Publications

NIHRC Submission to the Executive Office’s Consultation on the Framework for Race Relations

Date produced: June 2026

Below is a summary of the Northern Ireland Human Rights Commission's (NIHRC) recommendations and messages. You can also download the full document through the links provided.

Summary recommendations/messages

The Northern Ireland Human Rights Commission: 

2.7    recommends that the Executive Office references the core human rights instruments, including Windsor Framework Article 2, within the Draft Framework for Race Relations, ensuring that the obligations flowing from these human rights standards are embedded throughout the Framework to ensure practical compliance. The Ending Violence Against Women and Girls Strategic Framework 2024-2031 provides a good example of how this has been done.

2.13  recommends that the Executive Office strengthens the Draft Framework in line with the United Nations Office of the High Commissioner for Human Rights guidance on National Action Plans against Racial Discrimination, to ensure it is action‑oriented and capable of effective implementation. In particular, the Draft Framework should set out more concrete and measurable actions to be undertaken, with targeted goals, performance indicators, clear assigned responsibilities, defined timeframes and adequate budgetary provision, and arrangements for monitoring, evaluation, across all four outcomes.

2.16  recommends that the Executive Office ensures that the Draft Framework for Race Relations is accompanied by a full Human Rights Impact Assessment outlining all relevant human rights standards. This should include details of how Windsor Framework Article 2 obligations have been considered and how they will be monitored and implemented under the Framework. 

2.17  recommends that the Executive Office, monitors any proposed changes by the EU to the Racial Equality Directive, including relevant case law of the CJEU, in the development and implementation of the Framework for Race Relations, and that explicit reference is made within the Framework as to how any enhancements will be incorporated into NI equality law.

2.21  advises the Executive Office and the Department of Communities that, in accordance with the dynamic alignment obligation relating to Windsor Framework Articles 2 and 13, the definition of discrimination in relevant NI equality law should be amended to include “intersectional discrimination” aligned to the relevant provisions of the EU Pay Transparency Directive.

3.4    recommends that the Executive Office gives due regard to the findings of the independent review and its own identified responses and ensure that the shortcomings identified in the Racial Equality Strategy are not carried forward into the new Framework but instead addressed in a way that strengthens and enhances it.

4.5    recommends that, to ensure compliance with Windsor Framework Articles 2 and 13, any updates to NI Race Relations legislation must reflect any changes to the EU Racial Equality Directive which enhance rights, including those already introduced by the Standards for Equality Bodies Directive, and relevant CJEU jurisprudence.

4.6    welcomes the Executive Office’s proposals to enact updated Race Relations legislation and recommends this is supported by effective education and awareness raising programmes on anti-racism, equality and anti-discrimination aimed at public officials, civil society, the media, and the wider public.

4.7    recommends that the Executive Office implements systematic monitoring and impact assessment measures of new legislation, to ensure that it does not contribute to the perpetuation of racial discrimination.

4.12  recommends that the Executive Office strengthens the key interventions under Outcome 1 by setting out concrete and measurable actions or activities, including clear targets, intended beneficiaries, performance indicators, assigned responsibilities, and defined timeframes for delivery, to enable effective assessment of progress.

4.15  recommends that the Executive Office sets out the budget required for the implementation of the Framework’s Delivery Plan and takes the steps necessary to ensure that the Minority Ethnic Development Fund is released in a timely manner to avoid delays that could undermine delivery.

4.20  recommends that the Executive Office explicitly include disinformation as a key issue to be addressed under Outcome 1 and consider measures such as the provision of language classes and interpretation services to empower and assist racial and minority ethnic communities to report and challenge misinformation and disinformation.

4.21  recommends that the Executive Office considers the inclusion of initiatives aimed at promoting media literacy and encourage fact-checking of online sources, to build greater resilience to misinformation and disinformation.

4.22  recommends that the Executive Office considers translating the Framework into the indigenous, regional and minority languages spoken in NI, to enhance accessibility and engagement.

4.25  recommends that the Executive Office revisits the Racial Equality Subgroup’s terms of reference to ensure that it will implement all key actions and that it considers increasing funding and support to build capacity in the Subgroup.

5.2    recommends that the Executive Office rephrases the accompanying explanation of Outcome 2 to clearly articulate its objectives and to define the key terms of focus. The NIHRC advises that for guidance the Executive considers the definitions within the UN CERD.

5.5    recommends that the Executive Office provides more detailed information on how a victim centred approach will be delivered, including the provision of victim support services and the establishment of clear and accessible pathways from reporting to remedy.

5.14  recommends that the Executive Office revises Outcome 2 to provide greater clarity on how victims of racist incidents and hate crime will obtain redress and to set out the accountability and monitoring measure. The NIHRC advises that this should include clear mechanisms for the systematic collection, analysis, and publication of accurate disaggregated data and statistics on racist and xenophobic offences. This should include data on the number of incidents reported to the police, the number of cases investigated and prosecuted, the reasons for decisions not to prosecute, and the outcomes of prosecuted cases.

5.15 recommends that the Executive Office revises Outcome 2 to provide greater clarity on how victims of racist incidents, hate crime and paramilitary racist violence and intimidation will obtain redress and to set out the accountability and monitoring measure. 

          The NIHRC advises that this should include the following:

• Clear mechanisms to prevent and combat paramilitary racist violence and intimidation against ethnic minorities and migrants.

• Clear mechanisms for the systematic collection, analysis, and publication of accurate disaggregated data and statistics on racist and xenophobic offences, including incidents involving paramilitary groups.

• Data on the number of incidents reported to the police, the number of cases investigated and prosecuted, the reasons for decisions not to prosecute, and the outcomes of prosecuted cases.       

5.16 recommends that the Executive Office includes under Outcome 2 clear performance indicators, such as the percentage increase in reporting rates of race hate crime and racist incidents, the proportion of reported incidents of race hate crime and racist incidents leading to charges, and levels of victim satisfaction with police responses.

5.17  recommends that the Executive Office revises Outcome 2 to include concrete measures to analyse the nature and extent of racial discrimination within the criminal justice system, establish effective anti-discrimination monitoring services within the administration of justice.

5.18  recommends that the Executive Office strengthens the Framework by including training programmes aimed at eliminating racial or xenophobic prejudice among judges, other judicial personnel and jury members, as well as specialised training on victims’ needs for officials likely to come into contact with victims.

5.20  recommends that the Executive Office revises the fourth intervention under Outcome 2 to include clear practical steps on how to tackle misinformation and suggests including targeted engagements with the media, journalists and minority ethnic communities.

5.24  recommends that the Executive Office strengthens the first key intervention under Outcome 2 by specifying concrete activities to be undertaken in reviewing approaches to racially motivated and aggravated crime and access to justice for victims, clearly identifying the responsible departments, and engaging key stakeholders, including the Department of Justice, judges, prosecutors, law‑enforcement officials, and other relevant court and victim‑support services.

6.4    recommends that the Executive Office amends the Draft Framework for Race Relations to reflect its obligations relating to equality of service provision under the EU Racial Equality Directive and relevant CJEU case law.

6.7    recommends that the Executive Office introduces a dedicated intervention under Outcome 3 to improve access to interpretation and translation services for racial and minority ethnic communities, supported by clear funding commitments.

6.9    recommends that the Executive Office strengthens Outcome 3 by introducing corresponding interventions to address key issues identified by UN treaty body mechanisms, particularly in relation to education, employment, and access to health care services. These interventions should clearly specify the actions to be taken, the groups targeted, and the bodies responsible for delivery.

6.13  recommends that the Executive Office clarify how equality of access will be achieved across public services, with a particular focus on education, including campaigns at schools and identify the key actors to be involved and groups to be engaged including teachers. 

6.14  recommends that the Executive Office amends the Draft Framework to reflect its obligations relating to minimum standards for access to education under Windsor Framework Article 2, including requirements under the EU Racial Equality Directive.

6.21  recommends that the Executive Office strengthens Outcome 3 by including a corresponding intervention to improve access to employment, including targeted public-sector employment initiatives, and measures to expand access to vocational training and employment services for minority ethnic communities.

6.22  recommends that the Draft Framework include a commitment by the Executive Office to track CJEU case law in the area of employment discrimination on the grounds of race and ethnicity, and religion and belief, to ensure any enhancements are reflected in NI equality law. 

6.30  recommends that the Executive Office, guided by the recommendations of the UN Treaty Body mechanisms, strengthen Outcome 3 by including clear measures to support the implementation of programmes and initiatives aimed at increasing access to healthcare services for minority ethnic communities, including targeted actions involving healthcare professionals and hospital administration staff.

6.31  recommends that the Draft Framework be amended to reflect a commitment from the Executive Office and the Department of Health to identify and minimise procedural barriers to healthcare for migrant people, regardless of immigration status.

6.33  recommends that the Executive Office strengthens Outcome 3 by including activities targeted at actors within the housing sector to support the implementation of programmes and initiatives aimed at increasing access to housing in both the public and private sector.

6.34 recommends that the Executive Office strengthens Outcome 3 by including clear measures to prevent intimidation and violence by paramilitary groups against ethnic minorities and migrants to ensure equal access to adequate and culturally appropriate housing and to prevent de facto segregation. The NIHRC advises that this should include the collection, analysis and publication of data on such incidents, including the number of cases investigated and prosecuted, the reasons for decisions not to prosecute, and the outcomes of prosecuted cases.

6.39  recommends that the Executive Office strengthens the seventh intervention under Outcome 3 by clearly specifying actions to be undertaken by the Roma Thematic Group and Travellers Thematic Group, identifying the priority actions, bodies responsible for implementation, defined delivery timeframes, target groups to be engaged and associated budgetary requirements.

6.44  recommends that the Executive Office ensures that the data available is assessed with a view to revealing the existence and extent of racial discrimination, identifying discriminatory practices and patterns, and key priority areas for targeted action.

6.45  recommends that the Executive Office amends the Draft Framework to reflect the requirements relating to data collection set out in the EU Standards for Equality Bodies Directive.

7.6 recommends that the Executive Office considers replacing the term “community cohesion” with “intercultural dialogue” a term grounded in the Council of Europe Framework Convention for National Minorities.

7.7   recommends that the Executive Office utilises meaningful engagement with individuals who will be affected and their representatives beyond this public consultation to determine the key priority areas for implementation regarding trainings and workshops. 

7.8    recommends that the Executive Office clarifies the key interventions under Outcome 4, including specifying the key human rights topics, issues, and related trainings and workshops on race relations and ensuring that they are supported by clear responsibilities, timeframes, and monitoring arrangements.

8.4    recommends that the Executive Office strengthens the Delivery Plan by setting out institutional responsibilities for each outcome and intervention, so that roles and expectations are transparent to all government departments, stakeholders, and the wider public.

8.7    recommends that the Executive Office strengthens the Delivery Plan by identifying clear mechanisms for measuring progress against each outcome, including performance indicators, reporting arrangements, and procedures for identifying and addressing underperformance.

8.11  recommends that the Executive Office strengthens the governance arrangements by explicitly stating their frequency and providing for scheduling of Strategic Planning Group (SPG) meetings, including setting fixed time frames.

8.14 recommends that the Executive Office clarifies the frequency and timing of updates to the SPG Performance Report, including the introduction of regular reporting cycles. These reports should set out progress against agreed outcomes and performance indicators, identify challenges and underperformance, and inform corrective action.

Open the full submission in a new window here