How Compliance with the Canadian Gender Budgeting Act Drains Government Capacity

I don’t have enough information to share a useful opinion about the intrinsic value of the Canadian Gender Budgeting Act itself. Although there are some questions I’d love to be able to answer, like:

• What was the original problem it was supposed to fix?

• Has the implementation of the Act led to any positive outcomes?

• What other important work could have been done with the resources committed to compliance (i.e., opportunity costs)?

What I will do here however, is discuss some of the legislation’s indirect impacts. Specifically, the compliance costs.

Here’s how government documents describe reporting requirements:

“In 2018, Parliament passed the Canadian Gender Budgeting Act. The Departmental Plans and Departmental Results Reports are being used to fulfill the President of the Treasury Board’s obligations to make public, every year, analysis on the impacts of expenditure programs on gender and diversity.”

So every single year, every single government department is required to generate and submit detailed Gender-based Analysis Plus (GBA Plus) compliance reports.

In practice, departments decide for themselves how to fulfill their reporting obligations. Some, like Parole Board of Canada, will incorporate their GBA Plus report into their general planning document. For their 2026-27 departmental planning document, the GBA Plus section took up just 440 of around 7,500 words.

At the other extreme, Veterans Affairs Canada published a standalone GBA Plus document that stretched past 6,500 words in length. Canadian Heritage’s 2026-27 departmental plan compromised by incorporating GPA Plus reporting into each of the five core responsibilities sections of their general planning document. GPA Plus-related reporting took up 3,300 out of that document’s 15,000 words.

And then there’s the Canadian Grain Commission who chose to publish their own 1,000 word GBA Plus compliance document. I’m not sure whether there isn’t a subtle, cynical subtext to this introduction:

“Despite being a small department, the Canadian Grain Commission dedicated resources and collaborative cross-organizational efforts towards GBA Plus objectives.”

Some of the personnel costs of compliance can be sensed from this excerpt:

“This multi-year plan aligns with GBA Plus objectives by identifying and bridging gaps in employment equity through intersectional analysis and aims to create more equitable outcomes by addressing biases and barriers…As all Canadian Grain Commission managers are expected to contribute to equitable and transparent opportunities for all diversity groups and individuals in the workforce, each division has an action plan to respond to areas of concern.”

And it looks like there’s an ongoing struggle to figure out how to apply GBA Plus objectives to actual, real-world department programming:

“The Canadian Grain Commission continues to assess the impacts of the Safeguards for Grain Farmers Program on gender and diversity through a review of the department’s support for GBA Plus objectives.”

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To be sure, transparency is important. If a government decides to create a policy, then they are responsible for ensuring that it’s applied by all relevant departments.

Nevertheless, if you’re going to force dozens of government departments to commit significant resources to yearly reporting at this scale, the benefits had better be worth it.

Sure, a lot of the work probably amounts to cutting and pasting boilerplate text from one year to the next. Hopefully, even that will soon be handled invisibly by AI: not only will no one ever read the stuff, but no one will have even written it either. It’ll just be a digital workflow, silently moving electronic characters from one file system location and web page to another.

But that’s definitely how things work right now. The legislation’s goal involved lots of human interaction. And that interaction would undoubtedly drain time and resources away from actual program operations and drown out other, more important reporting.

After all, we’re not just talking about someone typing away at a keyboard. Real compliance will require that each federal organization ensures they’re:

• training staff in GBA Plus methodology;

• conducting analyses of programs and expenditures;

• collecting and disaggregating data;

• attending interdepartmental working groups;

• maintaining GBA Plus “responsibility centres”;

• drafting, reviewing, translating, and approving the annual tables;

• responding to Treasury Board and Women and Gender Equality Canada requirements;

• program-level analysis;

• management review and sign-off.

What does all that cost taxpayers each year? All told, probably upwards of $50 million. Which means that since the 2018 program start - and independent of implementation of the actual Act - CBA Plus reporting compliance costs alone are probably approaching a half billion dollars. And after all the reports, can we really positively identify any concrete street-level improvements?

What else could we have done with that money?

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There’s more: