For nearly three decades, Canadian universities and colleges have operated under a mandate requiring Institutional Research Ethics Boards (REBs) to scrutinize studies and ensure adherence to the Tri-Council Policy Statement on Ethics and Research (TCPS2). This regulatory framework, designed to safeguard research participants, has, however, become a significant point of contention for researchers across the country. Systemic concerns and difficult experiences with the functioning of this regime have been voiced consistently, primarily revolving around issues of "ethics sprawl" or "creep"—the expanding scope of ethical review beyond its core intent—and the bureaucratization of risk management. Despite these persistent criticisms, the trend has been towards intensifying, rather than streamlining, the review process. The 2022 update to the TCPS2, for instance, saw its length increase by nearly 25 percent to 288 pages, adding layers of complexity. Crucially, there appears to be a dearth of research evaluating the actual effectiveness of these procedures in protecting participants, with no universally agreed-upon standard for measuring success.
Decades of Dissatisfaction: A Pattern of Escalating Review
The journey of research ethics review in Canada has been a gradual ascent in regulatory demands. The initial implementation of REBs in the late 20th century aimed to establish a robust ethical oversight mechanism following growing global awareness of research misconduct and participant vulnerability. The TCPS2, first introduced in 1998, provided a foundational document for ethical conduct in federally funded research. However, as the policy evolved, so did its interpretation and application by REBs. Researchers began reporting instances where the review process extended beyond its intended scope, delving into areas considered outside the purview of ethical considerations.
Personal accounts from academics paint a picture of a process that has become increasingly arduous. Short-term grants have, on occasion, expired before ethics clearance could be secured for low-risk projects. Feedback from REBs has sometimes veered into domains that researchers deemed irrelevant to ethical considerations, such as critiques of literature review content or the requirement to address the hypothetical risk of survey participation causing participants to experience boredom. The complexities are amplified in multi-institutional projects, where navigating the ethics clearance processes across different universities has proven to be exceptionally burdensome and marked by inconsistency.
A National Survey Reveals Widespread Frustration
Prompted by these personal experiences and a suspicion that their difficulties were not isolated incidents, a group of researchers embarked on a national survey to gauge the broader sentiment among their colleagues. The objective was to move beyond anecdotal evidence and gather quantitative data on the impact of REB processes. The survey, a 28-question online instrument, was distributed to social science researchers at Canadian universities. A convenience sample of 620 individuals responded to the invitation, which was sent via email to 4,625 faculty members in Economics, Sociology, Political Science, and Anthropology, drawing email addresses from publicly available sources. No incentives were offered, and no follow-up communications were made to encourage participation.
The findings of this survey underscore the pervasive nature of dissatisfaction. A significant 58 percent of respondents indicated that the ethics review process deterred them from undertaking research altogether. Large proportions of researchers reported avoiding the use of interviews, surveys, or even routine classroom assessments due to the anticipated workload associated with REB applications. The extensive scrutiny from REBs has also demonstrably shaped study designs. Over half of the respondents confessed to omitting demographic variables such as sex, gender, and race from their studies, and a substantial 70 percent avoided working with populations identified as "vulnerable" to circumvent potential delays. This avoidance directly undermines critical research aimed at understanding and addressing issues of equity and marginalization.
Impact on Research Design and Scope
The chilling effect of REB processes extends beyond the decision to conduct research; it actively influences what research can be done and how. While some researchers acknowledged finding REB feedback beneficial for refining specific aspects of their protocols, such as consent forms, anonymity protections, data security measures, or Indigenous data governance frameworks, the overwhelming sentiment expressed in open-ended comments highlighted burdensome and distorting effects.
REB decisions have, in numerous instances, necessitated major alterations to study designs. This has included excluding minors from participation, abandoning interviews with victims of violence, mandating active consent for classroom studies where passive consent was previously deemed sufficient, and even blocking direct investigations into racist organizations. These interventions are perceived by many as particularly misaligned with the principles of critical inquiry, minimal-risk qualitative research, and community-engaged scholarship, which often require flexibility and nuanced approaches that may not fit neatly into standardized risk-assessment matrices.
The challenges are compounded for multi-institutional projects. Researchers reported facing duplicative and inconsistent reviews, even when prior ethics approval had been secured from another institution. Furthermore, there appears to be a low awareness and application of TCPS2 exemptions for activities such as quality assurance, program evaluation, and the use of anonymous data, leading to unnecessary review burdens.
The Classroom and Beyond: REBs’ Impact on Education
A particularly concerning aspect of the survey findings relates to the impact of REB procedures on teaching and pedagogical practices. A striking 71 percent of faculty respondents reported avoiding the design of assignments that involved data collection due to concerns about REB workload or delays. The majority of these faculty members had advised their graduate students to steer clear of data collection as a component of their coursework. Furthermore, nearly half of the faculty members whose roles involved community placements indicated that students were unable to conduct research during these experiential learning opportunities because of REB limitations. This has a direct consequence on the development of essential research skills among the next generation of scholars and professionals.
An Expanding Definition of "Risk" and Questionable Mitigation
At the heart of the researchers’ concerns lies the perceived expansion of definitions of "risk" and the often-questionable approaches to mitigating these perceived risks. The survey respondents overwhelmingly expressed that the REB system imposes discouraging levels of hassle and exhibits gatekeeping behaviors that add undue complexity to the research endeavor. This is particularly noteworthy given the lack of concrete evidence demonstrating that specific REB requirements consistently enhance the protection of research participants. The system, while well-intentioned, seems to have become an impediment rather than an enabler of responsible research.
Rebuttals and Resistance: Navigating the Discourse
Even in the process of conducting, discussing, and publishing this research, the authors encountered what they describe as "curious push-back." During the data collection phase, an REB official from one university contacted the researchers, demanding that they cease contacting faculty members at that institution, asserting that REB clearance was required from their university to contact their staff via publicly posted emails. In conference presentations where REB officials were present, the researchers were reportedly told they were not sufficiently emphasizing the positive aspects of REB review. Anonymous reviews for manuscripts detailing faculty and graduate student experiences have, at times, requested that the arguments be reframed to highlight deficiencies in researchers’ understanding and application of TCPS protocols, rather than focusing on the perceived shortcomings of the REB system itself. Invitations extended to TCPS representatives to participate in scholarly panels discussing the impact of REB practices have, according to the authors, gone unanswered.
This resistance suggests a deeply entrenched system and a potential reluctance to acknowledge or address the systemic criticisms. The issue is undeniably divisive. While virtually all responsible researchers acknowledge the paramount importance of research ethics, many fundamentally disagree with the aggressive nature of policing researchers, particularly concerning studies deemed to involve minimal or negligible risk. The current REB practices not only serve to dissuade valuable research but also actively inhibit critical aspects of teaching, specifically the instruction of research methodologies and the practical application of theoretical concepts to lived experiences.
Towards a More Effective Framework: Recommendations for Reform
In light of the extensive literature review and the direct feedback from over 600 Canadian researchers, the authors propose four concrete recommendations, which they believe are relatively straightforward to implement and would significantly improve the current landscape:
- Streamline Minimal-Risk Review: Implement a tiered review process that significantly expedites the review of studies deemed to be of minimal risk. This could involve pre-approved checklists for common minimal-risk methodologies and a shorter review turnaround time.
- Enhance Researcher Training and Support: Move beyond punitive measures and invest in robust training programs for researchers on ethical principles and TCPS2 compliance, coupled with accessible support services to assist with application preparation.
- Standardize Multi-Institutional Approvals: Develop a national framework or platform for the recognition of prior ethics approvals across institutions, reducing the burden of duplicative reviews for multi-site studies.
- Regular Effectiveness Audits: Mandate and conduct regular, independent evaluations of REB effectiveness, focusing on participant protection outcomes rather than solely procedural compliance. This would involve establishing clear metrics for success.
A Call for Action and the Future of Research Ethics
These recommendations, born from the lived experiences and feedback of a substantial cohort of Canadian researchers, represent a call for a more balanced and effective approach to research ethics oversight. The question remains: who will listen?
The Tri-Council is currently soliciting feedback on proposed updates to the Tri-Agency Framework: Responsible Conduct of Research, with a deadline of April 17, 2026. This period presents a critical opportunity for researchers, institutions, and the public to voice their perspectives and advocate for meaningful reform. Engaging with this consultation process is vital to ensuring that the regulatory framework evolves to genuinely support and enhance, rather than impede, the pursuit of knowledge and the ethical conduct of research in Canada. The ongoing dialogue and potential for policy adjustments underscore the dynamic nature of research ethics and the imperative for continuous evaluation and adaptation to meet the evolving needs of the research community and the public it serves.
