On January 16th, 2024, the Canadian government published a piece of policy that had been in the works for almost a year: the Policy on Sensitive Technology Research and Affiliations of Concern (STRAC). This piece of policy is a paradigm-shifting piece of legislation that will revolutionize the way that research is conducted throughout Canada. The STRAC presents strict restrictions on research done in Canada in two major aspects: involved organizations and fields of study. These restrictions are to be imposed on Canadian universities and organizations that receive funding from the Canadian federal granting councils starting in early 2024. As we explore these restrictions further, it is crucial to note that this legislation is liable to change and discussion at the government level.

The development of the STRAC was first marked by a joint announcement on February 14, 2023, in which the Minister of Innovation, Science and Industry, the Minister of Health, and the Minister of Public Safety announced the intention to “adopt a further enhanced posture regarding national security.” The announcement, and subsequently the creation of the STRAC, are funded upon the belief that Canada’s research sector is a prime target for foreign actors that may pose severe risks to national security. This belief stems from claims by the Canadian Security Intelligence Service (CSIS), in which they stated they had evidence that China was encouraging researchers to partner with Canadian universities in order to gain information that would lead to military advancements. Developing further upon this, when the STRAC was published, it included 5 key principles that are pronounced to be the defining factors of the legislation, namely: risk-targeted, science-appropriate, transparency, collaboration with the research community, and lack of discrimination. Nonetheless, these principles, or lack thereof in the policy’s restriction, appear to undermine the STRAC in its entirety.

Included with the publication of the STRAC are two lists: Sensitive Technology Research Areas and Named Research Organizations, both of which detail the areas of restriction listed by the government. The first list discusses “sensitive” research topics, and is, generally speaking, targeted to STEM fields. This includes, but is not limited to, research done for the development of artificial intelligence as well as the fields of aerospace, medical, quantum science, and robotic technologies respectively, all of which are studied and researched by faculty and students here at McGill University and at various other universities across Canada. The second list of restrictions focuses on research organizations that are considered to “pose the highest risk to Canada’s national security due to their direct or indirect connections with the military, national defence, and state security entities.” It is made up of almost 105 organizations and universities, all of which are located in either Russia, China, or Iran. This locational restriction seems to be in direct contrast to the statement that these organizations may “originate from anywhere in the world.”

While the policy is initially difficult to comprehend, it contains an appendix of crucial definitions to cut through the layers of restrictions and complicated premises. Generally speaking, funding restrictions will be applied to researchers in “sensitive” fields that are affiliated with the named research organizations. For the purpose of the policy, researchers are defined as “applicants, co-applicants, collaborators, and highly qualified personnel,” which includes undergraduate and graduate students, post-doctoral fellows, as well as research staff who seek funding from the federal granting councils. Affiliation is measured by the status of employment, appointment, or research status at any one of the named organizations. Thus, academic research in Canada has now entered a new age, one in which international cooperation will be heavily limited under these premises.

Institutions across Canada, namely those part of the U15 group, Canada’s 15 research-intensive universities, have published statements regarding the STRAC policy, as members of the greater academic community now face fears that their research aspirations are no longer feasible. In addressing their academic community, the administration at the University of Toronto has issued a statement ensuring that “the needs of the research community are reflected in the implementation of this new policy.” On a similar note, the University of Alberta reached out to their community ensuring that they remain devoted to safe and responsible research while simultaneously being committed to technology transfer collaboration.

As one of Canada’s most international universities, McGill has issued a statement of their own, in the form of a university-wide email, in response to the government's work. The statement began by reiterating a commitment to “openness in academic research and international collaboration.” With over 12,000 international students, approximately 30 percent of its student population, the McGill research community will undoubtedly face consequences in light of the STRAC restrictions. Those concerned are encouraged to reach out to Professors and Department Administrators for guidance in navigating the implications that STRAC may pose for their own work.

In the initial publication of the STRAC, the government announced that the lists are not comprehensive and are due to change over time. As it currently stands, the policy seems to be self-contradicting, insofar as it establishes a commitment to nondiscrimination and collaboration while also strictly targeting research organizations found in three countries. While it is unclear what direction future developments will move in, regarding restrictions, it should ultimately be stated that the policy represents a stark contrast to the current levels of international cooperation that Canadian researchers currently benefit from.