Unfortunately, this lack of consideration to the perspectives of the poor and to international human rights standards is also reflected in the government’s evolving approach to the implementation of the Act. [...] This first Canadian CSO report, A Time to Act, on the government’s implementation of the ODA Accountability Act focuses on the potential of this purpose and the accountability provisions of the Act to change develop- ment practice and to establish policy coherence for Canadian ODA. [...] While the criteria, “contributes to poverty reduction” and “takes into account the prospective of the poor”, are not defined in the Act, the Canadian Council for International Co-operation has argued that “only an explicit human-rights approach (HRA) to the implementation of Canadian ODA programming will be consistent with the three tests called for by the Act”.5 The legal rationale, noted above, [...] They have specified several elements in a human rights approach that should orient the priorities and practices of donors: • Assessment and analysis to identify the human rights claims of rights-holders and the corresponding human rights obligations of duty-bearers, as well as the immediate, underlying and structural causes of the non-realization of rights; • Programs to assess the capacity of rig [...] The Report to Parliament, however, does not relate the outcomes of the dialogues to the implementation of the Act, and in particular to the need to inform the Minister’s opinions for section 4(1).15 The Steering Committee, according to its internal minutes, does recognize the need to better document consultations and suggests that CIDA investigate a number of changes in practices to “refresh some