June 17, 2025
The Honourable Gary Anandasangaree, P.C., M.P.
Minister of Public Safety
House of Commons
Ottawa, Ontario
K1A 0A6
The Honourable Lena Metlege Diab, P.C., M.P.
Minister of Immigration, Refugees and Citizenship
House of Commons
Ottawa, Ontario
K1A 0A6
RE: The Strong Borders Act and its Harm to People Living with HIV and Other Marginalized Communities
We, the undersigned organizations, write to express our deep concern about the Strong Borders Act and the devastating impact it will have on people living with HIV and those from other marginalized communities.
For decades, our organizations have worked to advance the rights, health, and dignity of people living with HIV, including newcomers to Canada. The proposed legislation threatens to undo this work by further entrenching the harmful Safe Third Country Agreement (STCA) and expanding immigration detention, while introducing expansive barriers to refugee protection that will exclude genuine claimants. The proposed legislation will also increase the discretionary powers of immigration authorities, including providing them with excessive access to sensitive personal information. These measures will drive people further from safety, care, and justice.
Among its most troubling provisions, the legislation would:
- Cement the barrier on refugee claims for people who entered Canada irregularly from the U.S., despite overwhelming and ongoing evidence that the U.S. is not safe for many, including LGBTQI+, racialized people, and people living with HIV. These individuals face heightened risks in U.S. immigration detention, including denial of medical treatment, violence, and solitary confinement.
- Deny access to refugee claims for people who file claims more than one year after first arriving in Canada — a rule that applies retroactively to June 24, 2020. Over time, this will effectively bar people from seeking protection in Canada if they visited the country more than a year earlier. This approach ignores the evolving nature of persecution (i.e. for anyone who has not yet claimed protection). People may not recognize or may fear disclosing the risks they face immediately, particularly those related to changing health conditions, gender identity, or sexual orientation. Moreover, the barrier places people in danger in circumstances where conditions change in their country of origin.
- Largely restrict refugee protection in Canada to those who can obtain a Canadian visa, an option out of reach for many people at risk. In many cases, an immigration medical examination, including a mandatory HIV test, is required. This can result in refusals on health grounds or expose applicants to stigma and discrimination. For people persecuted for their health condition, sexual orientation, or gender identity — particularly in countries where such are stigmatized or criminalized — the process may be dangerous. These barriers mean that many of the people most in need of protection will now effectively be shut out of the system.
- Force many claimants into the Pre-Removal Risk Assessment (PRRA) process, a narrow and opaque mechanism that lacks full procedural protections and is overseen by non-specialist decision-makers. Acceptance rates for PRRA applications remain shockingly low, raising serious concerns about fairness and due process, and family reunification is often out of reach, as the PRRA process has fewer protections for dependent children abroad. As a result, many people with genuine protection needs are likely to be denied — not because their claims lack merit, but because the process itself is deeply flawed. This will inevitably lead to a surge in judicial reviews at the Federal Court, further burdening an already overwhelmed system, increasing costs, and delaying justice for those at risk.
- Increase the use of immigration detention, as more people are filtered through the PRRA process, where people are held in prison-like conditions indefinitely with limited oversight. This is particularly harmful to people living with HIV, people who use drugs, and those with other health conditions who often face inconsistent or inadequate access to medication, harm reduction, and other healthcare. Immigration detention has caused lasting trauma and contributed to multiple deaths. It also disproportionately affects racialized, disabled, and gender-diverse individuals.
These sweeping changes will make it even harder for people in Canada to access healthcare. When immigration laws instill fear of detention, deportation, or exposure, people avoid seeking care, particularly those from countries where HIV is highly stigmatized. At a time when Canada is the only G7 country with rising HIV rates, we should be removing barriers to care, not entrenching them in law.
We urge you to withdraw the Strong Borders Act.
We are united in the belief that Canada must uphold the rights and dignity of all people, including those living with HIV and seeking safety. We request a meeting with your office to further discuss these concerns.
Sincerely,
HIV Legal Network | Anne-Rachelle Boulanger, Policy Analyst
HIV & AIDS Legal Clinic Ontario | Ryan Peck, Executive Director
On behalf of the undersigned:
Action Hepatitis Canada Montreal | QC
Jennifer van Gennip Executive Director
Afro-Canadian Positive Network of BC | BC
Patience Magagula – Executive Director
AIDS Committee of Ottawa Ottawa | ON
Khaled Salam – Executive Director
Aids Community Care Montreal/ SIDA Bénévoles Montréal Montreal | QC
Mira Soueid – Executive Director/ Directrice générale
Algoma Community Legal Clinic | ON
Nuala Kenny – Executive Director
ANKORS | BC
Cheryl Dowden – Executive Director
Asian Community AIDS Services (ACAS) | ON
Ambrose Fan – Executive Director
Black Legal Action Centre | ON
Demar Kemar Hewitt – Executive Director and General Counsel
Canadian AIDS Society/Société canadienne du sida | ON
Christopher Mallais – Office Manager
Canadian Positive People Network | ON
Breklyn Bertozzi – Executive Director
CAYR Community Connections York Region | ON
Marie Morton – Executive Director
CATIE | ON
Jody Jollimore – Executive Director
Centre Action Solidarité | QC
Jeannette Uwantege – Coordonnatrice générale
Centre Associatif Polyvalent d’Aide Hépatite C (CAPAHC) | QC
Laurence Mersilian Directrice Générale
Centre des R.O.S.É.S. de l’Abitibi-Témiscamingue | QC
Vincent Roy Landry – Directeur Général
Centre for Spanish Speaking Peoples (CSSP) Toronto | ON
Amilcar Kraudie – Executive Director
Childhood Arrivals Support and Advocacy Centre of Canada | ON
Sarah Pole – Executive Director
Chinese & Southeast Asian Legal Clinic (CSALC) | ON
Christine Dang – Executive Director
Coalition des organismes communautaires québécois de lutte contre le sida (COCQ-SIDA) | QC
Ken Monteith – Directeur général (Executive Director)
Community Advocacy & Legal Centre | ON
Lisa Turik – Lawyer/Executive Director
Community Alliance For Accessible Treatment | ON
Furqan Waleed – Executive Director
Community Legal Clinic – Brant, Haldimand | ON
Carrie Sinkowski – Community Developer
Community Legal Clinic of York Region York Region | ON
Jeff Schlemmer – Executive Director
Community Legal Services of Ottawa/Services juridiques communautaires d’Ottawa | ON
Lili-Anne Kondo – Community Developer
Downtown Legal Services | ON
Asiya Hirji Supervising Lawyer
Elevate NWO | ON
Holly Gauvin – Executive Director
Gay Men’s Sexual Health Alliance | ON
Gilles Charette – Director
Hamilton Community Legal Clinic | ON
Clare Freeman – Executive Director
Health initiative for Men Vancouver | BC
Aaron Purdie – Executive Director
HIV Network of Edmonton Society | AB
Catherine Broomfield – Executive Director
Income Security Advocacy Centre (ISAC) / Centre d’action pour la sécurité du revenu (CASR) | ON
Claudia Calabro – Community Organizer
Inter-Clinic Immigration Working Group | ON
Natasha Manning – Co-Chair
Intervention régionale et information sur le sida – (I.R.I.S.-ESTRIE) | QC
Charlene Aubé – Directrice générale
Justice for Children and Youth Toronto | ON
Mary Birdsell Executive Director
Legal Assistance of Windsor | ON
Shelley Gilbert – Executive Director
Legal Clinic at Lincoln Alexander School of Law, Toronto Metropolitan University Toronto | ON
Khalid Janmohamed – Director, Legal Clinic
Northumberland Community Legal Centre | ON
Missy McLean – Registered Social Worker
Noumena Consulting Ottawa | ON
Johan du Plessis – Owner
Ontario AIDS Network Toronto | ON
Nasra Smith – Executive Director
Moyo Health and Community Services | ON
Jillian Watkins – Executive Director
PAN | BC
J. Evin Jones – Executive Director
PARN | ON
Jayne Dinesen – Executive Board Member
PEERS Alliance Charlottetown and Summerside | ON
Josie Baker – Executive Director
Portail VIH/sida du Québec | QC
Guillaume Tremblay-Gallant – Executive director
Positive Health Network | ON
Timothy McClemont – Executive Director
Positive Living Niagara | ON
Jackie Barrett-Greene – Director of Support, Education and Volunteer Services
Positive Living North: No kheyoh t’sih’en t’sehena Society | BC
Alexandria West – Executive Director
Pozitive Pathways Community Services | ON
Michael Brennan – Executive Director
Renfrew County Legal Clinic ON
Amy Scholten – Executive Director
Rexdale Community Legal Clinic | ON
Yodit Edemariam – Director of Legal Services
Ribbon Community | BC
Sarah Chown – Executive Director
Scarborough Community Legal Services | ON
Renee Griffin Executive Director
South Asian Legal Clinic of Ontario | ON
Shalini Konanur – Executive Director / Lawyer
Sudbury Workers Education and Advocacy Centre Sudbury | ON
Scott Florence – Executive Director
Tandem Mauricie | QC
Sébastien Perron – Direction Générale
The Neighbourhood Group Community Services | ON
Bill Sinclair – CEO
Uniphare | QC
Charles-Antoine Goulet – Responsable de la coordination
Women and HIV / AIDS Initiative (Initiative Femmes & VIH / SIDA) | ON
Molly Bannerman Director
Women’s Health in Women’s Hands Community Health Centre Toronto | ON
Wangari Tharao – Director, Research and Programs