By Karine Coen-Sanchez

Ontario’s Bill 166, or the Strengthening Accountability and Student Supports Act, has sparked significant debate and drawn a clear line for equity advocates across Canada. Promoted as a measure for policy reform, the bill’s implications are far-reaching, particularly for educational institutions, workplace standards, and community support systems — areas that disproportionately impact marginalized groups.

Central to these discussions is the recurring question: Who leads these policies, and whose experiences are being centred in the creation of so-called “inclusive” practices?

As a researcher focused on the lived experiences of Black and racialized communities in Canada, I approach this legislation with both caution and critical analysis. While Bill 166 claims to strengthen accountability and improve student supports, its potential to exacerbate inequities cannot be ignored.

Unpacking the concerns

At its core, Bill 166 aims to standardize practices that ostensibly support economic and social reform. However, a closer look reveals several challenges, particularly when viewed through an intersectional lens that considers systemic inequities:

• Ministerial overreach: The bill grants extensive powers to the Minister of Colleges and Universities to issue directives. These powers could be used to limit academic freedom, silence dissent, and penalize students or faculty for addressing contentious issues, such as the Israel-Palestine conflict.
• Racism and hate policies: The requirement for institutions to implement policies to address racism and hate, while laudable, risks being weaponized to target marginalized groups rather than protect them. Without clear anti-racist frameworks, these policies could perpetuate harm.
• Polite racism: My research has shown how “polite racism” operates in ostensibly inclusive environments, where subtle biases manifest as microaggressions, exclusion from opportunities, and coded language. This form of racism thrives when systemic barriers remain unaddressed, particularly in educational and workplace settings.
• Student mental health: The bill’s provisions for mental health policies may fall short in addressing the unique challenges faced by students from marginalized backgrounds, leaving significant gaps in support systems.

Polite racism: A hidden barrier

Unlike overt discrimination, polite racism is insidious. It appears in environments where exclusion is framed as “help,” where microaggressions and implicit biases are normalized, and where racialized individuals are held to higher standards or denied opportunities. In workplaces, this may mean limited access to leadership roles or harsher disciplinary measures. In schools, it manifests as low expectations, underrepresentation in curricula, and a reluctance to address systemic inequities.

The framing of Bill 166 risks perpetuating these barriers. By focusing on “standardization” without addressing the lived experiences of marginalized groups, the bill can reinforce systems of exclusion. My work as co-chair of the Social Sciences and Humanities Research Council (SSHRC) Advisory Committee to Address Anti-Black Racism has highlighted the urgent need to dismantle these subtle yet pervasive barriers.

Lessons from Canadian policy reform

Bill 166 is not unique in its aspirations — or its potential pitfalls. Similar efforts in other provinces provide critical lessons:

• Ontario’s Employment Equity Act sought to create fair hiring practices but faltered due to insufficient enforcement.
• British Columbia’s anti-racism strategies in schools exposed gaps in cultural competence among educators and highlighted persistent racialized achievement disparities.
• Quebec’s equity-focused policies faced resistance due to a lack of community consultation, underscoring the need for inclusive policymaking processes.

Federal frameworks like the Anti-Racism Strategy 2019-2022 offer valuable templates for embedding accountability and measurable outcomes into equity-focused policies. These examples demonstrate that well-meaning reforms must be grounded in robust, evidence-based practices to create meaningful change.

Advocacy and accountability

The path forward requires more than policy — it demands action. Stakeholders, educators and community leaders must engage directly with policymakers to ensure the voices of marginalized groups are centred in the conversation. Advocacy must go beyond critique to present research-backed recommendations, foster inclusive dialogue, and demand accountability.

My experience with SSHRC and my work on dismantling systemic barriers have shown the power of leveraging lived experiences to inform policy. We must continue to ask the hard questions: How will Bill 166 address the persistence of racial biases? How will it confront the polite racism that pervades our institutions?

Moving forward

Bill 166 has the potential to either advance equity or deepen existing inequities. Policymakers must adopt an intersectional lens, explicitly address polite racism, and prioritize the experiences of marginalized communities. Without these measures, the legislation risks becoming another missed opportunity for meaningful progress.

As equity advocates, we have a responsibility to shape a legislative framework that upholds justice and equality. By centring the lived experiences of those most affected, we can strive for a future where policies reflect the values Canada claims to uphold.

Karine Coen-Sanchez is an award-winning scholar and doctoral candidate at the University of Ottawa. She advocates for anti-racism and equity, driving systemic change within academia and beyond.