Biodiversity Boreal Climate change Freshwater Mountains

Canada's Species at Risk Act: listing lags and limbos

Thompson, P. R., Tissier, M. L., Lewthwaite, J. M. M., Cannon, S. E., Lopez, M. L. D., Menzies, A. K., Perron, M. A. C., Piczak, M. L., Vanderwolf, K., Schiller, L., Bugg, W. S., Bohn, S. J., Palen, W. J., Ray, J. C., & Otto, S. P.

Access

---

Key points

• Canada’s Species at Risk Act (SARA) aims to prevent wildlife extinction and support the recovery and management of species imperiled by human activity. A key first step is official listing under SARA following scientific assessment by COSEWIC and a Cabinet decision. However, while SARA sets deadlines for other stages of the listing process, it sets no deadline for the Minister to forward an assessment to Cabinet, creating the potential for indefinite delay.
• A 2017 federal policy sought to close this gap by establishing recommended timelines for forwarding listing decisions. The study found that the policy has been largely ineffective. Of 288 species examined since 2017, only 6% moved forward within the recommended timeframe, while 31% were eventually forwarded after delays. Of the 181 species still awaiting a decision, 85% had already exceeded the recommended timelines.
• Performance did not improve following the introduction of the policy. Decisions exceeded recommended timelines by an average of 477 days after 2017, compared with 484 days before the policy, and proportionally fewer species moved forward on time. Some groups were especially affected. None of the 64 marine mammals and marine fishes assessed since 2017 had been forwarded to Cabinet by the study cut-off date, and publicly available explanations for delays were often vague or absent.
• The findings expose a fundamental trade-off between administrative discretion and accountability. Flexible timelines can accommodate legitimate needs for consultation, additional information and coordination, but without binding limits or meaningful explanations they can also permit species to remain in limbo indefinitely. The authors argue for stronger accountability, including consideration of mandatory deadlines for this currently discretionary stage of the listing process.

Abstract

Canada's Species at Risk Act (SARA) aims to prevent wildlife extinction and facilitate the recovery and management of species imperilled due to human activity. A species may only be included on SARA after scientific assessment and a Cabinet decision. Recommended timelines for each stage of this process were introduced in 2017. We evaluated the influence of these recommendations by comparing delays before and after 2017, focusing specifically on the second stage where timelines are not mandatory. We also analyzed stated causes of delay for each species considered for listing. We found that decisions were made within the timeframe for only 6% of 288 species, and 31% were listed after delays. Critically, 85% of 181 species waiting for a decision have already exceeded recommended timelines. Timeline compliance did not improve after the 2017 policy was introduced (longer median decision times and proportionally fewer species advanced to decision), where decisions exceeded the timelines by an average of 477 days (versus 484 days pre-2017). Certain species groups, particularly marine vertebrates, experienced disproportionate delays, but publicly available information highlighting causes of delays is limited. Despite the intention of the 2017 policy to expedite decision-making, species at risk in Canada continue to wait.

Recommended citation

Thompson, P. R., Tissier, M. L., Lewthwaite, J. M. M., Cannon, S. E., Lopez, M. L. D., Menzies, A. K., Perron, M. A. C., Piczak, M. L., Vanderwolf, K., Schiller, L., Bugg, W. S., Bohn, S. J., Palen, W. J., Ray, J. C., & Otto, S. P. (2026). Canada's Species at Risk Act: listing lags and limbos. FACETS. https://doi.org/10.1139/facets-2026-0031