Reports

What Is a Policy Review?

A policy review is a structured, evidence-based reading of whether an organization’s written policies contain what they are required to contain. For a school board, it compares the content of the board’s publicly available policy documents against the specific obligations set out in provincial legislation, regulations and Ministry directives, in particular the Policy/Program Memoranda (PPMs) issued under the Education Act.

The question a policy review answers is simple: does the document say what it is required to say?

It does not assess whether the policy is being followed in practice. It does not evaluate the quality of a school’s day-to-day operations. It examines only the written record: the policies, plans and procedures that boards are required by provincial policy to maintain and make available to the public.

Acknowledging an Obligation Is Not the Same as Discharging It

This is the central distinction that drives every review on this site, and it is the reason so many boards that appear to have policies in place still do not meet the requirements.

When the Ministry issues a directive (for example, that boards “must establish a process” for parents to report bullying), boards can respond in two fundamentally different ways:

• Acknowledging the obligation: The board restates the Ministry’s language in its own policy. It says, in effect, “we have a process” or “appropriate steps will be taken” or “see Procedure 45.” The requirement has been noted. A box has been checked.
• Discharging the obligation: The board defines the process. It names who the parent contacts, how they contact them, what happens after the report is filed, what timeline applies, and who follows up. The requirement has been met. A parent can act on what they have read.

Many boards reviewed on this site fall into the first category. They have policies. The policies reference the right directives. The language sounds compliant. But when a parent reads the document looking for specific, actionable information (Who do I call? What happens next? What if nothing happens?), the answers are not there.

A policy that says “appropriate action will be taken” without defining what that action is has acknowledged the Ministry’s expectation. It has not discharged the obligation. From a parent’s perspective, a policy that acknowledges without discharging is indistinguishable from no policy at all, because it does not give them the information they need to protect their child.

Our reviews are designed to detect exactly this gap. A board that restates the Ministry’s directive in the board’s own words has not met the requirement; it has only acknowledged it.

Why Policy Reviews Matter

Policies Are the Foundation

Ontario’s safe schools framework depends on a chain of accountability: the Ministry sets requirements through PPMs, boards translate those requirements into local policies, and schools implement those policies in classrooms. If the first link in that chain is broken (if the board’s policy does not contain what the Ministry requires), then everything downstream is compromised. A school cannot implement a reporting mechanism that its board has never defined. A parent cannot follow an escalation path that does not appear in the policy, and PPM 144 requires boards to set one out.

The Value of Independent Review

There is no public record of systematic, province-wide review of board policies against Ministry requirements. Directors of Education are required under the Education Act (s. 283.1(1)(f)) to identify and report non-compliance to their boards, but the results of that reporting are not generally made public. Independent review adds a public, comparable view of how board policies reflect provincial requirements.

Parents Need Reliable Information

When a parent’s child is being bullied, or when a family needs to understand their rights under a code of conduct, the board’s policy is the document they are directed to consult. If that document is missing required content (a reporting path, an escalation mechanism required by PPM 144, a notification obligation), the parent is left without the information the province has already determined they are entitled to have. Policy reviews identify those gaps before a parent has to discover them in a crisis.

How We Conduct Policy Reviews

Every review follows the same four-stage process and applies three core operating rules. The method and criteria for each review are available upon request.

1. Document Collection

We collect policy documents from school board websites by following the links a parent would follow from the home page. For each board, we look for the specific documents required under the instrument being reviewed: codes of conduct, bullying prevention and intervention plans and policies, accessibility policies, plans and status reports, and any related procedures. Anything scored is downloaded and kept as captured on the date of the review. If a document is referenced in a policy but is not publicly available, it is treated as not posted for the purposes of the review. This reflects the parent’s experience: if you cannot find it, it does not help you.

2. Requirement Extraction

Each PPM and statute contains mandatory language (statements using “must,” “shall,” or “will”) that imposes specific obligations on school boards. We extract selected requirements and set them out in a written method, available on request. Only mandatory requirements are assessed. Aspirational language (“should,” “may,” “can”) is noted but does not form the basis of a determination. The requirements tested are not the whole of any instrument.

3. Assessment

Each board’s documents are assessed against that written method using three core rules. Each requirement is scored met or not met, with no partial credit.

• The Parent Bias. We read on behalf of the parent. If a policy is ambiguous, vague, or bureaucratic, it fails. The benefit of the doubt is never given to the institution. A parent reading this document is not a lawyer, not a policy analyst, and not a board employee; they are a person trying to protect their child. If the document doesn’t give them clear, actionable information, it fails.
• The Four Corners Rule. We assess the completeness of the provided text only. If the policy references an external document (“See Procedure 45” or “As per the Education Act”) without including the specific steps in the document under review, it fails. A parent who downloads a policy from a board website will read that document, not the five cross-referenced documents they would need to track down to assemble the full picture. A requirement is met only when the obligation is discharged within the documents under review.
• The Mandatory Language Rule. Language creates or destroys obligation. “Will,” “shall,” and “must” are commitments; they pass. “May,” “should,” “can,” and “encouraged” are suggestions; they fail. A policy that says principals “should notify parents” is telling you that notification is optional. In a bullying context, optional notification is operational failure.

4. Review

For the 2026 reviews of all 72 Ontario school boards, every determination that turned on a judgement was decided against written rules, under a documented review protocol, before publication, so the same wording is scored the same way at each board reviewed. File measurements (for example, whether a PDF is tagged or declares a language) were made by machine on the live file. The parent bias applies at every stage: if a reasonable parent reading the policy would not be able to determine their rights or the board’s obligations, the requirement is marked not met.

Verification practice for the 2025 pilots is stated on each pilot’s page.

Our Reviews

School Board Research has published reviews against the following provincial instruments. Board-by-board results are on the Board Report Card; the 2026 results are also kept at a fixed address, /board-report-card/2026-review/.

• PPM 128: Code of Conduct: all 72 boards reviewed in 2026 against selected requirements. No board met all of the requirements tested. The 2025 pilot (60 English-language boards, five requirements) is retained here.
• PPM 144: Bullying Prevention and Intervention: all 72 boards reviewed in 2026 against selected requirements. No board met all of the requirements tested. The 2025 pilot (29 English-language boards, seven requirements) is retained here.
• Accessibility (AODA and the Integrated Accessibility Standards): all 72 boards reviewed in 2026 against selected requirements for the accessibility documents a board must publish. No board met all of the requirements tested.

All 72 boards will be reviewed again in mid-January 2027, and the result published beside the 2026 figures.

What Policy Reviews Cannot Tell You

A policy review examines what is written, not what is practised. A board that does well on a policy review may still fail its students in implementation. Conversely, a board whose policy document does not meet the requirements may have strong informal practices that protect students in ways the written policy does not capture.

However, good policy is a necessary precondition for good practice. A school cannot consistently implement what its board has never defined. And for parents, who are directed to these documents when they need help, the written policy is the only reliable guide they have.

The reviews are research findings about published documents. A result of Not met is not a finding that the board has contravened the law, and it is not legal advice.

Principles

All reviews published on this site follow these principles:

• Public documents only. We assess what a parent can access. Internal procedures, draft documents, and materials not available on the board’s website are not considered.
• Mandatory language only. We assess requirements the Ministry or the statute has stated boards “must” meet, not aspirational guidance or best practices.
• Parent perspective. Each requirement is assessed from the standpoint of a parent seeking information. If the required content exists but cannot reasonably be found, it is treated as absent.
• Discharge, not acknowledgement. A board that restates a Ministry requirement without operationalizing it has not met the requirement. We assess whether the obligation has been met in substance, not merely referenced.
• Corrections welcome. A board that considers a result wrong can respond through the board response form. It must show that the document or language that answers the requirement was published on its website on the date of the review, in a form that meets the requirement, and give the route from the board’s home page by which a parent would have reached it. A result shown to be wrong on that evidence is corrected, and the correction is noted.
• Transparency. Sources consulted are logged with access dates as part of the method. Every result identifies the specific board document and language it relies on. The method and criteria are available upon request.

What Can You Do?

If the results show your board’s documents do not include what provincial policy calls for, you are not powerless. Here is what you can do, and roughly the order in which to do it.

1. Read the Policy Yourself

Go to your board’s website and find the relevant policy document (the Code of Conduct, the Bullying Prevention and Intervention Plan, or whatever applies). Read it the way you would if your child came home tomorrow and told you something had happened. Ask yourself: does this document tell me who to contact, what will happen after I report, how long it will take, and what to do if nothing changes? If you cannot answer those questions from the text in front of you, the policy has a gap, and it is not your fault for not understanding bureaucratic language. The policy was supposed to give you that information. It didn’t.

2. Write to the Director of Education

Do not start at the school level for a policy gap; this is a board-level problem. Write directly to the Director of Education. Be specific: name the PPM, name the requirement, and identify what is missing from the policy. For example: “PPM 144 requires boards to establish a process for parents to report bullying incidents. Your board’s Bullying Prevention and Intervention Plan does not describe this process. I am requesting that the board update its policy to include a clearly defined reporting mechanism, as the Ministry directive requires.” Ask for a written response. Keep a copy of everything.

3. Escalate to the Ministry of Education

If the board does not respond, or responds without addressing the substance of your concern, contact the Ministry of Education. The Ministry issues the directives that boards are required to follow, and it has the authority to intervene when boards do not follow provincial policy. The Ministry cannot act on gaps it does not know about. Your letter, with the specific PPM, the specific requirement and the specific gap, gives them something concrete to work with. You can reach the Ministry’s Parent Engagement Office at 1-800-387-5514 or through the Ministry of Education website.

4. Connect with Other Parents

One parent raising a concern is easy to dismiss. Ten parents raising the same concern, with the same evidence, is not. Organizations like Hold Schools Accountable are building networks of parents who are doing exactly this work: reading the policies, identifying the gaps, and asking boards to meet the standards the province has set. You do not have to do this alone, and you should not have to.

The purpose of this work is to give parents the information they need to hold their boards accountable, and to give boards a clear, evidence-based picture of where their policies fall short, so they can fix them. Every board reviewed on this site is welcome to update its documents ahead of the January 2027 review. If we make a mistake, we will always accept polite requests for corrections.