The National Housing Strategy (NHS), a ten-year plan to reduce chronic homelessness and housing need across the country, is coming to an end in 2027-28. Unfortunately, it was not successful in meetings its goals, and a key part of this failure was the lack of a consistent human rights-based approach. This means that there is an opportunity to learn from the first NHS and imagine a new strategy, one that respects and upholds rights while making real progress towards ending homelessness and housing need in Canada.
As a contribution to this visioning process, the Office of the Federal Housing Advocate released three reports in April 2026. These papers all deal with the need to include enforceable, rights-based targets in the new NHS, along with definitions of key concepts like affordability. Notably, the authors propose this be done by establishing conditional funding agreements between the federal government and other orders of government, similar to how health care is handled. I will summarize their conclusions below, but here are the three reports in full on the Homeless Hub:
- Rights-Based Intergovernmental Agreements for the Next National Housing Strategy, by Carolyn Whitzman
- A Rights-Based Approach to the Canada Housing Benefit, by Carolyn Whitzman
- Building Homes, Upholding Rights: A Human Rights Approach to Housing Agreements, by Alexandra Flynn
As the Federal Housing Advocate, Marie-Josée Houle, wrote when announcing these reports, “Canada is at a crucial moment. The federal government has an opportunity to build a National Housing Strategy that reflects Canada’s human rights commitments and ensures that everyone has access to housing that enables them to live in safety and in dignity.”
The Housing and Homelessness Crisis Deepened Despite the NHS
Although Canada enshrined the right to adequate housing in domestic law in 2019 with the National Housing Strategy Act, the NHS’s programs do not reflect it. This has occurred even as more people find themselves experiencing homelessness than when the NHS started.
Want to learn more about the right to adequate housing? Check out this introduction by the Canadian Human Rights Commission.
The federal government committed to “taking into account key principles of a human rights-based approach to housing” in the NHS, and these principles are as follows:
- Prioritize vulnerable groups
- Engage meaningfully with vulnerable populations
- Address discrimination and inequality in housing
- Use all appropriate means to advance the right to adequate housing and providing sufficient funding
- Ensure independent monitoring of this work
As Carolyn Whitzman explains (p. 9), the NHS failed to do any of these adequately. For instance, rather than prioritize creating housing that would be affordable to vulnerable groups, the NHS spent almost half its budget on the Apartment Construction Loan Program, which provided low-cost loans to developers to build market housing with only minimal affordability conditions. “According to analysis by the National Housing Council, only 3% of homes completed were affordable to those in core housing need,” Whitzman writes. (“Core housing need” refers to households who either spend more than 30% of their income on housing or are in housing that needs repairs or is unsuitable and can’t move to adequate, affordable housing in their area).
As well, in terms of engaging with vulnerable populations and addressing discrimination, Indigenous-led plans were not included in the NHS, and programs contained no clear guidelines around accessibility. This despite the fact that Indigenous people and people with disabilities are disproportionately impacted by homelessness and housing need.
The Canada Housing Benefit: An Example of How the NHS Missed the Mark
“The CHB has not achieved its purpose,” Whitzman wrote in her report on the Canada Housing Benefit (CHB). “A small minority of eligible renter households have received an amount that is insufficient to cover the growing gap between market and affordable rent.”
The CHB was introduced as part of the NHS in 2017, and it is essentially a rent subsidy, meaning it is meant to help cover the difference between the price of rent and what is affordable for very low- and low-income households. It was a key part of the NHS’s plan to meet its goal of reducing core housing need and cutting chronic homelessness in half, and so asking how a new CHB could be different is important for imagining a new NHS overall.
Critically, the CHB did not prioritize non-market housing for funding, and new non-market homes are not coming online quickly enough. Without this, rent subsidies cannot keep up with rising market rents, which leaves households still without adequate, affordable housing. This indicates a need to shift towards permanently funding affordable units rather than temporarily funding renters on the private market. Indeed, the CHB even required people to take their names off the waiting list for affordable housing in some provinces.
With all this in mind, below are three key recommendations from Alexandra Flynn and Carolyn Whitzman’s reports for ensuring that the next National Housing Strategy is truly rights-based:
- Establish conditional funding agreements similar to health care
- Enforce rights-based targets by measuring meaningful outcomes
- Implement standard definitions of key terms
1) Establish Conditional Funding Agreements Similar to Health Care
Alexandra Flynn outlines a key reason why the NHS largely failed to achieve its goals in her report (p. 1): “There are currently no legal mechanisms to hold any level of government in Canada legally accountable for ensuring access to adequate housing.” Despite all governments playing a role in housing, there is no shared framework to guide their work, and federal commitments around the right to adequate housing have so far proven unenforceable. Flynn refers to this as a “governance gap.”
However, this does not mean there is no solution. “Canada has faced similar jurisdictional ambiguity before,” Flynn explains, “in the context of health.” Like housing, there is no mention of health in the Constitution Act, but this hasn’t stopped the federal government from taking the lead on creating a national standard and compelling provinces to respect it. This is done by attaching conditions to federal health transfers that require provinces and territories to respect core principles in a model known as “contractual federalism.”
In such a model, the legal responsibility for the right to housing would be enforced through contracts between levels of government, with federal funds being contingent on rights-based results. This would not affect the powers of the provinces but would require them to meet national standards. These standards could include clear definitions of terms like “affordable” and specify outcomes that must be tracked.
2) Enforce Rights-Based Targets by Measuring Meaningful Outcomes
The outcomes piece here is key, because if there aren’t clear rights-based targets, then it becomes impossible to measure success. Whitzman recommends (p. 1) “internationally comparable rights-based outcomes, such as ending homelessness by 2040, ending low-income housing need by 2050, and providing enough affordable and adequate supply for moderate- and medium-income households by 2060.”
This requires data to be collected about progress towards those targets based on common definitions, and these data must be transparently available. Data collection could be a condition of funding transfers from the federal government as part of clear and accountable relationships.
Whitzman points out (p. 24) that the current NHS “had static targets that did not address an increasing and changing population, nor did it address the net loss of affordable housing for very low-, low-, and moderate-income households, which increased the number of households in core housing need and at risk of homelessness.” By static targets, she means things like the number of supposedly affordable units built, which might look impressive but masks the fact that housing need is growing faster than supply. A dynamic target, by contrast, would be whether the proportion of households experiencing homelessness or housing need actually declines over time. A dynamic target adjusts to a changing population and gives a clearer picture of whether a strategy is working.
3) Implement Standard Definitions of Key Terms
I’ve mentioned a few times that there is no standard definition of affordability in the NHS and that different programs adopt their own definitions. Whitzman takes aim at this issue by providing thorough, rights-based definitions of key concepts from the NHS, including affordability (p. 13). The usual federal definition is housing that consumes less than 30% of a household’s pre-tax income, including utilities, but this was not used by NHS housing supply programs, which preferred measures like the number of unit-years of below-market costs (which, importantly, is not based on any household’s ability to pay). Whitzman then gives the following definition of affordable housing: “Housing costs, including utilities, that consume no more than 30% of the pre-tax household income of very low- and low-income households.”
This ties affordability to income and ability to pay, which makes it possible to set clear targets and track progress towards them within a rights-based framework.
“Silence Should Not Preclude Action”
As Flynn writes (p. 22), “Canada’s constitutional framework may be silent on the right to housing, but that silence should not preclude action.” The federal government has committed to the right to adequate housing, and the renewal of the National Housing Strategy is a chance to put that commitment into action through enforceable funding agreements with provinces, territories, municipalities, and Indigenous governments. If it could be done for health, it can surely be done for housing, another fundamental human need shared by everyone in Canada.
See all of the Office of the Federal Housing Advocate’s work on housing rights in Canada