Global Affairs Canada CSO Partnership Policy – A Brief Guide and a Call for Engagement

Global Affairs Canada CSO Partnership Policy – A Brief Guide and a Call for Engagement


The ambitious objectives outlined in Canada’s Feminist International Assistance Policy (FIAP) can only be achieved in consultation with international and local civil society. Coherent with the Istanbul Principles and related frameworks such as the International Framework for CSO Development Effectiveness and the Busan Global Partnership for Effective Development Cooperation, FIAP is strengthened by a Policy on Civil Society Partnerships for International Assistance (the CSO Partnership Policy). Constructed in consultation with civil society, this policy outlines and defines how Global Affairs Canada (GAC) will engage with civil society actors on the implementation of the FIAP across nine action areas.


Nine action areas include:

  1. Empowering women and girls, promote gender equality, and reach the poorest, most vulnerable and most marginalized as the most effective means to eradicate poverty
  2. Facilitating a safe and enabling environment for civil society
  3. Protecting human life and dignity
  4. Fostering CSO leadership in innovation
  5. Integrating the role of CSOs as independent actors into international assistance programming
  6. Establishing more predictable, equitable, flexible, and transparent funding mechanisms
  7. Fostering multi-stakeholder approaches to international assistance
  8. Engaging Canadians as global citizens in international assistance
  9. Promoting sustainability, transparency, accountability, and results


Policy Objectives – CSO Implications

The human rights-based feminist approaches of FIAP require fundamental shifts in the structures, policies, processes, and programs of civil society actors working with GAC. Many of these shifts require institutional prioritization and resources, as we learned from civil society organizations (CSOs) partaking in the Women’s Voice and Leadership initiative.

Integrating considerations that account for gender norms and existing inequalities as well as devising tools and processes that allow for more gender-responsive and gender-transformative programs is a sector-wide challenge that can be achieved through collaboration, predictable and inclusive consultations, and continuous learning among diverse partners. To support these efforts, GAC and Canadian civil society crafted a policy outlining the entry points for strengthened government-civil society collaboration.

The CSO Partnership Policy highlights the responsibility of civil society actors to consult marginalized groups, including women and girls and ensure their perspectives are integrated across all areas of program design, delivery, and evaluation. Specifically, organizations are called to employ human rights-based approaches and institutionalize gender-based analysis in all of their work. CSOs should also collaborate with local/national responders as indicated through the guidance A Feminist Approach: Gender Equality in Humanitarian Action to strengthen the organizational and response capacity of local humanitarian actors as well as their long-term sustainability.


Implementation Plan

The CSO Partnership Policy is operationalized through the Implementation Plan, which lists proposed action for each of the nine action areas outlined above. To ensure progress towards the targets outlined in the Implementation Plan, Global Affairs Canada and Cooperation Canada have convened a Civil Society Policy Action Group (CPAG), which is open to civil society actors across the country. The two co-leads comprise the CPAG Secretariat, which on the GAC side reports to the Assistant Deputy Minister (ADM) for the Partnerships for Development Innovation Branch. CPAG gathers specialists from the sector, with each of the nine action areas co-led by representatives from relevant GAC teams and CSOs, who in consultation with broader coalitions formulate recommendations for policy implementation.

In 2018, CPAG devised a national survey, which informed the prioritization of: Objective 1 (Empower women and girls and promote gender equality); Objective 6 (Establish more predictable, equitable, flexible, and transparent funding mechanisms); and Objective 8 (Engage Canadians as global citizens). The implementation plan for the remaining objectives were approved in 2019, offering a policy tool for CSOs working towards a range of FIAP targets.


High-Level Narrative Update on Progress

In 2022, the CPAG produced a series of high level narrative updates on progress. The progress update captured key accomplishments, challenges and opportunities. They were presented in June 2022, as part of the annual CSO-GAC dialogue co-hosted by Cooperation Canada and Global Affairs Canada. 


Next Steps

CPAG is re-convening in 2023 to examine the group’s mandate and reinvigorate progress towards the CSO policy in a changing international cooperation context.

Global Affairs Canada’s CFO Engagement, Dialogue and Exposition: Cooperation Canada Takeaways

In November 2022, Global Affairs Canada (GAC) organized its annual Chief Financial Officer (CFO) Engagement, Dialogue and Exposition. The event brings together civil society and private sector partners with the CFO branch to share information, exchange on challenges and solutions, connect, and learn. The event was packed with useful information and exchange. I cannot possibly outline all the information shared but rather highlight some pretty important changes and points of information for which we should all take note.  


Improving the way we work  

The CFO branch is critical for all that we do in international cooperation with technical processes and procedures impacting our ways of working in both subtle and profound ways. This year’s dialogue covered a diverse range of topics and showcased some really important changes that are going to enable us all to work better and, where possible, in greater accordance with our values.  


Carbon offset credits will enable us to better work by our values 

In line with our shared commitments to combatting climate change, carbon offset credits are now an eligible expense for GAC funded programs. This is an important step in the right direction, particularly as organizations highlighted this challenge for realizing their commitments to climate change in 2020-21 Greening CSOs project. Criteria has been developed for admissible expenses in this regard, aligned with international good practice and the government of Canada’s overall strategy for Greening Government Strategy. Guidance towards practical implementation is forthcoming.  


The streamlined Technical Assistance Handbook offers simplicity and consistency  

Over the past year, GAC updated its Technical Assistance Handbook. GAC staff presented a review of the changes, including a significant reduction in the length of the handbook and a focus on simplicity and consistency; it is hoped the new handbook will be online at the start of 2023. Some important highlights include bringing technical processes and provisions up to date with the principles in the Feminist International Assistance Policy, ensuring consistency in the treatment of Canadian and staff recruited in partner countries, clarity on provisions related to duty of care and consistency for partners in terms of relocation and housing vis-à-vis GAC staff. GAC has also now catalyzed the development of a group insurance plan – which may be the first of its kind in the world – to enable organizations to obtain insurance to support their duty of care to employees. 


Risk management is an opportunity for transparency and capacity improvements  

Historically, Canadian organizations have not had a clear understanding of how the department assesses risk when reviewing potential partners and programs. At the dialogue, GAC staff presented the eight risk factors used by the department and the tools used by GAC to manage risk. Focusing on the criteria relate specifically to the partner, we learned what GAC is looking for in terms of 1) recipient governance, 2) recipient experience, 3) recipient financial viability, 4) corruption and fraud; 5) and recipient capacity and procurement. In addition, a later session presented a concrete overview of processes to manage fraud and corruption specifically.  

We learned that transparency is critical in the risk assessment process – the more information an organization can provide to the department, the more likely they will reduce their level of risk. Partners communicated that transparency works both ways and indeed, clarity on risk requirements affords partners an opportunity to improve their capacities. If organizations know what the department is looking for, they can update their policies, procedures and processes, and support one another through shared spaces like the CFO Working Group to identify best practices and opportunities for learning. CSO stakeholders called on the CFO branch to develop a checklist and further supports to enable partners to improve organizational effectiveness. 


Effective engagement and upcoming consultation  

The CFO branch at GAC is paving the way in terms of what meaningful dialogue and engagement can and should look like with civil society organizations. We all have much to learn from this model – for civil society and other departments at GAC. The November event was built with partner feedback on the agenda, space for questions and partner-led discussions and an exposition that allowed participants to speak directly with staff regarding specific questions for their organization. The dialogue was timely, informed and part of an iterative process. Our CFO Working Group not only inputted on the agenda and timing for the meeting, but also had the necessary information and lead time to prepare, identify priorities and develop recommendations. The CFO branch reported back on action points from its Spring meetings with CFOs and demonstrated accountability for action items identified and noted where constraints remain. This is what effective stakeholder engagement looks like. 

GAC staff shared plans to launch further consultations in 2023, including on overhead and advanced payments. The importance of localization and how that will interface with the Grants and Contributions Transformation initiative and beyond was highlighted as an important topic for future engagements. Cooperation Canada’s CFO Working Group will be an important entry point into these discussions and we look forward to building on the successful and effective engagement with CFO branch that we have come to appreciate and expect. 

Shannon Kindornay

Shannon Kindornay

Chief Operations Officer, Cooperation Canada

2022 CSO-GAC Dialogue on International Assistance and Development: A conversation on fostering an enabling environment for civil society 

2022 CSO-GAC Dialogue on International Assistance and Development: A conversation on fostering an enabling environment for civil society 

On June 30, Cooperation Canada and Global Affairs Canada (GAC) co-hosted the annual CSO-GAC dialogue on international assistance and development issues. At the dialogue, co-chairs of the Civil Society Policy Advisory Group (CPAG) launched a High-Level Narrative Update on Canada’s progress in implementing Canada’s Policy for Civil Society Partnerships for International Assistance – A feminist approach  (the Policy). Produced jointly by GAC and CSO co-leads for the nine objectives found in Canada’s implementation plan for the Policy, the High-Level Narrative Update showcased achievements, challenges and opportunities between 2019 and 2022. In addition to launching the Update, the annual dialogue provided an important opportunity to situate the Policy within the broader context of global commitments to civic space and the CSO enabling environment. In this light, the event featured an exchange on the 2021 DAC Recommendation on Enabling Civil Society in Development Co-operation and Humanitarian Assistance (the DAC Recommendation). The Dialogue also featured breakout discussions on the Policy’s three objectives most closely aligned with the DAC recommendation (Objective 2 – Facilitate a safe and enabling environment for civil society; Objective 5 -Integrate the role of CSOs as independent actors into international assistance programming; and Objective 7 – Foster multi-stakeholder approaches to international assistance).

While the conversation revealed many insights, here are  some key takeaways.


Enabling a democratic and safe civic space

Both the Policy and the DAC Recommendation provide a roadmap to foster a safe, enabling environment for civil society. Year on year, CIVICUS monitors the status of civic space, and the trends are worrying. Though there is certainly work to do, Canada remains “Open” in the latest scoring by CIVICUS, among less than 20 countries to share this rating. Participants noted deep concern at the rising prevalence of anti-democratic and authoritarian forces around the world, noting these trends are impacting our shared ability to deliver on Canada’s vision for feminist international assistance. Closing civic space undermines the international cooperation sector’s efforts to balance power, to advance localization and to improve effectiveness. Without strong commitment by all stakeholders  to promote democracy and civic space, including the three critical pillars outlined in the DAC recommendation, our international cooperation efforts will become increasingly difficult to deliver in the coming years. Government-civil society collaboration in advancing the Policy and the DAC recommendation are an important step in the right direction.


Opportunities and challenges: Facilitating partnerships, collaboration and fostering inclusivity

The High-Level Narrative Update noted GAC and CSOs progress specifically in two key areas: 1) advancing gender equality; and 2) streamlining processes, exploring innovative solutions, and improving transparency, accountability and results of international assistance, through dialogue and collaborative action.

Looking ahead, there are challenges to overcome and opportunities to seize. For example, participants noted the prevalence of barriers to partnership, particularly for CSOs in partner countries. How localization commitments have yet to truly bear fruit (considering  commitments under the Grand Bargain in 2016 and  historic commitments to country ownership stemming from the aid effectiveness agenda since the early 2000s) was central to the conversation. However, some positive steps have certainly been made both by CSOs and Global Affairs Canada. (Please see some examples here under Objective 1 in the Narrative Update reports). At a workshop in May 2022, the CSO Working Group on the DAC Recommendation on Enabling Civil Society (part of the DAC-CSO Reference Group) facilitated a discussion among southern CSO colleagues to identify reforms that would enable funding for southern CSOs. The outcome document pointed to pending areas for change including shifting from colonial mentalities to trust and respect for Southern CSOs, focusing on local priorities, and new ways of funding and working that promote collaboration and make use of CSOs platforms and coalitions to maximize outcomes.   Referring to the workshop during the Dialogue, Anabel Cruz, Founder Director of the Institute for Communication and Development (Uruguay), noted that Southern CSOs continue to face pressure for upward accountability to donors, rather than the communities in which they work. Discussions also pivoted around how expanding public-private partnerships could bring in voices outside the usual suspects and add to collaboration towards common goals, such as the UN Agenda 2030/Sustainable Development Goals. 

In addition, participants highlighted the need for greater diversity of perspectives across global fora for multi-stakeholder partnership, such as the Global Partnership for Effective Development Cooperation, as well as in the spaces created with Global Affairs Canada to promote a CSO enabling environment. Dialogue and engagement should reflect shared commitments to empowering marginalized voices and actively engaging peoples, communities and organizations from across Canada in responding to key international development challenges and pursuing common goals.  For example, Indigenous Peoples globally and in Canada have much to contribute in terms of knowledge and ways of knowing and doing that could enrich discussions in Canada and abroad. At the same time, power dynamics within institutionalized fora must be addressed to ensure meaningful engagement. It is not enough to offer a seat at the table; equitable approaches mean addressing barriers to finding the table, pulling up a chair, contributing to agenda setting and ultimately, knowing the table is safe for conversations that challenge historic ways of working. These reflections on how to improve our approach to inclusivity will be key to inform upcoming joint efforts in our work at the CPAG, and on enabling the DAC recommendation.  


Canada’s progress on the DAC Recommendation on Enabling Civil Society should harness existing consultation tables

On July 5th, the DAC Recommendation will see its first anniversary. Both the DAC and GAC have been active in raising awareness of its provisions. During the dialogue, Jacqueline Wood, Team Lead – Senior Civil Society Specialist at the OECD Development Cooperation Directorate, explained how the DAC is working on a set of toolkits that will facilitate implementation of the recommendation, the first of which will focus on “Funding Local Civil Society in Partner Countries.” The International Center for Not-For-Profit Law has also identified donors can take to expand civic space in view of the recommendation and in advance of the promised toolkits. As noted by Brian Tomlinson, Executive Director of AidWatch Canada and facilitator of the CSO Working Group on the recommendation, during the Dialogue, Canada’s progress will require mapping existing policies, mechanisms and opportunities and challenges for implementing the recommendation.

And Canada is well-placed in this regard. Canada has historically championed the CSO enabling environment and spoke out against closing civic space.  For Ministers Sajjan and Joly emphasize advancement of democracy and human rights as core priorities for international engagement, priorities that could not be more timely given global trends.

Moving forward from the launch of the CPAG’s High Level Narrative Update, an opportunity exists for the CPAG to plan forward-looking efforts, including opportunities to advance the DAC recommendation. The CPAG plans to convene a stock take in the Fall to talk about where we are at and the path forward on implementing the Policy.


CPAG Co-Chairs

Shannon Kindornay, Chief Operations Officer, Cooperation Canada

Stuart Savage, Director General – Engaging Canadians, Global Affairs Canada

Is the end near for Direction and Control?

Is the end near for Direction and Control?

In June, Cooperation Canada held a session dedicated to the sector-wide efforts to address the outdated regulatory framework of ‘direction and control’ which imposes significant barriers to establishing equitable relationships with communities and organizations without a charitable status. As the sector gears up for a new season of efforts of legislative change, we hope this Q&A will help.


Why are we (still) talking about the Canada Revenue Agency’s ‘direction and control’ requirements?

The international cooperation sector is undergoing a transformative shift: global governance frameworks are increasingly highlighting the importance of establishing equitable partnerships with local civil society organizations and other non-traditional partners in pursuits of healthier, more equitable and sustainable world for us all. These principles are recognized across global frameworks such as the 2030 Agenda for Sustainable Development (2030 Agenda), the Grand Bargain for Humanitarian Action, and policy instruments such as the recently approved Recommendation on Enabling Civil Society by the Development Assistance Committee of the Organisation for Economic Cooperation and Development (OECD DAC). Canada’s domestic policy framework, such as the Feminist International Assistance Policy (FIAP) espouses the same values. However, the ability of Canada’s charities to establish equitable partnerships with diverse actors working in domestic and international contexts is constrained by the 70-year-old legislative framework dubbed ‘direction and control.’


What is ‘direction and control’?

Canada’s charities are regulated by the Canada Revenue Agency’s (CRA) guidances CG-002 and CG-004 which respectively set conditions for Canadian charities to work with non-charitable actors internationally and within Canada. Building on Income Tax Act (ITA) provisions dating back to 1950s, these regulations represent a global legislative exception, requiring all registered Canadian charities to implement their ‘own activities’ when working with non-registered charities, and to exercise ‘full direction and control’ over those activities.

For Canadian registered charities supporting a project of a local partner without a charitable status, ‘direction and control’ regulations dictate the need for a written agreement that relegates these local partners – who are generally the ones with context-specific knowledge, community ties, and the initiative behind the given project – to the role of ‘intermediaries’ in need of micromanagement. In other words, staff from Canadian charitable organizations are legislatively obligated to insist on compliance processes that undermine the agency and the independence of actors without a charitable status.

In humanitarian contexts where these constraints cost lives and livelihoods, Canada’s charitable organizations again represent a global exception. In the aftermath of disasters and crises, speed and coordination matter. This is why the global community is increasingly working with ‘pooled funding’ where various actors contribute to centrally coordinated response delivered by pre-vetted local actors. Canadian charitable organizations cannot legally participate in most pooled funds and are forced to spend more resources on burdensome reporting requirements. This means that the contributions Canadians direct to solving global challenges are spent less effectively.


How is Direction and Control perpetuating inequality?

Direction and control legislation disincentivizes Canada’s charities from supporting nonprofit and community organizations, as Kevin McCort, the President and the CEO of the Vancouver Foundation confirmed during Cooperation Canada’s Forum 2021, saying that “domestic funders are also increasingly finding that the definition of charitable purposes has excluded a number of groups (…) so we can’t fund (…) community groups, but they are doing the kind of work we want to fund in service of our charitable purposes.” While local actors are proven to be the most effective in addressing community needs including throughout the COVID-19 pandemic they receive insufficient support.

The more marginalized a community is, the less likely it is to have a charitable status. By making it harder for equity seeking groups to access funding, Canada’s legislation is perpetuating inequality. Results of such systems are clear: a Carleton University domestic study found that only 0.7% of grants issued in 2017/2018 was allocated to Black-serving organizations, and just 0.07% to Black-led organizations. Similarly, this analysis of the Registered Charity Information Return database for 2018 shows that Indigenous Groups (defined using the Indigenous Peoples Solidarity Fund developed by Wanda Brascoupe for CanadaHelps) received only $1 for every $178 allocated to non-Indigenous groups.

Internationally, the figures are not better. This 2016 OECD report shows that less than 1% of global funding is allocated to women’s rights organizations in historically disadvantaged countries, and the 2021 Grand Bargain report found that the commitment of ‘localization’ has not been achieved.


How were the ‘direction and control’ regulations updated in November 2020?

In November 2020, CRA updated the above-listed guidance documents for clarity and context-informed amendments. During the same Forum 2021 session in June 2021, Tony Manconi, the Director General of the CRA Charities Directorate outlined these updates. Efforts to clarify the terminology entailed, for example, replacing expressions such as ‘agent’ and ‘agency agreement’ with ‘intermediary’ and ‘intermediary agreement’ and spelling out the definition of the term ‘capital’ to include ‘real property land’ and ‘immovable property on land.’

In terms of the changes that do, effectively, shift CRA expectation, a notable update is that of the increased threshold for projects requiring formal agreements from $1,000 to $5,000. Moreover, CRA will no longer require that non-charitable partners use a separate bank account for charitable funds, but the financial records will need to be fully accounted and linked to the reported expenditures. According to the latest guidance, charities are expected to show ‘direction and control’ via written agreements, detailed descriptions of project activities, monitoring and supervising, regular reporting, ongoing instruction, periodic transfers, and clearly separated activities and funds. The new guidance also clarifies the definition of ‘adequate books and records’ for low and high-risk categories.

While helpful, these amendments made by the CRA do not resolve the central concern of ‘direction and control’ focused on micromanaging local partners’ activities and undermining their agency. With the ‘direction and control’ test solidified in the legal precedence and case law on the Income Tax Act, room for regulatory flexibility on the part of CRA is extremely limited. To truly amend this outdated framework, a legislative change to the ITA is required.


What is the proposed legislative approach?

Significant efforts have been made to inform legislative reforms of the ‘direction and control’ framework. The Advisory Committee on the Charitable Sector (ACCS), established in 2019 to promote dialogue between the CRA, the Department of Finance, and charitable sector experts, has issued recommendations outlined in the January 2021 and April 2021 aligned with previous reports carried out since 2012. These include the 2019 Report of the Special Senate Committee on the Charitable Sector, which suggests removing the ‘own activities’ test from the Income Tax Act and focusing on the expenditure responsibility test instead. The Government response to this report, however, has not outlined a clear way forward.

To move away from activity-based compliance approaches and strengthen financial accountability of charitable actors, Senator Ratna Omidvar proposed the private members Bill S-222, which passed in the Senate on 17 June 2021. As the Senator explained during the June Cooperation Forum session, Bill S-222 builds on examples from countries like the United States and focuses on financial accountability, which leaves further room for subsequent CRA regulations to be developed in consultation with the sector. Furthermore, as a group of charitable lawyers supporting this bill claims, the bill does not erode existing guardrails around other aspects of charity regulations, including those related to anti-terrorism and proceeds of crime (money laundering).

According to Senator Omidvar, Bill S-222 aims to strengthen accountability provisions by expanding the definition of charitable activities and defining reasonable steps for ensuring resource accountability. This includes replacing operational direction and control with full upfront due diligence and establishing partner agreements that would, in line with international standards, list expected outcomes and the impact, reporting requirements, as well as budgetary and activity-level commitments. Non-charitable actors would remain accountable for the use of resources towards declared charitable purposes and desired outcomes, but the legal responsibility for project management and financial control would rest within their institution.


What are the potential next steps?

Bill S-222 was approved in June 2021, thanks to the all-party support of the Senate, which according to Senator Omidvar suggests a common understanding of the importance and the urgency of the proposed amendments. MP Philip Lawrence, the Conservative Party Critic for National Revenue, had committed to tabling the bill in the House of Commons. However, Canada’s federal election has interrupted this process of legislative change and this fall, the bill will need to be re-introduced.

Should Bill S-222 pass both the House of Commons and the Senate this time aroumd, CRA will have two years to produce regulatory guidance that operationalizes the new provisions and clarifies what, for example, an acceptable due diligence process or a partnership agreement would entail.


How can Cooperation Canada members get engaged?

To support sector efforts to amend the ‘direction and control’ legislation, Cooperation Canada members are invited to join a working group dedicated to this agenda. The group will be co-led by Céline Füri (Oxfam-Québec) and John Clayton (Samaritan’s Purse). The group will share intel, resources, and coordinate advocacy outreach in collaboration with other domestic groups. To get engaged you can:

  • Learn more about this issue and consult additional resources on this Cooperation Canada page
  • Join the ‘Direction and Control’ Working Group using Cooperation Canada’s Member Portal. Contact Fanta Diaby for help with the Portal and look out for the next meeting invitation.


Cooperation Canada, CanWaCH and the Humanitarian Coalition applaud the Government of Canada’s early response to avert the looming famine catastrophe

Today, the Government of Canada announced the allocation of $155 million CAD to support countries at the brink of famine. This decision is critical: right now, 11 people are dying every minute due to hunger and 41 million people are at risk of starvation. By acting now, before famine is declared, the Government is helping to prevent a catastrophe.  

This funding will be urgently disbursed across multilateral and civil society organizations for countries designated as most at risk by the international community. Decades of evidence have shown that the best humanitarian responses are early responses. Today’s decision reflects Canada’s commitments to humanitarian principles and international solidarity.  

Today’s announcement builds on commitments made at the G7 Summit in June, when global leaders pledged $8.5 billion towards famine prevention. The urgency of this funding is key: acting before a famine is declared is a humanitarian imperative. When famine is officially announced, it means that 30% of children are already suffering from malnutrition so acute they will either die or face life-long health consequences. Famine also drives conflict, worsens health crises and gender inequality while obliterating generations of investments in livestock, fisheries, and communities’ self-sufficiency.  

Canada is reacting now; before waiting on UN appeals and media moments – showing resolute action that reflects the values of Canada’s Feminist International Assistance Policy. The looming famine crisis is far from over – and women, adolescents and children will continue to be disproportionately affected. We call on Canada to continue to closely monitor the situation and scale up its response in an urgent, predictable, and equitable way, as it has done today.