Submission to the Government of Canada on the proposed Foreign Influence Transparency and Accountability Regulations

International research partnerships are an essential part of Canada’s open and collaborative research system. These partnerships support world-class scholarship and innovation, generate public value and are grounded in transparent intentions. The principles of academic freedom and institutional autonomy underpin Canadian research and scientific inquiry.

At the same time, evolving threats require that universities, researchers and the Government of Canada respond to efforts to exploit research in Canada and abroad. There is a shared responsibility to protect the research ecosystem. Canadian universities have developed risk-based, robust and targeted measures to safeguard research while maintaining research excellence, including through implementation of the Sensitive Technology and Research Affiliations of Concern (STRAC) framework and the work of the Government of Canada–Universities Working Group on research security.

In our submission, Universities Canada calls for:

1. Exempt academic research publications and scholarly dissemination as foreign influence activities, recognizing existing conflict of interest and affiliation disclosure requirements under the Responsible Conduct of Research and the application of several research security frameworks.
2. In instances where requirements are met to register under the Act, clearly define the respective responsibilities of institutions and individual researchers, ensuring that obligations are proportionate, practicable and aligned with the context of academic research.
3. Re-examine and correct the regulatory cost estimates to more accurately reflect the administrative and compliance burden likely to be incurred by universities, non-profits and charities.

We appreciate the opportunity to comment on these important regulations and look forward to further engagement with the Government on implementing measures that both safeguard national interests and support a strong, open, and collaborative research ecosystem.