mirrors the rationale that originally underpinned LE-024. Updating the directive and embedding relevant content in recruit and refresher training would strengthen Ontario’s ability to respond consistently and meaningfully to a form of harm that remains routinely under-identified in risk and safety planning systems.

7.2.2. Recommendation 2: Integrate the Violence Link into Mandated CAS Training

Context and Purpose: The report includes several recommendations calling for updated and standardized training for Children’s Aid Society (CAS) staff across Ontario, particularly in relation to intimate partner violence, coercive control, and the use of risk-informed assessment tools. As part of these broader training efforts, it is necessary to ensure that CAS staff are equipped to recognize, document, and appropriately respond to disclosures or observations of animal harm as a potential indicator of household risk. Exposure to animal cruelty is associated with increased rates of child maltreatment, coercive control, and other adverse childhood experiences. CAS workers may encounter these indicators in the course of routine home visits or interviews, including in situations where they are not the primary focus of investigation.

Jurisdiction: The Ministry of Children, Community and Social Services holds oversight responsibility for child protection agencies operating under the Child, Youth and Family Services Act. The Ministry issues directives and training expectations related to the use of standardized risk assessment tools, case documentation, and sector-wide practice guidance.

Recommendation: As part of any broader expansion or standardization of mandated training for CAS staff, the Ministry of Children, Community and Social Services should ensure that such training explicitly includes:

• Recognition of animal cruelty as a form of environmental violence and a potential risk factor for child maltreatment, coercive control, or escalating family violence;
• Procedural guidance on documenting observed or disclosed animal harm during child protection investigations;
• Referral expectations and inter-agency coordination procedures where risk to children or co-occurring interpersonal violence is suspected.

Implementation Considerations:

• Existing child protection training already includes content on environmental and structural risk factors; integration of animal cruelty content should align with those modules to minimize duplication.
• Alignment with planned updates to the Eligibility Spectrum, CFRA, and risk tool guidance may improve implementation consistency and reinforce documentation expectations.
• Parallel training is being recommended for police, Crown attorneys, and judicial educators; coordinated language across systems may improve inter-agency recognition and response.

Rationale: Animal cruelty is both a discrete form of harm and a known indicator of broader family risk. CAS staff are uniquely positioned to observe animal neglect or abuse in the course of routine investigations, particularly in households where children may be exposed to multiple forms of violence. Ensuring that these indicators are recognized and appropriately referred supports early intervention, risk-informed safety planning, and consistency across Ontario’s violence prevention infrastructure.

7.2.3. Recommendation 3: Amend Ontario’s Keira’s Law Provision to Include the Violence Link and Encourage Federal Alignment

Context and Purpose: Ontario amended section 43.1 of the Courts of Justice Act through the Strengthening Safety and Modernizing Justice Act, 2023, creating a legislative foundation for specialized judicial education on intimate partner violence and coercive control. This education is overseen by the Chief Justice of the Ontario Court of Justice and delivered through the Court’s Education Secretariat. However, current legislation does not reference specific risk domains and does not formally include animal cruelty as a potential mechanism of coercive control. Given that animal cruelty is excluded from most existing risk assessment tools, professional training programs, and legislative frameworks related to family violence, its omission in judicial education risks reinforcing that systemic blind spot. A narrowly scoped amendment is warranted to ensure that this risk factor is not overlooked in Ontario’s implementation of Keira’s Law.

This recommendation proposes a legislative refinement to Ontario’s Keira’s Law framework and encourages a parallel amendment to the federal Judges Act, ensuring consistency across court levels.

Jurisdiction: Section 43.1 of the Courts of Justice Act, RSO 1990, c C.43, governs judicial education for provincially appointed judges and justices of the peace. The Ministry of the Attorney General has the authority to propose amendments to this section. While Ontario cannot prescribe content or require training for federally appointed judges, it may formally request alignment through amendments to the Judges Act, RSC 1985, c J-1, which is under federal jurisdiction.

Recommendation: The Government of Ontario should amend section 43.1 of the Courts of Justice Act to include structural parameters for judicial education on intimate partner violence and coercive control. These should include:

• A clarification that education on coercive control may include content on the use or threat of animal harm as a tactic of intimidation or escalation;
• A requirement that training under this section be completed within 120 days of appointment;
• A requirement that refresher training be made available to all sitting judges at least once every three years;
• A requirement that anonymized participation statistics be published annually by the Chief Justice of the Ontario Court of Justice.

For example, the section could be amended to include the following:

(6) In approving education under this section, the Chief Justice shall consider whether the program addresses known mechanisms of coercive control, including the use of animal harm or threats of animal harm to intimidate, punish, or exert control over a partner or child.

(7) Judges appointed to the Ontario Court of Justice shall complete training under this section within 120 days of their appointment.

(8) Refresher education shall be made available to all full-time, part-time, and per diem judges on a rolling basis at least once every three years.

(9) The Chief Justice shall publish anonymized statistics annually on the completion of education under this section, including initial and refresher training.

The Government of Ontario should also formally request that the federal Minister of Justice consider a parallel amendment to section 60 of the Judges Act, RSC 1985, c J-1, to ensure that federally appointed judges sitting in Ontario receive training that includes the violence link and its relationship to coercive control.

Implementation Considerations:

• Any amendment must be carefully scoped to respect judicial independence and avoid prescribing training content;
• Language should mirror accepted frameworks such as Bill C-3 (sexual assault law seminars), which require participation but delegate curriculum development to judicial bodies;
• Coordination with the Ontario Court of Justice Education Secretariat and the National Judicial Institute may support aligned implementation;
• Annual reporting may be embedded within existing publications such as the Chief Justice’s Annual Report.

Rationale: The inclusion of animal harm in judicial training on coercive control reflects current risk literature and improves alignment with other sectors of Ontario’s justice system, including Crown and police education. Many victims experience the threat or injury of animals as a mechanism of intimidation, yet this behaviour may be minimized or overlooked in the absence of targeted training. Updating Ontario’s judicial education legislation to acknowledge the relevance of animal cruelty in coercive dynamics would support risk recognition and reinforce Ontario’s leadership on Keira’s Law implementation. A parallel federal amendment would ensure consistency for Superior Court judges hearing family, child protection, or criminal matters in Ontario.

7.2.4. Recommendation 4: Establish a Dedicated Training Stream for Animal Cruelty Prosecutions Within Crown Education Programming

Context and Purpose: While the Criminal Code provides a detailed statutory framework for prosecuting animal cruelty offences, these charges are infrequently laid, inconsistently prosecuted, and often treated as legally and operationally peripheral. There is currently no standardized Crown training on how to identify, prepare, or prosecute animal cruelty offences, despite their documented correlation with intimate partner violence, coercive control, child maltreatment, and, in some cases, organized crime. Creating a formalized training stream would support more consistent file management, improve evidentiary rigour, and ensure that Crown attorneys are equipped to make legally sound, risk-informed prosecutorial decisions. Former Crown Education Lead Robin Flumerfelt and Sonia Anand who leads education for the provincial prosecutors who handle most of the PAWS-related offences/prosecutions, are likely resources who may be considered as advisors for this work.

This recommendation complements proposed Crown policy updates and file-streaming expectations addressed separately.

Jurisdiction: The Ministry of the Attorney General is responsible for Crown training via the Criminal Law Division and Crown Law Office—Criminal, including the development and delivery of foundational education for new Assistant Crown Attorneys and continuing education for specialized prosecution streams and established Crowns. The Crown Policy Manual and internal prosecution memoranda are administered by the Criminal Law Division and Crown Law Office—Criminal. The Ministry has the authority to revise training curricula and set expectations regarding subject matter coverage and prosecutorial competencies.

Recommendation: The Ministry of the Attorney General should establish a dedicated training stream on animal cruelty prosecutions, integrated into both foundational and continuing Crown education. This training should include:

• Instruction on prosecuting offences under sections 445, 446, and 447 of the Criminal Code, including the evidentiary requirements and legal elements specific to each charge;
• Guidance on the development of prosecutorial files, including expert evidence (e.g., forensic veterinary reports, necropsies), documentation standards, and chain-of-custody considerations;
• Contextual education on the overlap between animal cruelty and other risk domains, including intimate partner violence, coercive control, child endangerment, and organized crime;
• Guidance on working with police and AWS officers to clarify jurisdiction, validate charge selection, and ensure that file development aligns with evidentiary thresholds;
• Instruction on the crafting of conditions in bail, probation, and peace bond proceedings—including the appropriate use of animal prohibition orders under section 447.1 of the Criminal Code, and associated public safety considerations;
• Instruction on how animal cruelty prosecutions intersect with domestic violence protocols and team-based file management, to support coordinated risk assessment and consistent application of protective conditions.

All Assistant Crown Attorneys should receive this training during their initial onboarding, and the Ministry should ensure that updated or refresher content is made available through annual continuing education sessions. Training should align with proposed updates to the Crown Policy Manual.

Implementation Considerations:

• Prosecutorial training modules that include some information on animal cruelty should be updated. Training modernization may require input from external experts, including forensic veterinarians, AWS staff, investigators, experts from the National Centre for the Prosecution of Animal Cruelty, and Crown attorneys with prior file experience;
• Materials should be developed in consultation with the Crown Policy Division to ensure consistency with planned file-streaming protocols and election guidance;
• Training content may be modularized to accommodate differences in regional file volume or specialization;
• Refresher content should be incorporated into the Ministry’s existing annual training calendar, and tracked as part of continuing education records.

Rationale: Animal cruelty offences remain structurally minimized within Crown education despite their recognized association with interpersonal risk. Crown attorneys are not routinely trained on how to prosecute these files, evaluate their risk implications, or draft appropriate public safety conditions. The absence of structured training has contributed to file inconsistency, underutilization of prohibition orders, and missed opportunities for integrated risk response. By establishing a formal training stream—analogous in structure to those used for IPV, SV, or firearms prosecutions—the Ministry can support more consistent enforcement, align prosecutorial practices with the realities of risk, and ensure that animal cruelty files are handled with the legal and evidentiary rigour required by the Criminal Code.

7.2.5. Recommendation 5: Assign Policy Responsibility for Animal Cruelty to Crown Law Criminal’s DV Team and Stream Files to DV Crowns in Local Offices

Context and Purpose: Animal cruelty offences—including neglect, abandonment, injury, sexual offences involving animals, and organized animal fighting—are legally complex and often intertwined with other serious public safety concerns. These offences regularly co-occur with IPV, coercive control, child endangerment, and in some cases, organized crime. Despite this, there is currently no assigned policy team within Crown Law Office—Criminal responsible for monitoring case law, developing interpretive guidance, or supporting frontline Crown attorneys handling these files. Similarly, in many regions, animal cruelty files are not systematically screened or triaged to specialized Crown teams, leading to inconsistent treatment and under-acknowledgment of risk.

This recommendation proposes a two-tiered structural response: first, assigning subject-matter responsibility to the Domestic Violence (DV) team at Crown Law Criminal; and second, flagging all animal cruelty charges as DV for the purpose of local file streaming, regardless of whether a domestic relationship is evident on the facts. While some animal cruelty charges are already flagged as DV based on case-specific indicators, the consistent association with interpersonal risk justifies broader file routing through the DV stream. In offices with the necessary resources, this approach could evolve into a dedicated animal cruelty assignment. Until then, this measure ensures alignment with Ontario’s existing risk-informed infrastructure.

Jurisdiction: The Ministry of the Attorney General has the authority to assign internal policy portfolios within Crown Law Criminal and to update the Crown Prosecution Manual accordingly. It also oversees operational guidance and streaming practices across regional Crown Attorney’s Offices, including the designation of specialized DV Crowns. The Ministry can implement internal SCOPE flags, issue streaming directives, and structure file ownership practices consistent with risk and public safety objectives.

Recommendation: The Ministry of the Attorney General should:

• Assign responsibility for the legal interpretation and policy development of Criminal Code animal cruelty offences—including sections 160, 445, 445.01, 445.1, 446, and 447—to the Domestic Violence policy team at Crown Law Office—Criminal. That team should:
  • Monitor case law and coordinate appellate positions;
  • Prepare legal memoranda and guidance materials for Crown offices;
  • Support policy alignment with charge screening, condition-setting, and risk framing.
• Ensure that all charges under the above provisions are:
  • Flagged internally in SCOPE and treated as DV-stream files;
  • Automatically streamed to the designated Domestic Violence Crown in each Crown Attorney’s Office;
  • Non-transferable outside the DV stream, except where re-assigned internally to a Crown with comparable experience in risk assessment and protective conditions.
• Update the Crown Prosecution Manual to include a directive on the prosecution of animal cruelty offences, addressing:
  • Charge selection guidance between the Provincial Animal Welfare Services Act and the Criminal Code, including public interest, offence severity, and evidentiary sufficiency;
  • Election guidance for hybrid Criminal Code offences, developed in consultation with subject-matter experts, and informed by risk considerations tailored to animal cruelty. Factors may include:
    • The death of an animal or serious injury likely to have resulted in death;
    • The number of animals affected;
    • The offender’s prior history of similar or related conduct;
    • Any clear connection to coercive control, child endangerment, or IPV;
    • The potential impact of a summary versus indictable proceeding on sentencing range, public safety, and lasting record consequences;
  • Conditions-related practice guidance, including the use of prohibition orders under section 447.1 and protective clauses under sections 515, 732.1, and 810 of the Criminal Code;
  • Risk and context framing guidance, including articulation of co-occurring harm (e.g., to children or partners) and red-flag indicators of escalation or organized conduct.

Implementation Considerations:

• Local DV Crowns may require additional training to support consistent treatment of these files, particularly where animal cruelty has not previously been handled in a specialized stream;
• Assignment to Crown Law Criminal’s DV team may require the rebalancing of internal portfolios to accommodate additional monitoring, appellate, and policy development responsibilities;
• SCOPE flagging and internal streaming protocols should mirror those already in place for DV and high-risk files, and be coordinated with case management staff;
• Updates to the Crown Policy Manual should be designed to complement police and judicial training, ensuring coherence across systems.

Rationale: Ontario’s existing DV prosecution infrastructure provides a well-developed, risk-oriented foundation for managing cases that intersect with family violence, coercive control, and repeat offending. These structures include dedicated Crown roles, file streaming protocols, and policy supports that facilitate specialized case handling and coordinated condition-setting. By assigning responsibility for animal cruelty prosecutions to the DV policy team at Crown Law Criminal and streaming related files to DV Crowns at the local level, the Ministry can immediately improve consistency, strengthen early risk recognition, and support public safety. As data and practice evolve, this structure may be refined or replaced by a dedicated animal cruelty prosecution stream. Until then, alignment with the DV model provides an operationally sound and strategically justified interim solution.

7.2.6. Recommendation 6: Amend Ontario’s Family Law Act to Allow Possession Orders for Companion Animals

Context and Purpose: In cases involving IPV, coercive control, or protracted separation conflict, animals are frequently used as instruments of leverage, intimidation, or punishment. The presence of a companion animal can also complicate safety planning for victims, particularly where children are attached to the animal or where there is fear that harm will be inflicted as a means of exerting control. Ontario courts currently lack a statutory mechanism to address this risk, and in the absence of legislative guidance, may default to property-based reasoning that overlooks the dynamics of coercion or family violence.

By enabling possession orders for companion animals under a structured and narrowly scoped provision, Ontario can give courts the tools to support safer separation and more stable household transitions. Framing these orders within a protective and risk-informed structure ensures that the reform remains focused on safety, not sentiment, and avoids creating a broader custody-style regime for animals. Aligning this change with Ontario’s evolving approach to coercive control strengthens the coherence of the province’s family law response and fills a documented procedural gap.

Jurisdiction: The Ministry of the Attorney General is responsible for the Family Law Act, RSO 1990, c F.3. Legislative changes to authorize possession orders involving pets could be made by amending section 24—Ontario’s exclusive possession provision—or, more likely, by introducing a new section 24.1. Unlike British Columbia, Ontario’s family property regime is based on equalization of value, not possession of specific items. There is no existing statutory structure that allows a court to assign ownership or possession of personal property outside of consent orders. Creating a narrowly scoped provision for companion animals would establish this authority in a defined and justifiable context.

Recommendation: The Government of Ontario should amend the Family Law Act, RSO 1990, c F.3, by amending section 24 or introducing a new section, perhaps 24.1, to authorize courts to grant possession orders for companion animals in separation and parenting contexts. The amended provision should:

• Define “companion animal” as a domesticated animal kept primarily for companionship and not for commercial or agricultural purposes;
• Permit the court to assign exclusive or joint possession of a companion animal to one or both parties;
• Clarify that legal ownership or title is not determinative and that possession may be assigned based on relational, welfare, and safety-based factors;
• Set out specific factors to guide judicial discretion, including:
  • The risk of family violence or coercive control;
  • The relationship between the animal and any children;
  • Each party’s history of care or harm toward the animal;
  • Each party’s ability and willingness to meet the animal’s needs;
  • The likelihood that a failure to assign clear possession would result in further conflict, harm, or distress;
• Explicitly clarify that the provision does not create a regime for shared possession, pet custody, or ongoing care schedules, and that companion animals are not to be treated as analogous to children for the purpose of separation orders;
• Establish that companion animal possession orders may be enforced through Ontario’s protection order regime, coordinated with broader reforms to protection order legislation and enforcement mechanisms addressed elsewhere in this report.

Implementation Considerations:

• Ontario lacks a general statutory mechanism for courts to grant possession of personal property. Creating one, even for companion animals alone, introduces a new doctrinal feature to the Family Law Act and may require careful drafting and inter-ministerial coordination.
• Legislative drafting should mirror the structure and clarity of British Columbia’s Family Law Act, s. 97(4.1), while accounting for Ontario’s exclusive possession framework and procedural norms.
• Judicial education and family law training materials should make clear that this provision is intended to support finality and safety, not to enable ongoing disputes over custody or shared animal care.
• Implementation should be coordinated with planned updates to Ontario’s protection order landscape to ensure that possession orders for pets are enforceable and recognized across court systems.

Rationale: Companion animals often serve as emotional supports for children or adult victims of family violence. They may also be targeted or exploited by abusers as tools of coercion and control. Without a statutory mechanism to assign possession of animals, family courts are unable to meaningfully respond to a frequent source of conflict and risk in separation proceedings. A narrowly scoped legislative amendment—either through section 24 or a new section 24.1—would provide courts with clear, limited authority to assign pet possession where justified. Embedding enforcement through the protection order regime ensures that such orders are functional and protective, not symbolic. Importantly, the provision must be drafted to avoid creating a parallel child custody regime for animals. Aligning this reform with Ontario’s broader modernization of risk-responsive family law strengthens the province’s commitment to safety, trauma awareness, and effective separation processes.

7.2.7. Recommendation 7: Amend Ontario’s Civil Protection Order Legislation to Include Companion Animals

Context and Purpose: In cases involving IPV, coercive control, or risk to children, threats or harm to companion animals are frequently used to intimidate, punish, or destabilize victims. Victims may delay separation or return to unsafe households out of concern for the animal’s safety, particularly when children are emotionally attached to the animal or when the animal is used as leverage. While courts can currently impose animal-related conditions in criminal matters (e.g., through bail, probation, or peace bonds), they may be strengthened with explicit reference to animals and pets.

In contrast, 41 U.S. states and the District of Columbia allow courts to include animal-related clauses in civil protection orders, including exclusive possession, prohibitions against harm or removal, and police-enforceable compliance terms. British Columbia’s Family Law Act permits similar relief in family protection contexts. In Ontario, the absence of this authority limits courts’ ability to provide practical, enforceable protection in high-risk family violence matters. Adding this tool would close a known risk gap and support Ontario’s broader commitment to risk-informed, trauma-responsive legal frameworks.

Jurisdiction: The Ministry of the Attorney General holds responsibility for Ontario’s family and civil protection order statutes, including the Family Law Act, the Children’s Law Reform Act, and relevant parts of the Courts of Justice Act. The Ministry may amend these statutes or introduce a standalone provision to authorize pet-related protection clauses. These reforms fall within Ontario’s jurisdiction and can be implemented independently of federal action. This recommendation should be implemented in tandem with broader reforms to protection order infrastructure proposed elsewhere in this report.

Recommendation: The Government of Ontario should amend its protection order legislation—either by amending the Family Law Act or by introducing a new, standalone provision—to explicitly authorize courts to include pet-related conditions in civil protection orders. The statute should provide that:

• The court may grant exclusive possession of a companion animal to the applicant;
• The court may prohibit the respondent from threatening, harming, hiding, selling, or otherwise interfering with a companion animal;
• The court may prohibit the respondent from attending at the location where the animal is kept, or from interfering with veterinary care, food, shelter, or other basic needs;
• The court may direct law enforcement to assist in retrieving or transferring the animal, where necessary;
• Relief may be granted regardless of legal ownership, where the court is satisfied that the relief is necessary to reduce risk or prevent coercive harm;
• A “companion animal” should be defined as a domesticated animal kept primarily for companionship and not for commercial or agricultural purposes.

All conditions issued under this provision must be enforceable and accompanied by appropriate compliance mechanisms, including police authority to assist with execution where needed. The provision should be drafted to ensure consistency with Ontario’s broader protection order modernization efforts and should complement, not duplicate, possession-based reforms proposed under the Family Law Act.

Implementation Considerations:

• Ontario’s protection order legislation must be amended to clearly authorize police enforcement of animal-related clauses, including assistance with retrieval or transfer;
• Plain-language application forms, judicial training materials, and benchbooks should be updated to reflect this authority and to align with guidance issued under Recommendation 3;
• While this provision is scoped to companion animals, the Ministry should remain attentive to emerging recognition of livestock-related coercive control in rural family violence contexts. Courts should not be precluded from applying risk-based discretion in such cases, where safety concerns are clearly established.

Rationale: Animals are frequently entangled in the dynamics of family violence, both as emotional leverage and as targets of intimidation. When no legislative authority exists to include pet-related conditions in civil protection orders, courts are unable to respond meaningfully to known vectors of risk. Victims may be forced to choose between personal safety and animal safety, or to delay protective action in the absence of legal remedies. Authorizing courts to issue animal-related protection conditions—modeled after U.S. statutes and aligned with current criminal authorities—would fill a documented structural gap, enhance coherence across Ontario’s risk response systems, and better equip family and civil courts to protect victims from coercion, intimidation, and harm.

7.2.8. Recommendation 8: Evaluate the Inclusion of Animal Cruelty in Ontario’s Risk Assessment Tools and Triage Protocols

Context and Purpose: Animal cruelty is increasingly recognized in the research literature as a potential indicator of future risk, particularly in cases involving intimate partner violence, child maltreatment, and coercive control. Despite this, Ontario’s core risk assessment tools—including ODARA, B-SAFER, DVRM, the Eligibility Spectrum, and the CFRA—do not currently include animal cruelty as a structured domain. This omission may limit the ability of police, Crowns, probation officers, and child protection workers to identify risk early and intervene appropriately.

At the same time, other risk domains—such as coercive control, technology-facilitated abuse, and economic abuse—have gained prominence since many of these tools were first developed. A broader review of Ontario’s risk instruments is warranted to determine whether these evolving forms of harm should be structurally integrated. This includes not only assessing their relevance but also evaluating whether existing tools maintain predictive validity when such domains are added.

Jurisdiction: Ontario’s risk assessment and screening tools are used across multiple sectors, including policing, bail court, child protection, probation, and correctional services. These tools vary in origin—some are developed externally, while others are provincially maintained. The Ministries of the Solicitor General, Children, Community and Social Services, and the Attorney General all have operational responsibility for systems in which these tools are used. As such, a coordinated, government-initiated review process is required to ensure consistent and methodologically sound decision-making across sectors.

Recommendation: The Ministries of the Solicitor General, Children, Community and Social Services, and the Attorney General should jointly initiate and fund a time-limited review of Ontario’s violence risk assessment and screening tools to determine whether indicators of animal cruelty—and other underrepresented domains such as coercive control, economic abuse, and technology-facilitated abuse—should be structurally integrated. This review should:

• Include tools such as:
  • ODARA, B-SAFER, and DVRM (used by police, Crowns, and in bail proceedings);
  • Eligibility Spectrum, CPRA, and CFRA (used by child protection workers);
  • Correctional tools used at probation intake or in custodial risk classification;
• Be led by or in collaboration with the original developers or designated research leads for each tool;
• Examine whether the addition of animal cruelty indicators would contribute independent or additive predictive value;
• Determine whether inclusion would require full tool revalidation, and if so, what scope of research, testing, and sample size would be necessary;
• Assess whether modification is feasible within the tool’s existing structure or whether supplementary prompts and structured professional judgment guidance are more appropriate;
• Be supported by a clearly scoped funding stream with deliverables that include:
  • A determination of whether animal cruelty and other flagged domains should be included;
  • Evidence of predictive performance post-inclusion;
  • An assessment of revalidation needs, timelines, and feasibility.

Implementation Considerations:

• Risk assessment tools must retain statistical defensibility and operational utility. Any additions must be methodologically sound and appropriately tested;
• Some tools may not be modifiable in the short term due to licensing, cross-jurisdictional use, or validation design. In these cases, ministries may issue supplementary prompts or documentation guidance to ensure that animal cruelty is considered during structured judgment or case planning;
• Inter-ministerial coordination is essential to ensure definitional consistency and to avoid duplication;
• This review process should be aligned with broader system modernization efforts across police, Crown, child protection, and probation services.

Rationale: Structured risk tools are central to how Ontario screens, triages, and manages cases involving violence and coercive harm. These tools must evolve as the evidence base and legal landscape change. Emerging risk domains—including animal cruelty—are now better understood, but have not yet been tested for formal integration. A government-initiated and funded review is essential to evaluate whether such domains offer predictive value, and whether they can be integrated without compromising tool validity, statistical integrity, or practical function. This review would provide the evidentiary foundation needed to guide risk tool modernization in a careful, methodical, and system-wide manner.

7.2.9. Recommendation 9: Recognize Livestock-Related Coercive Control in Rural IPV Screening and Triage

Context and Purpose: In rural and agricultural communities, threats to livestock—including neglect, abandonment, disposal, or intentional harm—can be used as powerful tools of coercive control in IPV contexts. Livestock may hold significant emotional value, serve as a child’s 4H project, or represent the family’s primary economic livelihood. Threats to harm or destroy animals can delay separation, suppress disclosure, or be used to punish a victim’s noncompliance. These tactics are often indistinguishable in function from other forms of coercive control but are structurally overlooked in safety planning and triage.

Discussions of the violence link—including its integration into screening tools—have primarily focused on harm to companion animals. However, in rural IPV contexts, threats to livestock function in similarly coercive ways and can carry great psychological, financial, and practical impact. These dynamics are often overlooked in mainstream risk framing, despite their significance for safety planning and early intervention.

Jurisdiction: The Ministries of the Solicitor General, the Attorney General, Children, Community and Social Services, Agriculture, Food and Agribusiness, and Rural Affairs each have a role in ensuring that IPV risk screening and response structures are appropriate to rural and agricultural contexts. No legislative amendment is required to improve recognition of livestock-related coercive control; however, cross-ministry coordination and policy guidance are needed to ensure it is structurally visible across sectors.

Recommendation: The Ministries of the Solicitor General, the Attorney General, Children, Community and Social Services, Agriculture, Food and Agribusiness, and Rural Affairs should work collaboratively to issue cross-sectoral guidance and/or triage updates that:

• Acknowledge livestock-related threats, control, or harm as a potential form of coercive control in rural IPV contexts;
• Instruct police, shelter intake staff, EIP tables, and victim services workers to screen for livestock-related threats, particularly where victims identify ongoing conflict in a farming or animal-based household;
• Provide examples of livestock-related coercion, including threats to slaughter animals, withhold food or care, or sell shared farm animals in retaliation for disclosure or separation;
• Encourage local IPV coordination tables, High-Risk Committee meetings, and DV court stakeholders in rural areas to consider the potential role of livestock-related threats in their case management discussions;
• Incorporate livestock-related screening prompts into police triage tools, shelter intake forms, and child protection documentation templates where applicable;
• Ensure that front-line justice system and shelter staff understand that this recommendation is not about livestock law enforcement but about flagging coercive risk indicators that are unique to rural IPV settings.

Implementation Considerations:

• No legislative or regulatory amendments are required to implement this recommendation;
• Materials and triage prompts may be developed or piloted in partnership with rural shelters, OPP detachment leads, High-Risk Committee coordinators, and victim support agencies in agricultural regions;
• Stakeholders should be reminded that the goal is not to change how livestock are regulated or protected, but to recognize livestock threats as a relational violence indicator within IPV dynamics;
• Where regional IPV coordination hubs are created (as envisioned under the proposed Ontario Intersectoral Violence Prevention and Risk Network), these hubs may play a role in standardizing rural IPV screening protocols and ensuring livestock-related coercion is recognized in triage and file planning;
• Sector-specific examples should be developed with support from Agriculture, Food and Agribusiness and Rural Affairs as well as other trusted rural-facing institutions to ensure cultural and contextual relevance.

Rationale: In rural Ontario, livestock are not only economic assets but also deeply embedded in household dynamics. Where animals represent livelihood, emotional investment, or family history, threats to harm or dispose of livestock can carry profound coercive weight. These dynamics often go unrecognized by urban-centered service systems, which may not understand the role of livestock in coercive control. By providing screening prompts and structured guidance to front-line professionals, Ontario can ensure that rural IPV victims are not excluded from risk-informed intervention simply because their form of control falls outside conventional frameworks. This is not a recommendation about livestock regulation—it is a targeted structural correction to improve coercive control recognition in contexts that have been historically overlooked.

7.2.10. Recommendation 10: Establish a Northern and Remote Companion Animal Veterinary Access Fund

Context and Purpose: Veterinary access is a foundational component of compliance under Ontario’s animal welfare legislation, including the Provincial Animal Welfare Services Act, 2019 and relevant provisions of the Criminal Code. In many northern and remote communities, however, consistent access to veterinary services for companion animals—particularly dogs—is logistically unfeasible for much of the year. These areas face long-standing service gaps, including the absence of year-round clinics, limitations on mobile unit capacity, and challenges in securing veterinary documentation for either preventive care or legal proceedings.

Where no veterinary services are accessible within a reasonable radius or seasonal window, individuals and communities may face structural barriers to compliance. This creates operational challenges not only for residents but also for investigators, courts, and compliance systems that rely on veterinary input. A stable, government-funded access mechanism—delivered through trusted service partners—would support equitable compliance and reduce structural service disparities, without introducing new obligations or enforcement burdens.

Jurisdiction: The Ministry of the Solicitor General is responsible for the PAWS Act and for oversight of provincial enforcement infrastructure. The Ministry of Agriculture, Food and Agribusiness regulates veterinary licensure and has oversight of veterinary education and rural practice supports. The Ministry of Health may also intersect with this work through mobile care logistics and public health coordination. The Government of Ontario has the authority to fund veterinary access services through transfer payment-style agreements and to establish arm’s-length delivery partnerships that enable reliable, community-requested care in underserved regions.

Recommendation: The Government of Ontario should establish a stable, annualized veterinary access fund to support intermittent service delivery for companion animals in northern and remote communities without year-round access to veterinary care. The fund should:

• Be delivered through multi-year agreements with non-profit organizations, mobile veterinary units, veterinary educators, or service consortia that have demonstrated experience providing companion animal care in remote contexts;
• Be designed in consultation with current service providers, the Ontario Veterinary College (OVC), and representatives from remote or service-limited communities, to ensure alignment with real-world delivery conditions;
• Prioritize core services necessary for legal compliance for companion animals, including population management (e.g., spay/neuter), emergency care, and documentation suitable for enforcement, investigation, or protective intervention;
• Be available to support service delivery only in communities that request or welcome participation;
• Be structured to support low-administration, arm’s-length service coordination, while ensuring that basic cost and coverage data are collected to inform future planning.

Implementation Considerations:

• The fund should be managed through a dedicated envelope that enables stable, long-range planning by participating organizations, and avoids requiring year-to-year reapplication to maintain continuity of care;
• Program eligibility criteria should reflect experience delivering companion animal services in remote regions and a demonstrated understanding of logistical access barriers that affect households with domestic pets;
• Community participation must remain voluntary, and no outreach or service expansion should occur without local interest or agreement;
• Transfer payment agreements should be structured to preserve operational autonomy while enabling accountability through routine reporting and outcome tracking;
• Relevant Ministries should ensure that licensure, transport, and insurance regulations do not present unintended barriers to mobile or intermittent veterinary practice in underserved areas.

Rationale: Animal welfare enforcement frameworks assume that veterinary services are accessible province-wide. In large parts of northern Ontario, that assumption is inaccurate. Lack of access does not reflect unwillingness to comply—it reflects the absence of infrastructure. This recommendation does not address livestock care or agricultural veterinary systems. Its sole focus is on enabling access to basic veterinary services for companion animals—particularly dogs—through low-barrier, community-welcomed models. By supporting delivery through organizations that already provide intermittent care, Ontario can enable functional compliance in areas where permanent services are not viable. This is a logistics and infrastructure response to a known access barrier, not a reform initiative or public education program.

Section 8: Firearms and Intimate Partner Violence in Ontario

8.1. Governance Framework for Firearm Control in Ontario

8.1.1. Federal and Provincial Roles

Firearm regulation in Canada is primarily federal, governed by the Criminal Code and the Firearms Act.⁸¹⁰ The Criminal Code defines firearm-related offences (e.g. illegal possession, use, transfer) and establishes firearm classifications (non-restricted, restricted, prohibited). The Firearms Act (administered by the federal Minister of Public Safety) sets out the licensing regime and rules for possession, storage, transportation and acquisition of firearms.⁸¹¹ Under this federal framework, provinces have a limited role: they may regulate the property and civil rights components of firearms (e.g. hunting regulations, shooting range safety, sales requirements) but cannot create criminal law.⁸¹² Crucially, provinces can opt to administer the Firearms Act through a provincially appointed Chief Firearms Officer (CFO). Ontario is one of seven provinces that have “opted-in” to have their own CFO responsible for local oversight of firearms licensing and safety, under delegation of federal law.

8.1.2. Licensing (PAL) and Registration

To legally own or acquire firearms in Canada, individuals must obtain a Possession and Acquisition Licence (PAL) through a vetting process under the Firearms Act.⁸¹³ The CFO of the province issues PALs after background checks, including screening for criminal records, domestic violence history, and references. Applicants are required to pass safety training and (for restricted weapons) must obtain additional authorizations. All restricted firearms in Canada must be registered in the national database maintained by the RCMP’s Canadian Firearms Program. Non-restricted firearms (such as ordinary rifles and shotguns) are not individually registered in most provinces due to the 2012 ending of the long-gun registry, meaning their ownership is tracked only via the owner’s PAL record and point-of-sale records. The RCMP CFP maintains the Canadian Firearms Information System, which police can query (via CPIC) to see if a person has a licence or registered guns. Overall, the federal government retains full authority over licensing standards and firearm classifications, while the province (through the CFO and local police) delivers the program on the ground.

8.1.3. Chief Firearms Officer’s Powers and Responsibilities

Ontario’s CFO plays a critical role in administering firearms law and has broad authority to enhance public safety. The CFO’s duties include issuing and renewing individual PALs, issuing licences to businesses, approving firearm transfers (especially for restricted/prohibited firearms), and authorizing transport of restricted firearms. The CFO is responsible for ensuring continuous eligibility of licence holders—meaning they must monitor and revoke licences if an individual no longer meets safety criteria. Under the Firearms Act, the CFO has discretion to deny or revoke a licence if a person poses a risk to themselves or others (e.g. due to violence, mental instability, or misrepresentation). This includes the authority to attach conditions to a licence or an authorization (for example, requiring safe storage measures, or limiting a restricted gun owner’s approved uses). The CFO can appoint firearms officers to conduct inspections of businesses and, with proper process, inspect private owners’ storage to ensure compliance with regulations.

Notably, recent legislative amendments have strengthened the CFO’s mandate in domestic violence situations. As of 2023, the Firearms Act now requires a CFO to suspend or revoke a licence promptly upon receiving information that the holder has engaged in domestic violence, even if no criminal charge has yet been laid.⁸¹⁴ For example, if a CFO has reasonable grounds to suspect an individual of violence toward an intimate partner (as defined broadly in the Act), the CFO must revoke their PAL within 24 hours. Similarly, if a person becomes subject to a court protection order, their firearms licence is automatically revoked, and they must surrender any firearms in their possession within 24 hours. These provisions underscore the CFO’s responsibility to act decisively to remove firearms access from individuals deemed a safety risk in the context of IPV.

8.1.4. Role of Police and Courts in Enforcement

While the CFO administers licensing, day-to-day enforcement of firearm laws in Ontario involves a coordinated effort among police, courts, and other agencies. Local and provincial police services are on the front lines: they respond to domestic violence incidents, seize firearms when necessary, and lay charges for firearms-related offences under the Criminal Code.

Police are also tasked with enforcing court orders that prohibit an individual from possessing weapons. For example, if a person is released on bail for a domestic assault, the court will almost invariably include a condition prohibiting firearms possession and requiring the surrender of any guns and licences. Under Criminal Code section 515(4.1), such weapons prohibitions must be considered at bail for offences involving violence.⁸¹⁵

Police services have policies (strengthened after past inquests) to proactively remove firearms in domestic calls—conducting searches or obtaining warrants if there is reason to believe firearms are present and pose a danger. The importance of these practices was highlighted by the Arlene May inquest: in that case, the perpetrator had been released on bail with an order to surrender his firearms licence, yet no one ensured compliance, and he legally purchased the shotgun used to kill his former partner. Today, when an accused is charged in a domestic incident, police are expected to query the national firearms database and ask about firearms access. If firearms or licences are present, officers should seize them for public safety pending further order.

Courts play a key role through firearm prohibition orders. In criminal proceedings, judges must impose mandatory firearms prohibitions on anyone convicted of a serious violent offence or any offence involving a firearm. Even for other domestic violence crimes (e.g. assault, criminal harassment), judges commonly issue discretionary prohibition orders under Criminal Code Section 110, barring the offender from possessing firearms for a period (often 10 years or more for serious domestic violence). These orders trigger legal obligations to surrender all firearms and any PAL to police or the CFO. However, enforcement can be challenging—it relies on the offender to comply or on police to execute search warrants if non-compliance is suspected.

There is evidence that compliance checks have not always been consistent or timely. Past inquests uncovered gaps where prohibited persons retained firearms due to poor communication between courts, police, and the CFO. In response, information-sharing has improved (for instance, all firearms prohibition orders are recorded in CPIC, and the CFO’s Firearms Interest Police (FIP) flag system alerts authorities of licence holders who are persons of concern). The recent federal amendments go further by requiring that if a person is subject to a court protection order, their firearms licence is automatically revoked, and they must surrender any firearms in their possession within 24 hours.⁸¹⁶ This is a significant development bridging civil and criminal realms, effectively mandating coordination so that a civil order to protect a victim results in immediate firearm removal action.

8.1.5. Family and Civil Court Measures

Traditionally, Ontario’s family courts had limited direct authority over firearms in domestic violence cases. The provincial Family Law Act allows courts to issue restraining orders to protect an estranged partner, but these orders mainly restrict contact and proximity (e.g. requiring the respondent to stay away from the victim’s home or workplace). There is no explicit provision in Ontario family law empowering a family judge to order the surrender of firearms or a firearms licence as part of a restraining order. In practice, if a family judge is concerned about guns, they may include a general term like “not to possess weapons,” but enforcement would rely on the person’s compliance or parallel action by police under criminal law.

The Divorce Act (federal) was amended in 2021 to recognize family violence and encourage considering safety in parenting orders, but it too provides no direct mechanism for weapons prohibition in family proceedings.⁸¹⁷ This historical separation of civil and criminal tools meant that victims seeking safety through family court had to separately alert police or a CFO about firearm risks. Ontario did consider a Domestic Violence Protection Act in 2000 (Bill 117),⁸¹⁸ which would have allowed emergency orders including weapon surrender, but it was never brought into force. Thus, until recently, the onus remained on criminal justice channels to address firearms.

In 2023, the federal Firearms Act was amended through Bill C-21 to include a new provision—section 70.1—which requires the Chief Firearms Officer (CFO) to revoke a person’s firearms licence if they are subject to a protection order, or if there are reasonable grounds to suspect they have engaged in domestic violence or stalking.⁸¹⁹ Revised procedures, policies, process, and education on such is now needed.

If the forthcoming regulations include Ontario family court restraining orders under s. 46 of the Family Law Act, such orders would trigger mandatory PAL revocation, but only if the CFO is made aware of the order. At present, no system exists to ensure that family court restraining orders are sent to the CFO. Ontario therefore has an immediate opportunity to close this enforcement gap by legislatively requiring that restraining orders involving IPV risk be forwarded to the CFO and local police. Creating this notification mechanism would operationalize federal law, ensure timely licence revocation where required, and significantly improve firearm risk management in the family law context.

8.2. Recommendations

8.2.1. Recommendation 1: Expand Anonymous Violence and Firearm Risk Reporting via Partnership with Crime Stoppers

The Ontario government should partner with the Ontario Association of Crime Stoppers (OACS) to implement a province-wide initiative enabling anonymous public reporting of potential risks in the context of intimate partner violence (IPV), sexual violence (SV), human trafficking (HT), and firearm access. This would allow family members, neighbours, survivors, or service providers to report known or suspected violence, coercive control, or firearm access—before more serious crime occurs.

While Crime Stoppers is the only anonymous province-wide system that could support such reporting, many Ontarians do not understand that it could be used to report preventive concerns regarding escalating violence or firearms access, and the current digital platform does not clearly welcome or support tips involving domestic, sexual, or human trafficking-related risk. This recommendation works from the existing success of the Crime Stoppers platform, expands its scope, and launches an accompanying awareness and training initiative focused on firearm-related threats—but also improves access to anonymous reporting more broadly, for all forms of escalating violence risk.

Implementation Details:

• Partnership Structure:
  • The Ministry of the Solicitor General should enter into a formal agreement with OACS to:
  • Promote Crime Stoppers as an escalating violence prevention-focused tool for reporting IPV/SV/HT and firearm-related risks;
  • Ensure that tips involving firearms, coercive control, or high-risk domestic situations are flagged and triaged appropriately to local police services and, where applicable, to the Chief Firearms Officer (CFO) for PAL/licence review.
• Platform Modernization:
  • The government should provide funding and strategic support for OACS to:
  • Update its online tip form and backend system to include clear categories such as “Intimate Partner Violence,” “Sexual Violence,” “Firearm Risk,” and “Human Trafficking”;
  • Redesign the user experience (UX) to reflect that Crime Stoppers accepts tips about people at risk of committing harm, not only reports of past or solved crimes;
  • Add public-facing language stating that anonymity is guaranteed, and tipsters will never be contacted or required to testify;
  • Include plain-language information about what may happen after a tip is submitted (e.g., referral to police, CFO review, no follow-up obligation).
• Awareness Campaign:
  • Launch a province-wide, time-limited campaign—especially in rural, northern, Indigenous, newcomer, and gun-owning communities—to educate the public that:
  • You can report a concern that someone may commit a violent offence, not just past or solved crimes;
  • Crime Stoppers tips are completely anonymous, and tipsters will never be contacted;
  • Police and the CFO can take preventive action, including PAL revocation, even without a criminal charge, under s. 70.1 of the Firearms Act.
• Training: Ensure Crime Stoppers call-takers and coordinators receive trauma-informed training from IPV/SV/HT experts, in partnership with the Ontario Network of Sexual Assault/Domestic Violence Treatment Centres, the Ontario Network of Victim Service Providers, and the CFO’s office.
• Police Service Protocols:
  • The Ministry of the Solicitor General should direct all Ontario police services to:
  • Develop or update internal policies clarifying how to triage and respond to Crime Stoppers tips involving IPV, SV, HT, and firearms;
  • Ensure all such tips—regardless of whether charges are laid—are recorded in the service’s records management system as an occurrence linked to the named individual, location, or context (similar to “information-only” threat reports);
  • Establish a referral protocol to notify the CFO when PAL ownership is mentioned or suspected.

Costing and Implementation:

• The Ministry of the Solicitor General will need to determine costs associated with:
  • Updating Crime Stoppers’ digital infrastructure, including translation and UX redesign to clarify that the platform supports reporting of IPV/SV/HT-related concerns, not just criminal offences, and even in the absence of firearm risk;
  • Training for call-takers and coordinators on receiving and triaging prevention-based tips in a trauma-informed manner;
  • Designing and delivering a public awareness campaign in partnership with trusted local intermediaries (e.g., gun clubs, police services, settlement agencies, Indigenous organizations);
  • Creating print and digital education materials for distribution in firearm retailers, shooting clubs, police stations, victim services, and newcomer support organizations.
• A full rollout of this initiative—including platform modernization, tip form updates, training, and a province-wide awareness campaign—is expected to require approximately 8 to 12 months from project start through public launch and early evaluation. This timeframe accounts for planning, stakeholder engagement, content development, technical upgrades, and campaign execution.

• Following rollout, key data metrics should be collected and reviewed on an ongoing basis to support continuous improvement of public messaging, reporting pathways, and enforcement protocols. Metrics should include:

  • Number and type of tips received (firearm-related and otherwise),
  • Geographic distribution,
  • Referral rates to police or the CFO,
  • Enforcement outcomes and stakeholder feedback.

  This data should be used to assess where refinements are needed in campaign targeting, tip triage, or system integration, and to ensure that the initiative continues to respond effectively to public safety priorities.

• This initiative constitutes a functional expansion of Crime Stoppers’ traditional mandate—from post-crime tip collection to violence prevention and risk reporting. Most local Crime Stoppers programs are currently sustained through charitable fundraising and community partnerships, not core provincial funding. Dedicated operational support from the province will be required to ensure capacity, equity of access across jurisdictions, and sustainability.

Rationale: Currently, Ontario has no dedicated anonymous reporting mechanism for firearm-related risk in IPV/SV/HT contexts. While Crime Stoppers is widely used for reporting past criminal activity, it is not currently positioned or resourced as a tool for early reporting of escalating risk. The federal Canadian Firearms Program’s reporting line is narrowly limited and is largely unknown to the public.⁸²⁰ This recommendation would expand Crime Stoppers’ functional role—while still respecting its scope—to allow credible, violence-related risk disclosures to be submitted safely and anonymously. These might include concerns that:

• A person under a restraining order still has firearms;
• A survivor is afraid to report threats because they live in a small community;
• A neighbour hears escalating conflict in a home where they know firearms are present.

This is not a general-purpose “tip line” for vague suspicions—it is a structured violence prevention tool aimed at ensuring the public can report known risks involving IPV, SV, HT, and firearms without fear of retaliation. It also ensures that police respond consistently and track the information, even if no charges follow immediately. This aligns with the Ontario government priorities of crime prevention, victim safety, and public accountability.

Proposed Legislative Linkage (if required): No legislative change is required. However, the Ministry of the Solicitor General may wish to issue a directive under its authority in the Police Services Act, clarifying that police services boards must work with Crime Stoppers to:

• Respond to IPV/firearm-related tips;
• Develop appropriate internal referral protocols; and
• Ensure that the CFO is notified where PAL-holders or known firearm access is involved.⁸²¹

8.2.2. Recommendation 2: Implement a Provincial Domestic Violence Firearm Education Program for PAL Holders, Retailers, and Gun Clubs

The Ontario government should fund and implement a firearms safety education program—delivered in collaboration with the federal Canadian Firearms Program (CFP), the Chief Firearms Officer (CFO) of Ontario, and subject matter experts—that targets:

• Licensed firearm owners (PAL holders),
• Firearm retailers,
• Range and club safety officers, and
• Hunting/outdoor associations.

The program should focus specifically on domestic violence prevention, safe storage during family conflict, and red flag identification.

Implementation Details:

• Program Design and Oversight:
  • Led by the Ministry of the Solicitor General, in partnership with the Chief Firearms Officer of Ontario and the Canadian Firearms Program.
  • Drafted with input from members of the Domestic Violence Death Review Committee (DVDRC), particularly those with expertise in firearms, risk factors, and fatality prevention.
• Stakeholder Review:
  • Draft materials should be shared with:
    • Representatives of victim services and survivor advocacy organizations (e.g. OAITH, Luke’s Place),
    • Representatives of Ontario’s firearm community (e.g. Ontario Federation of Anglers and Hunters, Canadian Coalition for Firearm Rights, and local sport shooting clubs).
  • The purpose of consultation is to ensure materials are:
    • Trauma-informed and factually accurate,
    • Accessible and clear,
    • Received as constructive and useful by the firearm-owning public.
• Core Components:
  • A mailed IPV and firearm safety insert to all PAL holders in Ontario (one-pager on the relationship between firearm ownership and risk of domestic homicide, safe storage during separation, warning signs of coercive control, and how to contact police or the CFO if someone is unsafe).
  • A free, 30-minute online training module for PAL holders (similar in structure to hunter safety refreshers) hosted on the CFP site.
  • Retailer and club toolkits (posters, counter brochures, and private-range signage) to be distributed to all authorized Ontario retailers and clubs via CFO mailing lists.
  • Content should include:
    • Why and how firearm ownership is a risk factor for domestic homicide and domestic homicide-suicide,
    • How to temporarily transfer firearms during marital breakdown or protective order periods,
    • Red flags to watch for in buyer behaviour (e.g. extreme anxiety, aggressive questions about legal use),
    • How and when to contact police or the CFO with concerns,
    • Information about anonymous reporting via Crime Stoppers (linking to Recommendation 1).
• Mandatory Posting Requirement:
  • Although the Shooting Clubs and Shooting Ranges Regulations, SOR/98-212, are federal regulations under the Firearms Act, the Ontario CFO is responsible for their enforcement and may impose additional approval conditions under section 29.⁸²²
  • Accordingly, the Ontario CFO should require, as a condition of shooting club or range approval, that all clubs prominently display a standardized awareness poster titled “Responsible Firearm Ownership and Family Safety”.
  • The poster should:
    • Show how a commitment to firearm safety aligns with valuing safety of all family members,
    • Emphasize safe firearm storage during family conflict,
    • Provide contact information for Crime Stoppers, the CFO, and local police,
    • Use non-stigmatizing imagery and wording appealing to hunters, sport shooters, and collectors.

  • Suggested language for CFO approval condition:

    “Pursuant to the authority granted under section 29 of the Firearms Act, the Chief Firearms Officer of Ontario requires all approved shooting clubs and ranges to post, in a public-facing location, the Ministry-issued poster titled Responsible Firearm Ownership and Family Safety, and to maintain its visibility and condition in accordance with Ministry instructions.”

  • Printing and distribution costs should be covered by the province for the first year.
• Delivery Channels:
  • Printed materials shipped to every firearm vendor and club in Ontario (per CFO database),
  • Integration into new PAL course instructor kits via the RCMP CFP,
  • Optional “badge” program for businesses or clubs completing training (e.g. “Certified Violence Prevention Ally”).
• Costing and Evaluation:
  • The Ministry of the Solicitor General will determine cost implications of:
    • Materials production and mailing (one-time),
    • Online module development and hosting,
    • Partnered awareness campaign.
  • Pilot evaluation can be conducted via a small number of participating gun clubs and retailers before provincial rollout.

Rationale: Research and DVDRC reviews have recommended public education campaigns about how to report public safety concerns related to firearms where there is a history of intimate partner violence or serious mental health concerns.⁸²³ Firearms owners overwhelmingly value safety, legality, and community standards. This recommendation enables lawful owners to be part of the solution, rather than treated as a risk category. Data on the attitudes of Canadian or Ontario gun-owners was not available, but a 2023 U.S. study found that nearly 80% of gun owners support laws that temporarily prohibit firearm access for individuals subject to domestic violence protection orders.⁸²⁴ Requiring visible, standardized materials at retail and club points of contact ensures no one is left without the information they need to act.

8.2.3. Recommendation 3: Incorporate Firearms Risk Education into the Expanded Neighbours, Friends and Families Campaign

Rather than recommending the creation of a standalone, public-facing website hosted by the Chief Firearms Officer (CFO), the Subcommittee proposes that firearms-related public education and safety information be integrated directly into the expanded, province-wide Neighbours, Friends and Families (NFF) campaign and community resource platform, as envisioned in the prevention section of this report.

While Alberta has developed an independent CFO website that provides licensing and compliance information for firearm owners, this report does not recommend a similar approach in Ontario. A separate provincial platform would require new funding, infrastructure, and sustained promotion—and may have limited public reach or recognition. By contrast, integrating firearms education into the NFF campaign ensures that messaging is embedded within an existing evidence-informed IPV prevention initiative, reaches a broader range of Ontarians—including rural, northern, and firearm-owning communities—and avoids duplication of public awareness infrastructure.

Implementation Details:

• Content Development:
  • The expanded NFF platform should include both violence-prevention messaging and information relevant to responsible firearm ownership, such as:
    • The connection between firearms and domestic homicide risk;
    • Warning signs and risk factors involving firearms;
    • How to raise concerns (e.g., through Crime Stoppers, police, CFO);
    • What to expect after reporting (including limitations and next steps);
    • PAL responsibilities (e.g., prohibited transfers, red flag indicators);
    • Basic safe storage, transport, and compliance inspection standards, to give firearm owners, neighbours, and service providers clear, accurate reference points for determining when behaviour may be unsafe or unlawful.
• Platform Integration:
  • The updated NFF website will act as the central public access point for both IPV prevention messaging and firearms-related safety guidance.
  • All posters, brochures, and toolkits provided to firearm retailers, gun clubs, and police (as outlined in Recommendation 2) should include the NFF web address as the primary link for public information.
• Coordination with Crime Stoppers:
  • Crime Stoppers and NFF serve complementary but distinct purposes:
    • The expanded NFF platform, as proposed, is a public education initiative that helps people understand how IPV, coercive control, and firearms can intersect, how to support someone at risk, and how to identify warning signs and risk factors;
    • Crime Stoppers offers a secure, anonymous way for individuals to share information with authorities if they believe someone may be at risk of harming themselves or others and do not feel safe reporting through official channels.
  • The NFF website should include a clearly marked link to the Crime Stoppers portal, as well as to the Canadian Firearms Program (CFP) reporting line, along with plain-language guidance to help people understand:
    • The availability of anonymous and non-anonymous reporting for concerns about firearms;
    • The kinds of situations where reporting may be appropriate (e.g. escalating conflict, illegal firearm possession, concerning behaviour by someone known to have firearms);
    • What types of information can help authorities assess risk (e.g. the presence of firearms, protective orders, threats, recent separation);
    • The difference between submitting an anonymous tip and making a formal report to police or the CFO;
    • What, if anything, a tipster can expect after submitting a concern.
• Community Engagement:
  • Development of firearm-related NFF content should be informed by:
    • Members of the Domestic Violence Death Review Committee (DVDRC),
    • The Chief Firearms Officer of Ontario,
    • Representatives of firearm-owner communities (e.g., Ontario Federation of Anglers and Hunters, Ontario rifle associations).
  • This ensures content is accurate, trauma-informed, non-stigmatizing, and practical.
• Funding and Evaluation:
  • This initiative should be funded through the broader expansion of NFF recommended in the prevention section of this report.
  • Evaluation should include feedback from both firearm owners and IPV prevention stakeholders to ensure the messaging is trusted, accessible, and effective.

Rationale: Public awareness about the risk of firearms in domestic violence situations is essential, but so too is clarity for firearm owners and community members about what safe, legal, and responsible gun ownership looks like. Integrating this information into the expanded NFF campaign ensures that the public can learn to recognize firearm-related risk factors in the context of IPV, understand their legal options, and know how to act—all from one trusted, accessible platform.

This avoids the confusion and fragmentation that would result from developing multiple government-run sites for different aspects of firearms education. It also encourages firearm owners to view this initiative as part of a broader conversation about community safety and responsibility, rather than as punitive or adversarial. Finally, it reinforces a clear pathway from awareness (NFF) to action (Crime Stoppers).

8.2.4. Recommendation 4: Establish a Joint Police–CFO Protocol for Proactive Compliance Checks Following Firearm Prohibition Orders

The Ministry of the Solicitor General should direct all Ontario police services to implement a standardized, province-wide protocol—developed in collaboration with the Chief Firearms Officer (CFO)—for conducting proactive compliance checks whenever a firearm prohibition order is issued in the context of IPV.

Implementation Details:

• Scope of Application: Applies to all firearm prohibition orders issued:
  • Under s. 109 (mandatory) or s. 110 (discretionary) of the Criminal Code following conviction or discharge;⁸²⁵
  • As a condition of bail (s. 515(4.1)) in IPV cases;⁸²⁶
  • Under s. 810 peace bonds where firearms are prohibited;⁸²⁷
  • Under federal s. 70.1 Firearms Act revocation for individuals subject to a protection order.⁸²⁸
• Protocol Requirements: Upon issuance of any firearms prohibition order, the responsible police service must:
  • Confirm whether the person has an active PAL or previously registered firearms (via CPIC and the CFO’s Firearms Interest Police (FIP) database),
  • Within 72 hours, conduct an in-person visit to:
    • Confirm that the PAL and any known firearms have been surrendered,
    • Ask about additional firearms not on record (including those of cohabitants),
    • Document compliance and/or initiate a warrant if non-compliance is suspected.
  • Notify the CFO of results for all cases involving licensed individuals or historical PAL holders.
• Victim Notification: The results of the compliance check (i.e., confirmation that firearms were removed or that enforcement action is underway) must be communicated to the survivor via their assigned Victim Services contact. This notification should occur within five business days of the check. Survivors should also be informed of the option to request follow-up if they are still concerned.
• Integration with Broader Systems: The recording and flagging of completed compliance checks should be integrated into a geospatial risk-monitoring tool for IPV offenders proposed by this report, as outlined earlier. This communication and risk-tracking function will also be supported by the Ontario Integrated Violence Prevention and Response Network (OIVPRN), a collaborative hub model recommended later in this report that formalizes inter-agency information sharing among police, courts, Victim Services, and the CFO.

• Data Collection and Oversight: Each police service should maintain a compliance log, noting:

  • Date of prohibition order,
  • Date and outcome of compliance check,
  • Any firearms seized and/or charges laid.

  These logs should be auditable by the Ministry of the Solicitor General as part of regular risk enforcement evaluations.

• Costing and Funding:
  • The Ministry will need to determine staffing and training costs for smaller police services (particularly in northern/rural areas).
  • The province may consider dedicated one-time funding for:
    • Officer training on firearms prohibition enforcement,
    • Standardized compliance check forms and guidance,
    • Backend tracking integration with CPIC, FIP.

Rationale: Inquests and DVDRC reviews consistently show that firearm prohibition orders are not sufficient unless actively enforced. In the Hadley and May cases, individuals subject to court orders continued to possess firearms due to lack of follow-up.⁸²⁹

Ontario does not currently mandate post-order compliance checks across all jurisdictions, leaving gaps between courts, police, and the CFO. This protocol would provide a standardized, enforceable mechanism—ensuring that prohibition orders result in actual firearm removal, not just legal paperwork. Including survivors in the notification process increases transparency, improves safety planning, and aligns with trauma-informed policing principles.

8.2.5. Recommendation 5: Expand Family Court Authority to Identify Firearm Risk and Notify Enforcement Agencies in IPV Cases

The Ontario government should amend the Family Law Act and associated court rules to mandate that family court judges inquire into firearm access and notify the Chief Firearms Officer (CFO) and police when IPV risk is identified in restraining order or custody/access proceedings.

This recommendation operationalizes the federal requirement under s. 70.2(1) of the Firearms Act to revoke firearms licences when a person becomes subject to a protection order—by ensuring the CFO and police are actually notified when that happens. Currently, most restraining orders are not sent to the CFO, meaning no firearm revocation occurs, even when required by law.

Implementation Details:

• Legislative Amendment:

  • The Family Law Act, RSO 1990, c F.3, should be amended to include the following new provision under s. 46 (Restraining Orders):

    46(6) Mandatory notification—firearm access
    Where the court, in making an order under this section, has reason to believe that the respondent may have access to one or more firearms or holds a firearms licence issued under the Firearms Act (Canada), the court shall direct that a copy of the restraining order be provided to:
    (a) the Chief Firearms Officer of Ontario; and
    (b) the police service having jurisdiction in the area where the respondent resides.

  • A companion provision should be added under Part III (Custody and Access), after the best interests analysis in s. 24:

    24(6.1) Mandatory notification—firearm access in family violence cases
    Where the court, in making or varying an order under this Part, determines that there is a risk of family violence and has reason to believe that a party may have access to one or more firearms or holds a firearms licence issued under the Firearms Act (Canada), the court shall direct that notice of the order be provided to:
    (a) the Chief Firearms Officer of Ontario; and
    (b) the police service having jurisdiction in the area where the party resides.

• Court Form and Procedural Updates:

  • All restraining order and custody forms should be revised to include a mandatory checkbox and short affidavit section:

    “To the best of your knowledge, does the respondent have access to firearms or a firearms licence (PAL)? Yes / No / Unknown.”

  • Where “Yes” or “Unknown” is selected, court clerks should be required to transmit the order or notice to the CFO and local police within 48 hours.
  • The Family Law Rules (O Reg 114/99) should be amended accordingly, and the Ministry of the Attorney General should issue procedural guidance to:
    • Court clerks on transmission responsibilities;
    • Judges on interpreting “access to firearms” and triggering mandatory notice;
    • Family law practitioners on incorporating this step into submissions.
• CFO/Police Response: Upon receiving a restraining order, the CFO should:
  • Check PAL status and FIP flags,
  • If applicable, revoke the PAL under s. 70.2(1) of the Firearms Act,
  • Coordinate with police to retrieve any known firearms.
• Victim Notification: Victims should be notified, through Victim Services or the Victim/Witness Assistance Program (VWAP), once the CFO and police have received the restraining order and confirm that a PAL has been revoked or a firearm surrender process has begun. Both services are expected to become formal components of the Ontario Integrated Violence Prevention and Response Network (OIVPRN) agency proposed later in this report.
• Integration with Broader Systems: These notifications should be flagged for real-time tracking by police, courts, and support agencies. The proposed Ontario Integrated Violence Prevention and Response Network (OIVPRN) should assume responsibility for compliance tracking, coordination, and follow-up where necessary.
• Alignment with Ongoing Reform:
  • The Ontario government should review the forthcoming report from the Law Commission of Ontario (LCO) on reforming the protection order system before finalizing legislative or form changes under this recommendation.
  • Preliminary findings from the LCO should also inform implementation of Recommendation 3, which addresses proactive enforcement of firearm prohibition orders.
  • In addition, the Government of Ontario should formally recommend to the federal Minister of Public Safety that restraining orders issued under s. 46 of the Family Law Act be explicitly included in the forthcoming regulation defining “protection order” under s. 70.1 of the Firearms Act.

Costing and Implementation:

• The Ministry of the Attorney General will need to cost:
  • Form updates and digital system changes,
  • Training for court clerks and judges,
  • Secure data-sharing with the CFO and local police.
• A 6-month pilot could be launched in three jurisdictions with high-volume family courts and regional Victim Services teams.

Rationale: Ontario’s family courts regularly receive detailed disclosures about intimate partner violence in custody and restraining order proceedings, yet there is no formal mechanism to notify police or the CFO about firearm risks. This means that even when a court finds that someone poses a danger and issues a restraining order, the federal requirement under the Firearms Act to revoke the person’s PAL and remove firearms is not triggered—simply because no one was notified. This gap is structural, not legal—and fixable. Family court judges should not be expected to remember to do this ad hoc. A mandatory checkbox, clear statutory language, and formal coordination will protect lives, reduce administrative burden, and create system-wide clarity. Importantly, this solution avoids criminalizing the respondent, respects due process, and gives the CFO clear authority to act within their mandate. The forthcoming report from the Law Commission of Ontario (LCO) on Ontario’s protection order system should be reviewed to ensure alignment of this recommendation with broader systemic reforms.

Proposed Legislative and Regulatory References:

• Family Law Act, RSO 1990, c F.3, new ss. 46(6) and 24(6.1);
• Firearms Act, SC 1995, c 39, s. 70.1;
• Family Law Rules, O Reg 114/99;
• Ontario Court Forms 10, 25, 35.1.

8.2.6. Recommendation 6: Provide Specialized Domestic Violence Training to PAL Decision-Makers and Issue Targeted Bill C-21 Rollout Guidance to Justice Sector Stakeholders

The Ministry of the Solicitor General should ensure that firearms licensing decision-makers within the Office of the Chief Firearms Officer (CFO) receive mandatory, specialized training on IPV, lethality risk, and coordinated enforcement responsibilities under the Firearms Act. This training should apply only to CFO staff involved in reviewing, approving, or revoking Possession and Acquisition Licences (PALs), and in carrying out risk-based firearm enforcement duties. Administrative staff and third-party firearms instructors (e.g. Canadian Firearms Safety Course trainers) are not within scope of this recommendation.

Separately, the Ministry of the Attorney General and the Ministry of the Solicitor General should issue a one-time, province-wide communication to justice sector stakeholders—specifically Crown attorneys, provincial judges and justices of the peace, probation officers, VWAP, and police services—summarizing Ontario’s responsibilities and authorities under Bill C-21, including s. 70.1 and 70.2 of the Firearms Act and the new firearm licence suspension regime.

Implementation Details:

• CFO Training Development and Delivery:
  • The training content should be:
    • Developed by the Ministry of the Solicitor General in collaboration with members of the Domestic Violence Death Review Committee (DVDRC);
    • Shared with victim services stakeholders for initial feedback and trauma-informed review;
    • Rolled out as a mandatory internal module for CFO licensing staff involved in PAL decision-making or firearm compliance enforcement.
  • Training should cover:
    • IPV risk factors, lethality indicators, and how firearms increase risk;
    • PAL revocation procedures under the Firearms Act;
    • Risk flagging and coordination with police and courts;
    • Communication with victims and integration with the ESRI Safekeeping platform, as proposed elsewhere in this report.
• Bill C-21 Rollout Communication:
  • The federal government’s licence suspension regime under Bill C-21 came into force on March 7, 2025, alongside other staggered implementation measures.
  • The subcommittee was unable to determine whether Ontario’s justice sector personnel—such as Crown attorneys, Justices of the Peace, police services, and probation officers—have already received formal guidance or training on the new authorities under Bill C-21.
  • If not already underway, the Ministry of the Attorney General and the Ministry of the Solicitor General should issue a targeted communication to:
    • Crown attorneys;
    • Justices of the Peace and provincial judges;
    • Probation officers;
    • Police services;
    • VWAP and Victim Services partners.
  • The communication should:
    • Clearly summarize relevant C-21 provisions (s. 70.1, emergency weapons prohibition orders, licence suspension mechanisms);
    • Clarify when and how to refer matters to the CFO;
    • Identify contact points and protocols for escalating IPV-related firearm risk;
    • A subsequent communication may need to be sent following confirmation of federal regulations.
• Funding and Oversight:
  • CFO staff training should be resourced through the existing Ministry training budgets or as a dedicated line within firearms administration funding.
  • C-21 communications can be coordinated through existing government-to-government bulletins or justice sector distribution channels.

Rationale: Section 70.1 of the Firearms Act, introduced through Bill C-21, requires the Chief Firearms Officer to revoke a PAL if the individual is subject to a protection order or is reasonably believed to have engaged in domestic violence or stalking. In addition, the licence suspension regime established by Bill C-21 came into force on March 7, 2025, expanding provincial enforcement responsibilities. However, the subcommittee was not able to ascertain whether Ontario’s justice sector personnel have developed sufficient procedures, processes and training on the scope of these new responsibilities. Given the complexity and phased implementation of Bill C-21, proactive communication and operational guidance are essential to ensure all relevant actors understand their roles, referral obligations, and risk intervention tools under the new law.

Part 4: Hubs & Ontario Integrated Violence Prevention and Response Network

4.1 Sectoral Organization of Service Delivery in Ontario

Ontario does not have a legislated or standardized framework for the organization of services responding to intimate partner violence (IPV), sexual violence (SV), or human trafficking (HT). Instead, services are delivered through a decentralized network of independent not-for-profits, community-based organizations, hospital-based programs, and municipal partners. These services operate without an overarching provincial mechanism to define which organizations deliver which services, to whom, and in which geographic areas. There is no requirement or support for these services to coordinate with one another, and in practice, the level of coordination and integration varies significantly across communities.

Most frontline victim services in Ontario are delivered by locally governed, incorporated non-profit organizations. These include emergency shelters, rape crisis centres, sexual assault centres, second-stage housing providers, victim witness assistance programs, community-based victim service agencies, trauma counselling organizations, and culturally-specific or francophone-serving providers. These organizations are not arms of government and do not fall under a centralized provincial administrative structure. Ontario’s Victim Services, for example, have a shared mandate, but are governed by independent boards of directors, operate with their own internal policies, and hold separate service contracts or funding agreements. The Ontario Network of Victim Service Providers (ONVSP) supports its over 40 member agencies to strengthen collaboration, foster knowledge-sharing, and provide a collective support system for frontline victim service providers, but does not have oversight over the individually incorporated and independently governed organizations providing service.⁸³⁰

There is no consistent province-wide framework of legislated or standardized catchment areas that applies to all agencies working in a specific area. Some agencies have defined catchment areas, others define their own service boundaries informally, based on historical relationships, staffing capacity, or negotiated understandings with nearby providers. The Child Witness Centre testified that “the level of care you receive as a victim… is dependent on your postal code,” with service availability, scope, and quality varying considerably between regions.⁸³¹ Without defined geographic jurisdictions, many organizations are unable to accurately describe the population they serve, calculate per capita funding requirements, or link their operations to demographic or crime data for their region. This lack of geographic structure also makes it difficult for policy-makers to assess what types of services are available in each part of Ontario.

Cooperation across agencies is voluntary and generally informal. There are no legislative or regulatory requirements for organizations in the IPV/SV/HT space to collaborate, share information, or co-develop protocols. The Safe Centre of Peel, one of the few co-located service hubs in the province, testified that the success of their model relies on strong partner relationships and “glue positions” that keep the vision and commitment of collaboration alive across all 23 partnering agencies.⁸³² The reality for most agencies, however, is that “there’s no centralized case management or coordination of services for victims.”⁸³³

The current service structure can result in disjointed experiences for victims. Agencies may refer victims elsewhere when a disclosure or service need falls outside their formal mandate, resulting in multiple disclosures and potential re-traumatization. The Safe Centre of Peel testified that,

[S]urvivors told us that they did not want to repeat their stories over and over; …that they often just gave up trying to travel from place to place and navigate a complex system that did not understand. It was particularly difficult for victims who didn’t speak the language; were new Canadians; had low to no finances, young children and virtually no support system.⁸³⁴

Further to this, the Committee was also told that IPV response in Ontario has largely been “reactive,” with agencies typically “becoming involved after a criminal incident has already occurred.”⁸³⁵ This means that victims who attempt to seek help before criminal charges are laid may receive inconsistent or partial responses. These structural barriers affect victims’ ability to access timely support and contribute to service disengagement, frustration, and missed opportunities for safety planning.

4.2 Funding Structures and Challenges

Ontario’s IPV, SV, and HT service sectors are funded through a combination of annualized transfer payments, one-time project grants, and competitive short-term funding opportunities. Formula for determining funding allocations vary across sector and agency, or in some cases, no standardized funding formula exists. Considered in sum, the province lacks any formal link between funding levels and service demand indicators such as local population size, crime rates, or demographic pressures. Funding structures vary widely depending on the type of service, the ministry administering the funds, and the historical circumstances under which the funding was originally established.

4.2.1 Predominant Funding Models

Organizations delivering IPV/SV/HT services receive funding through a mix of:

• Annualized transfer payments, typically renewed on a year-by-year basis, but not guaranteed beyond the fiscal cycle;
• Short-term project grants, often intended to pilot new services or initiatives for limited durations;
• One-time funding announcements, linked to specific government priorities or emergent needs.

These funding models rarely guarantee stability over multiple years. Core service providers such as shelters, sexual assault centres, and victim service agencies have reported that even essential services often rely on unstable or piecemeal funding structures.⁸³⁶ Additionally, funding renewal is often subject to political priorities and budgetary decisions external to the agencies’ control.⁸³⁷ This funding instability undermines service continuity and makes long-term planning extremely difficult for organizations operating core victim support programs.

4.2.2 Absence of Per Capita or Needs-Based Funding Formulas

There is no provincial per capita or needs-based funding model for IPV/SV/HT services. Additionally, funding levels are not automatically indexed to population growth, inflation rates, or rising service demand.⁸³⁸ The absence of formula-based funding complicates agencies’ ability to plan, forecast, or justify resource needs based on demographic trends. It also exacerbates regional disparities, as some service areas may experience rapid population growth or increasing IPV/SV/HT rates without commensurate increases in funding.

4.2.3 Fragmented Funding Across Ministries

As with governance, funding responsibilities for IPV/SV/HT services are divided between multiple ministries. MCCSS funds shelters and some VAW counselling programs; MAG funds Partner Assault Response programs and certain victim assistance programs; MOH funds hospital-based sexual assault and domestic violence treatment centres; and EDU funds prevention programming in schools.

There is no integrated funding framework across ministries. Each funding stream operates under distinct reporting requirements, accountability structures, eligibility criteria, and evaluation frameworks. This fragmentation contributes to administrative duplication, increased reporting burdens, and inconsistencies in service models across the province.

The Jean Tweed Centre noted that multi-ministry funding creates significant complexity for agencies trying to deliver seamless services, as each funder maintains its own priorities, outputs, and reporting timelines.⁸³⁹

4.2.4 Structural Competition and Duplication Caused by Grant Models

Short-term and project-based grants can introduce competition between agencies for scarce resources.⁸⁴⁰ This competition can discourage collaboration and the sharing of best practices, as organizations must position themselves against one another to secure limited funding. One example of this was seen in the submission by ONVSP, which states that: “The primary reason shelters request so much information is to inflate their statistics for night bed requests, driven by competition for scarce resources” and suggests that shelters don’t refer as much as they could to ONVSP due to scarcity of funding and the reality that funding competitiveness is increased by having higher statistics for service.⁸⁴¹

This example highlights findings elsewhere in research, suggesting that competitive grant structures fracture service ecosystems by incentivizing individual agency survival over coordinated sectoral development.⁸⁴² Competitive structures also lead to duplication of proposals, fragmented service pilots that are difficult to sustain, and gaps in systemic service planning.

4.2.5 Funder-as-Expert Dynamics and Mismatched Deliverables

Problems also arise from a mismatch between funder decision-making priorities and service need realities. The Government of Canada’s evaluation of project funding noted that funders often assume the role of expert, prescribing models without sufficient input from frontline organizations, leading to deliverables that are disconnected from client realities.⁸⁴³ As a result, frontline agencies are often forced to retrofit their service models to meet externally defined project criteria rather than community needs.

4.2.6 Organizational and Service Instability

Short-term, project-based, and unpredictable funding structures undermine organizational stability. Notably:

• Agencies experience high staff turnover due to insecure employment contracts tied to unstable funding,
• Service development and community relationships are disrupted when pilot programs end abruptly,
• Administrative capacity is drained by the continual need to apply for funding, report on project deliverables, and navigate overlapping reporting requirements.⁸⁴⁴

The Stanford Social Innovation Review’s report on the “Nonprofit Starvation Cycle” found that nonprofits systematically underinvest in infrastructure, professional development, and long-term planning because of funding instability.⁸⁴⁵ The Council of Nonprofits’ CommonSense Contracting report similarly concluded that unstable funding and delayed payments result in workforce attrition, program disruptions, and reduced service quality.⁸⁴⁶

The ONVSP submission noted that due to a lack of core funding, staff frequently resort to creating new projects, applying for short-term grants, organizing fundraisers, or relying on volunteers to make up for funding shortfalls. Concerningly, “this creates an unstable support system that fails to prioritize victims.”⁸⁴⁷

4.3 Fragmentation and Victim Navigation Problems

The decentralized and uncoordinated structure of Ontario’s IPV, SV, and HT service landscape has significant effects on victims’ ability to access timely, appropriate, and continuous support. Service navigation is not standardized across the province, and victims frequently encounter systemic obstacles, such as being referred elsewhere, receiving inconsistent guidance, or being asked to retell their stories to multiple providers. These patterns are not the result of individual failings, but of broader structural conditions in which each agency operates independently and without legislated referral obligations, common intake models, or shared information systems.

Victims may disclose abuse in a wide range of settings, including hospitals, police services, shelters, sexual assault centres, mental health programs, substance use treatment programs, or housing services. However, because service mandates differ—and because few agencies are equipped or funded to offer comprehensive support—victims often face barriers to accessing essential support due to inconsistent identification and classification of their needs. The lack of integrated care models was emphasized by the Jean Tweed Centre noting that “the current system for supporting victims of intimate partner violence and sexual violence is deeply fragmented, resulting in siloed services that hinder effective care.”⁸⁴⁸ As a result, victims may be required to repeat their disclosures in multiple settings, often in close succession, and with limited continuity in support. The ONVSP reported that service users “express frustration [when] they [do] not receiv[e] the help they expected from other agencies.”⁸⁴⁹ Consequently, without centralized guidance or navigation, victims are then left to coordinate their own care across disconnected systems.

The lack of centralized intake and follow-through is not limited to complex cases. Even in comparatively straightforward situations—for example, where a victim discloses to police and is referred to a victim services agency—there may be significant variability in the follow-up process. This is because there is no legislated or province-wide framework requiring service providers to ensure continuity of care, nor any guarantee that a referred client will be contacted, followed up with, or integrated into another agency’s caseload.

Additional problems have been noted in the role of VCAO programs specifically. Despite VCAOs being created by the government to act as system navigators for victims, there remains significant confusion about their role among politicians and members of the public service. This lack of clarity and limited effort to provide such clarity impacts victims as they may be unaware of services available to them or they may become ineligible for time-sensitive services due to significant delays in the current system. As the ONVSP notes, “these gaps often arise when non-VCAO agencies fail to provide support or referrals elsewhere, leaving victims to eventually seek help from VCAOs independently if they are fortunate enough to have prior knowledge of services.”⁸⁵⁰ Consequently, the ONVSP has advocated for the MCCSS to better define their role and the role of others in the system, with VCAOs “formally designated as System Navigator Care Coordinators,” with a mandate to act as a central point of contact for victims regardless of entry point.⁸⁵¹ Additionally, “agencies that do not deliver the VCAO program and specialize in assisting victims of only specific crimes, such as those of sexual assault or [IPV], should not be referred to as Victim Service Providers. Instead, they should be identified by their agency name to reduce confusion experienced by victims, community partners, and funders.”⁸⁵² Systemic fragmentation also affects the relationship between services and courts. Gaps in communication between the legal system and community services is a known barrier to coordinated safety planning and support.⁸⁵³ For example, community-based providers may not be notified when a bail condition is modified or when a trial date is set. Without shared case information, they may be unable to adjust safety plans or advise clients appropriately.

While these navigation challenges are most acute for victims with complex needs—such as those experiencing co-occurring substance use, housing instability, or multiple forms of victimization—they are not limited to high-risk cases. Even in low-risk or early-intervention scenarios, the absence of a system-wide intake or navigation infrastructure limits the sector’s ability to consistently engage survivors, reduce attrition, or provide a coordinated response.

4.4 Risk Detection and Safety Planning Failures

As described in detail in the report section on risk assessment, Ontario does not have a standardized or province-wide mechanism for sharing risk-related information across the sectors involved in IPV, SV, or HT response. Testimony to this Committee outlined how there is minimal alignment across sectors (e.g., victim services, police, courts, child welfare, and healthcare) in their methods for documentation and reporting, which has resulted in data fragmentation as some sectors are collecting detailed information while others may not document IPV cases at all. This lack of standardized data collection and reporting not only hinders the accuracy of measuring IPV prevalence, it also makes it difficult to identify trends, effectively allocate resources, or develop evidence-based policies, and can undermine survivors by misrepresenting or overlooking their experiences.⁸⁵⁴ This also creates substantial barriers to timely risk detection and safety planning, even in high-risk or escalating cases.

Community-based victim service agencies do not have automatic access to real-time information about court outcomes, bail conditions, probation status, or other system events that may affect client safety. Service providers often rely on clients themselves to provide updates about legal proceedings, custody arrangements, or offender movements—information that may be incomplete, delayed, or emotionally difficult for the client to manage.

There is no province-wide risk coordination protocol or shared flagging system that alerts community service providers when a client is identified as high-risk in another part of the system. For example, a victim may be assessed as high-risk by police but the information may not be shared with the hospital team, the shelter, or the trauma counselling provider. These structural limitations can also affect the ability to conduct proactive or multi-agency safety planning. In the absence of clear protocols for information sharing, agencies are often left to develop safety plans based solely on the information they gather directly from the client, without input from other sectors.

The lack of sustained relationships between community-based victim services and justice sector actors compounds this issue. There is no legislated requirement for probation, Crown counsel, or police to coordinate case monitoring with non-profit agencies. This can lead to missed warning signs, contradictory safety planning, or situations in which a victim is falsely reassured about their level of risk.

Some communities have developed informal mechanisms or pilot protocols to share risk information—for example, local high-risk case conferencing groups, situation tables, or informal relationships between police and shelters. However, these structures are not consistent across Ontario and are not supported by a provincial mandate or infrastructure. As a result, whether or not risk is identified, monitored, or shared depends on geography, local agency leadership, and available staffing resources.

These gaps are particularly dangerous in cases involving coercive control, stalking, or repeat offenders. In the absence of integrated risk tracking, a perpetrator’s behaviour may be assessed in isolation at each point of contact rather than as part of an escalating pattern.

The consequences of risk detection failure are borne disproportionately by victims, who may believe they are safe based on outdated or incomplete information. Service providers operate with limited visibility, constrained ability to engage proactively, and reduced capacity to intervene before harm escalates.

4.5 Geographic Coverage and Service Mapping Issues

Ontario does not have a legislated or standardized system of geographic service catchments for IPV, SV, or HT service delivery. Instead, service boundaries are defined organically by individual organizations based on historical practice, internal capacity, funding arrangements, and informal local agreements. This lack of standardized service territories complicates efforts to conduct province-wide service planning, assess service gaps, advocate for funding based on population needs, or link service delivery to demographic and crime data.

Most agencies determine their own catchment areas without formal mandates. These self-defined territories vary widely in size, population density, and scope of services offered. In some regions, multiple agencies may overlap in service provision, while in others, significant geographic gaps exist. The Child Witness Centre observed that “the level of care you receive as a victim… is dependent on your postal code,” illustrating how geographic disparities in service availability are structurally embedded in the current system.⁸⁵⁵ Without formalized boundaries, it is difficult to establish which populations are served by which agencies, complicating needs assessments, service mapping, and system accountability.

Without a legislated catchment framework, agencies may not have access to consistent, population-specific data regarding the geographic areas they serve. Agencies cannot consistently match their service delivery areas to existing population-level demographic data, creating challenges for demonstrating service demand, advocating for funding increases, or identifying underserved populations.

This absence of geographic standardization also affects the provincial government’s ability to assess coverage. There is currently no centralized or publicly available map that outlines what services are available in each region, which agency is responsible for which areas, or where service gaps exist. The lack of geographic service coordination also contributes to duplication and gaps in service. In some areas, multiple agencies may independently develop services or outreach programs without awareness of each other’s operations. In other regions, critical services such as sexual assault crisis response, VAW counselling, or trauma-informed legal support may be absent or limited.

Agencies that attempt to advocate for additional funding based on need often face structural challenges in demonstrating the size or characteristics of the populations they serve. Without assigned catchments and linked demographic data, it is difficult to make consistent, evidence-based arguments for population-based funding or service expansion.

Where regional coordination does exist—for example, through voluntary networks or collaborative projects—it is the result of local initiative rather than mandated system design.

In the absence of legislated service catchments, some regional planning models have used existing justice system boundaries to support geographic alignment. One example is the assignment of communities to Crown Attorney offices. Every municipality and region in Ontario falls within the jurisdiction of a designated Crown office, which is responsible for criminal prosecutions, coordination with police, and the administration of court-based services such as bail hearings and trial scheduling.⁸⁵⁶ These jurisdictions are structurally stable and consistent across the province. Unlike municipal boundaries, which may change due to amalgamations or restructuring,⁸⁵⁷ or police jurisdictions, which may shift due to service agreements or regionalization,⁸⁵⁸ Crown jurisdictions are fixed and mapped directly to Ontario’s justice administration infrastructure.⁸⁵⁹ They also cover all areas of the province, including rural, remote, and military communities, and are used for caseload assignment, disclosure management, and coordination with other justice sector actors.

In almost all cases, local police services refer all charges to a single Crown office, and Crown files are managed through that centralized office’s structure. While exceptions may occur—for example, the Ontario Provincial Police (OPP) operates across broader geographic areas—each OPP detachment is assigned to a specific Crown office, and files are referred accordingly. Military police in areas such as Pembroke similarly refer charges to a designated Crown office, ensuring complete coverage of federal, provincial, and specialized enforcement bodies within a coherent prosecutorial structure.

Because this referral logic is already established, using Crown jurisdictions as a geographic framework for planning purposes may provide a practical and administratively coherent approach. It would avoid the need to create new boundaries and allow for alignment with police services, probation officers, and victim/witness programs that already operate within the same justice geography. Crown districts also function as natural organizing units for integrated safety planning, since they are tied to bail supervision, case management, and criminal risk assessment activities.

Importantly, aligning geographic catchments to Crown jurisdictions does not imply that Crown Attorney offices hold any governance role or oversight within a future hub structure. The Crown’s jurisdiction is referenced only as a stable geographic boundary for service mapping. Should municipal or policing boundaries shift over time, police services would continue to refer charges to a designated Crown office, and jurisdictional boundaries would remain coherent. While the number of Crown offices may expand or contract based on system needs, the approach offers a scalable framework that does not require administrative re-mapping for each local change in enforcement or municipal organization.

Of note, regional planning structures may need to accommodate service users who access supports outside their assigned catchment. This may occur in rural, remote, or border communities where proximity, mobility, or safety needs shape client choice. Flexible intake and cross-boundary protocols can ensure that geographic planning frameworks support service access without creating rigid restrictions.

4.6 Prevailing Funding Practices in the Non-Profit Sector

Across Canada and internationally, non-profit organizations responsible for delivering public services are frequently funded through a mix of short-term project grants, competitive applications, and annualized transfer payments. These mechanisms are not unique to any one jurisdiction and have become standard administrative practice in many areas of social and community service delivery. The model allows governments to direct spending toward priority areas and pilot new initiatives. However, in practice, grant-based funding structures often create organizational instability, undermine long-term planning, and introduce delays and inefficiencies into service delivery.⁸⁶⁰

Several systemic challenges exist with project-based funding models for the non-profit sector. These include:

• Short funding cycles that limit an organization’s ability to retain staff, plan multi-year services, or develop long-term infrastructure;
• Delayed disbursement of funds, in which awarded grants are announced or processed months after the intended start date, compressing delivery timelines and forcing organizations to deliver 12 months of programming in 6 to 9 months;
• Administrative burdens associated with overlapping applications, reporting requirements, and time-limited pilot deliverables;
• Caps on overhead or indirect costs, which limit investment in leadership, data systems, training, and evaluation;
• Competition between providers, which discourages collaboration and information sharing;
• Structural expectations that funders—not service providers—define deliverables, models, or evaluation criteria.⁸⁶¹

These funding structures can potentially produce disruptive turnover, program instability, and a loss of institutional knowledge across the non-profit sector. The Government of Canada’s own review of project-based funding also highlighted how project-funding allots more control to the funder over the content of the project, in comparison to core-based fundings, which allows more flexibility and autonomy on the part of the organization.

While grants are well suited to proof-of-concept or research initiatives, they are less compatible with the delivery of essential services that require continuity, multi-year investment, and coordination. In many cases, core victim services in Ontario—including trauma counselling, system navigation, case coordination, and outreach—are delivered by organizations operating under these same structural constraints. Consequently, service delivery is shaped by the administrative realities of grant cycles, not by client needs or longitudinal planning.

Concerns also exist around grant approvals being announced months after the proposed start date. This compresses the time available for implementation and increases the pressure to hire staff, launch programming, and spend allocated funds within an artificially shortened window. Testimony from the Child Witness Centre stated that: “over the last year, we’ve had eight grant-driven contracts on our staff, and the estimated net loss of approximately 70 weeks of staff time relating to short-term grants and contracts has an impact on the value of our service and the number of children that we serve or place on a wait-list, with an estimated net loss equivalent of $70,000 or the care of 70 children per year.”⁸⁶²

Short-term contracts tied to project funding make it difficult to attract and retain experienced personnel. Rehiring and retraining cycles are frequent, which can further exhaust financial resources and time. When funding is not renewed, staff positions may be eliminated with little notice, even in high-performing programs.

In addition to instability, the competitive nature of project funding often undermines collaboration. Agencies are placed in the position of competing against each other for limited resources, which may discourage service alignment, shared protocols, or best practice dissemination.⁸⁶³

Program evaluation is also affected. Grants are typically designed around predefined outputs and timelines, limiting the ability to assess longer-term outcomes. In some cases, organizations may be required to deliver a full program and submit final reports within 12 months of grant receipt, even when client engagement or trauma recovery timelines extend well beyond that period.

The cumulative effect of these structural features is that organizations delivering core services for victims of IPV, SV, and HT are subject to the same constraints typically associated with research or innovation pilots. In sectors where service continuity, trust-building, and coordination are essential, grant-based funding models may be misaligned with operational realities.

4.7 Integrated Hub Models—Family Justice Centers, One-Stop Centres, and Community-Based Collaboratives

4.7.1 Origins of the Family Justice Center Model—San Diego

The Family Justice Center (FJC) model was first developed in San Diego, California in 2002 through a partnership between the San Diego Police Department, the District Attorney’s Office, and the Domestic Violence Council.⁸⁶⁴ As the first facility of its kind in the United States, the FJC sought to address fragmented service delivery by co-locating multiple agencies involved in responding to IPV under one roof. The Center is considered a “one stop shop” for victims of IPV, as it houses the entire domestic violence units of the San Diego Police Department and the San Diego City Attorney’s Office to hold perpetrators accountable for their crimes, and contains over 200 professionals on-site providing comprehensive services.⁸⁶⁵ Services include counseling, forensic medical examinations, restraining orders, temporary shelter, community-based victim and child support services, civil legal assistance, and more. Through a survivor-centred approach, where the needs and experiences of both adults and children are prioritized, the FCJ offers a supportive, trauma-informed, hope-centred environment, ensuring survivors feel safe and empowered.

San Diego’s FJC quickly became a model of interest, as evaluation data indicated that it reduced domestic violence homicides in the city by 90%.⁸⁶⁶ The FJC framework has since been implemented in 150 regions across the United States, and further evaluation data mirrors this trend in reduced domestic violence homicide rates: Alameda County (California) has decreased by 75% and Brooklyn (New York City) has dropped by 51%.

In addition to homicide reduction, measurable improvements in survivor engagement and satisfaction have been found. Internal program evaluations at the Contra Costa County (California) FJC found that 100% of clients felt safer after accessing services at the FJC; 80% reported feeling more empowered and able to advocate for themselves, make informed choices, and navigate complex systems; and 75% of families experienced an increase in protective factors and resilience in the prevention of secondary assault or re-assault.⁸⁶⁷ These outcomes suggest that the FJC model is a replicable structure that improves public safety, survivor well-being, and criminal justice efficiency.

4.7.2 International Diffusion and Adaptation

In 2006, the National Family Justice Center Alliance was established in response to the increasing demand for technical support from the FCJs that were rapidly being implemented. The Alliance has since evolved, changing its name to Alliance for HOPE International in 2015, which symbolizes the model’s holistic and hope-centred approach to helping adult and child survivors of IPV.⁸⁶⁸

International adoption of the FJC concept has also expanded steadily. In Australia, the state of Victoria developed Orange Door Centres, which are support and safety hubs that bring together practitioners from specialist family violence services, child and family services, Indigenous services, and perpetrator services to form multi-disciplinary teams and provide wrap-around support.⁸⁶⁹ The Orange Door model was developed in response to the 2016 Royal Commission into Family Violence and emphasizes integrated intake and multi-agency collaboration.⁸⁷⁰ In the United Kingdom, Multi-Agency Risk Assessment Conferences (MARACs) and Multi-Agency Safeguarding Hubs (MASHs) coordinate police, social care, health, and victim services in real-time case conferencing models.⁸⁷¹ These hubs prioritize collective risk assessment and intervention planning for high-risk cases, especially where children are present.

Finally, an officially recognized network of FJCs in Europe exists, providing a central platform for knowledge and experience exchange. Specifically, the European Family Justice Center Alliance (EFJCA) is a network of FJCs from across 38 countries, which prioritizes multi-agency cooperation and provides a central platform for its members to share knowledge, good practices, and support.⁸⁷² The Alliance supports the development of victim-centred services co-located in one location, advocates for international conventions, and offers capacity building and training for professionals in the field.⁸⁷³

4.7.3 Ontario-Based Hub Models

Ontario does not currently have a legislated hub model for IPV or SV services. However, a handful of communities have developed co-located service centres that share key features with the FJC approach.

In 2006, the Family Violence Project (FVP) of Waterloo Region was launched, with the purpose of providing a co-located, multi-service, multi-sectoral response to family violence. The FVP was the first of its kind in Canada and has since inspired the development of several “family violence hubs” across Canada.⁸⁷⁴ The Project includes an embedded representative from the Crown Attorney’s Office, as well as co-located victim and child services, shelters, counselling services, police, and more. The presence of the Crown provides clients with opportunities for an in-depth, informative session on court procedures and inquiries pertaining to an individual or specific case.⁸⁷⁵

The Safe Centre of Peel in Brampton drew its inspiration from the evidence-based San Diego FJC model, recognizing that “cross-sectorial collaboration among community services such as shelters, family services, child welfare, justice, legal, health, settlement are vital in responding to the victims of IPV.”⁸⁷⁶ The Safe Centre hosts over 24 partner agencies that provide efficient wraparound services under one roof to adults who have experienced violence and abuse, including needs and risk assessment, individualized safety planning, client navigation, referrals to sexual assault counselling, short-term counselling, settlement and immigration services, parenting education and resource, and access on police reporting (if required).⁸⁷⁷ These agencies share common physical space, cross-refer clients, and collaborate on complex cases. In 2021, the Peel Regional Police created a specialized IPV unit that was integrated into the Safe Centre. Safety Network Durham (formerly DRIVEN) is another collaborative hub that exists. Survivors connect with a care coordinator, who is then able to assist with safety planning and system navigation, connecting clients with partnered agencies that can be accessed on-site, off-site, and virtually. Safety Network Durham uses a client-centred approach, where information will not be shared amongst co-located or collaborating agencies without the specific consent of the individual client and the client’s choices in which agencies will and will not be involved is respected.⁸⁷⁸