Short answer: if your thesis involves living human participants or human biological materials, TCPS 2 requires review and approval by your institution’s Research Ethics Board before you begin. Research relying exclusively on anonymous or lawfully public information may be exempt. Your REB — not you, and not your supervisor — makes that determination.
Almost every delay we hear about in Canadian graduate research has the same shape: a student designs a study over the summer, drafts a recruitment email, and only then discovers that the Research Ethics Board needed to see it first. The rules are not obscure. They sit in a single national policy document that anyone can read, and the parts that decide your case are about four paragraphs long.
What is TCPS 2, and does it apply to me?
The governing document is the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans, known as TCPS 2. The current edition is TCPS 2 (2022), published jointly by Canada’s three federal research agencies — CIHR, NSERC and SSHRC.
It applies to you through your institution rather than directly. Canadian universities that receive federal research funding agree to apply TCPS 2 across research conducted under their auspices, which includes graduate theses whether or not the individual project is funded. In practice this means the national policy sets the floor, and your university’s REB sets the local procedure on top of it. Both matter, and only one of them is the same everywhere.
What exactly requires ethics review?
Article 2.1 is the operative rule. It states that ethics review and approval by an REB is required before the research commences for research involving:
- living human participants;
- human biological materials, as well as human embryos, fetuses, fetal tissue, reproductive materials, and stem cells — including materials derived from deceased individuals.
Two words in that article do a great deal of work. “Before” means before recruitment, not before analysis: sending a single pilot survey to three classmates to “test the wording” is data collection. And “living human participants” is broader than interviews. It covers surveys, focus groups, observation, secondary analysis of identifiable data, and any study where a person’s responses are the object of inquiry.
Does course-based research count?
Yes, and this surprises people. TCPS 2 states plainly that the scope of the policy “includes course-based research activities, the primary purpose of which is pedagogical, because of the possible risks to those recruited to participate in such activities, and the fact that, from their perspective, such activities may appear indistinguishable from” research proper.
The reasoning is participant-centred rather than student-centred. A person answering your questionnaire cannot tell whether it is a real study or a methods exercise, and the risk to them is identical either way. Many institutions handle this through a delegated or departmental process rather than a full board review, but the activity is still inside the policy.
Does it matter that I will never publish?
No. This is the single most common misreading, and TCPS 2 addresses it directly: “choice of methodology and/or intent or ability to publish findings are not factors that determine whether an activity is research requiring ethics review.”
A master’s thesis that will sit in an institutional repository and be read by four people is subject to exactly the same test as a study destined for a journal. Publication is a dissemination decision. Ethics review is triggered by what you do to participants, not by where the results end up.
When is REB review not required?
There are genuine exemptions, and they are narrower than the versions that circulate in departmental corridors. Three articles carry them.
| Article | What it exempts | The condition students miss |
|---|---|---|
| 2.2 | Research relying exclusively on information that is publicly available through a mechanism set out by legislation or regulation and protected by law, or in the public domain where individuals have no reasonable expectation of privacy | “Exclusively.” Add one interview to a documentary study and the exemption is gone |
| 2.4 | Research relying exclusively on secondary use of anonymous information or anonymous biological materials | Only if linkage, recording or dissemination does not generate identifiable information. Anonymous is not the same as coded or anonymised |
| 2.5 | Quality assurance and quality improvement studies, program evaluation, performance reviews, and testing within normal educational requirements used exclusively for assessment, management or improvement | “Used exclusively for” those purposes. The moment the purpose becomes generating generalisable knowledge, it is research |
Article 2.2 gives worked examples of what counts as lawfully public: registries of deaths, court judgments, public archives, and publicly available statistics such as Statistics Canada files. That last category is why so much quantitative thesis work in Canada proceeds without a participant-facing ethics submission — though your institution may still require a determination form saying so.
Does using Statistics Canada data need approval?
Usually not under Article 2.2, because the files are publicly available through a mechanism set out in legislation. But “no REB review” is not the same as “no process.” Public Use Microdata Files are self-serve; confidential microdata held in a Research Data Centre requires an approved project, security screening and an oath before you touch anything. Those are access controls administered by Statistics Canada, and they run on their own timeline alongside whatever your REB decides.
If your thesis will use national statistical data, the practical sequence and the access tiers are set out in our guide to getting Statistics Canada microdata for your thesis, which explains which tier requires what.
What about quality assurance and program evaluation?
Article 2.5 excludes them from the definition of research, and the application note explains why: these are assessments of an organisation or its employees or students, within the organisation’s mandate, administered in the ordinary course of operations where participation is expected. Staff performance reviews, student course evaluations and internal reporting all sit here.
The trap is the hybrid project. An evaluation of a clinical programme designed to improve that programme is exempt. The same evaluation designed to produce findings you will generalise to other programmes in your discipline is research. Students in nursing, education, social work and public administration hit this boundary constantly, and it is the single most useful thing to ask your REB about before you write a word of your methods chapter.
Who actually decides?
The board does. Under Article 6.3, the institution grants the REB the mandate to review the ethical acceptability of research on its behalf, “including approving, rejecting, proposing modifications to, or terminating any proposed or ongoing research involving humans.” TCPS 2 is explicit that REBs need independence in their decision-making, and that as an entity drawing its authority from the institution, the REB remains accountable to the institution’s highest governing body.
What follows from that is practical. A supervisor’s opinion that your project is exempt is not a determination. If you are unsure, most Canadian REBs offer a short determination or screening request precisely so that the answer is on the record before you start. Getting a written “no review required” costs you a week. Discovering after the fact that you needed review can cost you the data, because a board cannot retroactively approve collection that has already happened.
What is CORE-2022 and do I have to complete it?
CORE-2022 is the free online tutorial on TCPS 2, hosted by the Panel on Research Ethics. It walks through the three core principles the policy is built on — Respect for Persons, Concern for Welfare, and Justice — and issues a certificate of completion.
Whether it is mandatory is an institutional decision, not a national one. Many Canadian graduate programs require the certificate from every student listed on an ethics application, and some require it from supervisors too. Check your own REB’s submission checklist rather than assuming; it is a short course, and it is often the item that holds up an otherwise complete file.
How should I sequence this?
- Write the methods section first, in enough detail that someone else could run the study. Determination questions cannot be answered about a vague plan.
- Check whether your institution requires a determination form even for exempt projects. Many do.
- Complete CORE-2022 if your program requires it, and add anyone else who will handle data.
- Submit with your instruments attached — consent script, recruitment text, questionnaire, interview guide. Missing attachments are the most common cause of a file being returned.
- Build the review cycle into your timeline as a round trip, not a single step. Boards routinely ask for modifications, and that is a normal outcome rather than a rejection.
Everything above is about clearing the gate. The work that follows — turning an approved protocol into a methods chapter that reads as though you meant it — is the part students underestimate. Draft your methods chapter in Tesify and keep the structure and citations consistent while the content stays entirely your own.
Frequently asked questions
Is TCPS 2 (2022) the current version?
Yes. TCPS 2 (2022) is the edition currently published by the Panel on Research Ethics on behalf of CIHR, NSERC and SSHRC. Earlier editions are superseded, so guidance written against TCPS 2 (2018) should be checked against the current text.
Does an undergraduate honours thesis need REB review?
If it involves human participants, yes — the policy does not exempt research by level of study. Institutions often route undergraduate projects through a delegated or departmental review rather than the full board, which is faster but is still review.
My supervisor says I do not need approval. Is that enough?
No. Article 6.3 places the determination with the REB. A supervisor’s view is useful advice, but only the board’s decision protects you if the question is raised later.
Can I get approval after collecting data?
No. Article 2.1 requires approval before the research commences. Data collected without required approval generally cannot be legitimised afterwards, which is why the exemption question is worth settling early.
Does secondary analysis of an existing dataset need review?
It depends on whether the data are anonymous. Article 2.4 exempts secondary use of anonymous information only where linkage, recording or dissemination does not generate identifiable information. Coded and anonymised datasets are treated differently from anonymous ones.
Does analysing social media posts count as publicly available information?
Not automatically. Article 2.2 turns on whether individuals have no reasonable expectation of privacy, which varies by platform, by whether the account is restricted, and by how you present quotations. This is a determination worth asking about rather than assuming.
Do I need approval to interview professionals about their work?
Yes. Interviewing professionals is still research involving living human participants. Their expertise does not remove the requirement, though it may affect how the board assesses risk and consent.
Is a pilot study exempt?
No. A pilot involving human participants is research involving human participants. Testing instruments on real people before approval is one of the more common ways students create an unfixable problem.
What if my study spans two institutions?
Each institution’s REB has a mandate over research conducted under its auspices, so multi-institution projects generally need a plan for review at each site. Many Canadian institutions have harmonised or reciprocal arrangements that reduce duplication — ask your research ethics office early.
Does my program evaluation count as research?
Under Article 2.5, evaluation used exclusively for assessment, management or improvement of the programme is not research. If the design and intent are to produce generalisable knowledge beyond that programme, it is.
How long does REB review take?
There is no national standard, because turnaround is set by each board’s meeting cycle and review stream. Delegated review of minimal-risk projects is typically much faster than full board review, which is scheduled around meeting dates. Ask your own office for its current cycle rather than relying on a figure from another university.
Where do I read the policy myself?
The full text of TCPS 2 (2022) is published free by the Panel on Research Ethics. Chapter 2 covers scope and approach — the articles quoted above — and Chapter 6 covers the governance and authority of REBs. Reading those two chapters takes an afternoon and settles most questions.
One last framing worth carrying into your thesis: ethics review is not a formality bolted onto research design. The questions a board asks — who is your participant, what could go wrong for them, what did you actually tell them — are the same questions an examiner will ask about your methods. A protocol that survives review tends to produce a defensible methods chapter, and it is much easier to write both at once than to reconstruct one from the other. For the difference between the thesis, dissertation and major research paper these requirements attach to, see our guide to Canadian graduate degree requirements.