Dear Minister: We urge you to reconsider your cuts to the Interim Housing Assistance Program immediately

The Honorable Lena Metlege Diab, P.C., M.P. 
Minister of Immigration, Refugees and Citizenship 
365 Laurier Ave West 
Ottawa, Ontario, K1A 1L1 

September 24, 2025 

Dear Minister Diab, 

In my role as the Chair, I am writing to you on behalf of the City of Toronto’s Housing Rights Advisory Committee, a body established to guide City Council in its efforts to fulfill the progressive realization of the right to adequate housing.  

We wish to express our alarm that the federal government intends to cut funding for Toronto’s refugee services under the Interim Housing Assistance Program (IHAP), leaving the City short by $107 million next year alone. As a municipal government, Toronto lacks the fiscal flexibility to assume the additional costs of maintaining these services. Your action, therefore, jeopardizes shelter access for thousands of refugees in Toronto, amounting to a violation of both international and domestic human rights law.  

Violations of statutory obligations under the National Housing Strategy Act (NHSA) 

Section 4 of the NHSA declares that it is the housing policy of the Government of Canada to recognize the right to adequate housing as a fundamental human right under international law and to progressively realize this right. Reducing support for refugee shelter constitutes a retrogressive measure that cannot be justified in the present context in Canada. Thus, this action violates the government’s obligation to pursue progressive realization.  

Section 5(2)(c) of the NHSA states that the National Housing Strategy is to “focus on improving housing outcomes for persons in greatest need.”  Refugees come to Canada seeking safety and protection from persecution, oppression, and trauma. They are clearly among those in greatest need of government action to respect, protect, and fulfill their rights. Though not officially linked to the National Housing Strategy, IHAP is a crucial part of the federal government’s constellation of housing programs. The funding cuts are clearly contrary to the purposes and statutory requirements set out in the NHSA.  

Section 5(2)(d) of the NHSA states that the National Housing Strategy must “provide for participatory processes to ensure the ongoing inclusion and engagement of civil society, stakeholders, vulnerable groups and persons with lived experience of housing need, as well as those with lived experience of homelessness.” A core aspect of a human rights-based approach is empowering those whose rights have been denied to shape the policies and programs that affect them. Cuts to IHAP were made without any such participatory process.   

Violations of the Charter of Rights and Freedoms 

Cuts to IHAP predictably expose refugees to risks to their life and to serious harms to security of the person, both of which are protected under section 7 of the Charter.  

Furthermore, refugee claimants, who are disproportionately racialized and marginalized, have the right to equal access to basic shelter compared to non-refugees under section 15 of the Charter. The federal government is rolling back a critical ameliorative measure required to address pre-existing disadvantage faced by this group.  

Violations of international human rights law 

Canada acceded to the International Covenant on Economic, Social and Cultural Rights in 1976, committing the federal and all sub-national governments to uphold minimum core obligations under the right to adequate housing. This includes providing immediate access to emergency shelter for every person who requires it. (The Committee on Economic, Social and Cultural Rights’ General Comment No. 4 affirms that access to shelter is an immediate obligation that must be provided without discrimination.) Under article 2, this right must be guaranteed without discrimination based on national origin.   

Similarly, articles 21 and 23 of the 1951 Refugee Convention require that the government provide equal treatment to refugees in housing and public assistance.  

Canada as a champion of human rights  

Canada prides itself on its human rights record and has bid to join the UN Human Rights Council for the 2028-2030 term. We suggest that it is incumbent on us, before assuming such an important global role, to examine our own conduct and ask whether we are living up to the same standards we seek to advance globally.   

Refugees come for a safe place to recover and rebuild their lives, and Canada has benefitted immensely from the contributions they have made to our economy and our society. Our country can afford dignified shelter for refugees. This is not an issue of jurisdiction or even of money. This is fundamentally about people and whether we are willing to stand up and protect human dignity for all.  

We urge you to reconsider your cuts to IHAP immediately. 

Sincerely, 

Elizabeth McIsaac
Chair, Housing Rights Advisory Committee, City of Toronto 
President, Maytree  

CC:
The Right Honorable Mark Carney, P.C., M.P., Primer Minister of Canada 
The Honorable Sean Fraser, P.C., M.P., Minister of Justice and Attorney General 
The Honorable Gregor Robertson, P.C., M.P., Minister of Housing and Infrastructure 
Her Worship Olivia Chow, Mayor, City of Toronto 
Councillor Gord Perks