Submitting Complaints Against Anti-Choice Ads

You can complain to Ad Standards about any anti-choice public message where the responsible entity can be identified (i.e., the anti-choice group). In most cases, this will be a paid ad such as on a bus.

Note: Please do not complain to Ad Standards about graphic images of aborted fetuses, as the agency has already issued four decisions against them, but the main anti-choice group responsible refuses to comply. Regulation of the graphic images then becomes a government responsibility, so please complain to your Mayor & Council. See our guide Take Action Against Aborted Fetus Images in Public.

  • Current Ads to Complain About
  • How to Submit a Complaint to Ad Standards
  • Guide to Advertising Code
  • Previous Complaints and Sample Letters

Current Ads to Complain About

February 2024: This ad appears in the Broadway-City Hall Skytrain station (Canada Line) at Cambie and Broadway in Vancouver.

The ad claims that “life begins at conception” in the context of depicting an infant. The claim has no scientific basis and is a disputed matter of opinion. It is therefore inaccurate under Section 1 of the Advertising Code. Further, the photo of the infant alongside the claim creates the misleading impression that a baby should be equated with an embryo or fetus. But fetuses are not legal persons in Canada.

The phrase “life begins at conception” is widely used by the anti-choice movement to condemn abortion. The juxtaposition of the phrase with the infant photo would be perceived by many as judgmental against abortion and those who have them, and as an affront to their human rights to bodily autonomy and privacy. Therefore, the ad appears to contravene Section 14 of the Advertising Code in several ways: It is an unacceptable depiction that demeans anyone who can get pregnant, especially those who’ve had or may be considering an abortion. The ad is discriminatory on the basis of sex because it targets ciswomen and gender-expansive people who can get pregnant. The ad offends standards of public decency because a large majority of Canadians support abortion rights.

How to Submit a Complaint to Ad Standards

What is “Ad Standards”?

If you see an anti-choice ad that you feel is inappropriate, offensive, inaccurate, etc., you can submit a complaint to the advertising watchdog Ad Standards. This private agency administers the Canadian Code of Advertising Standards (“the Code”).

Ad Standards has limited enforcement powers restricted mostly to asking the advertiser to rescind the ad and not use it again, and some anti-choice groups refuse to honour this request. Although the Code has no authority or legal standing on its own, it is widely endorsed by advertisers, advertising agencies, and media. When ads are deemed to contravene the Code, the decisions can be effectively used to convince the ad hosts (local governments, media outlets, etc.) to remove the ads and not accept similar ads again. Further, many cities and municipalities cite the Code in bylaws and advertising policies, which gives the Code further authority and strength.

Please note that Ad Standards only accepts up to 10 complaints on any particular ad. They only need ONE complaint to initiate a review, and large numbers of complaints slow down their process.

Therefore, please check with ARCC ( before sending in a complaint, particularly for ads that are not confined to one city or region in Canada.

Filling out the Complaint Form

You can submit your complaint online or by snail mail or fax. When submitting online, the website will take you through a series of questions. We provide guidance for most of the steps as follows:

“Your Information”

It’s probably better to submit your complaint as an “Individual”, not a “Group”, in case Ad Standards designates you as a “competitor” under their Advertising Dispute Procedure.

“What is the name of the advertiser?”

Enter the name of the anti-choice group, and not the newspaper, radio station, transit or billboard company, etc.

“What is the Product or Service advertised?”

Depending on the ad, you might say something like, “Anti-abortion rhetoric that tries to persuade people that abortion is murder.” Or: “A message that abortion should be illegal.” “

“Where did you see the advertisement?”

It’s okay if you can’t remember precisely where and when you saw it, just give your best estimate. The location could even be a link to a news story showing the ad.
“When did you see the advertisement?”

Specify the location and date.

“Describe the advertisement”

If you don’t have a photo or copy of the ad to send (see next field), describe the ad in detail here.

Alternatively, provide a link to a copy of the ad online. Sometimes a media story will show it or the anti-choice group responsible will have it on their website. Make certain that any linked copy you provide is the same ad you saw.

“Attach a copy of the advertisement, if available”

Upload a file with a picture of the advertisement, if you have one.

“Please describe your concern about the advertisement”

See our Guide to Advertising Code below to help you, if desired. For example, you may want to cite section(s) of the Advertising Code and explain why you believe the ad contravenes them.

However, it’s fine to just describe the negative effects the ad had upon you or your loved ones, or give your own reasons why you feel the ad is inappropriate. This could even make your complaint stronger, e.g. if you had a strong emotional reaction to the ad.

If Ad Standards thinks there might be a Code infringement, they will accept your complaint for formal review by the Advertising Standards Council.

“Advertiser Contact”

If accepted for review, Ad Standards will send your complaint to the advertiser. You can choose whether to give them permission to also disclose your name and contact info to the advertiser. To be safe from possible anti-choice harassment, it’s best to select “No”.

Guide to Advertising Code

If desired, you can do a bit of research on the Code to figure out what Code sections the ad might contravene, and the previous decisions Ad Standards has made against anti-choice ads. Again, this is not necessary, feel free to submit a complaint based on your own thoughts and opinions.

Here’s the Canadian Code of Advertising Standards, complete with explanation and definitions.

To see decisions against anti-choice ads, visit Ad Standards’ page that links to recent, annual, and archived complaint summaries. You’ll need to browse through them as there is no search feature.

Sections of the Code Pertinent to Anti-choice Ads

Section 1: Accuracy and Clarity

Anti-choice ads are considered advocacy ads. Just by their nature, most anti-choice ads will run afoul of Section 1 of the Code, Accuracy and Clarity, which is worded quite broadly to capture not only inaccuracies but also deceptive or misleading claims, omissions, and claims unsupported by evidence. This is especially important for anti-choice ads that may not on the surface be inaccurate, but which result in an overall misleading impression.

Ad Standards says: “In assessing the truthfulness and accuracy of a message … the concern is not with the intent of the sender or precise legality of the presentation. Rather the focus is on the message, claim or representation as received or perceived, i.e. the general impression conveyed by the advertisement.”

Previous examples of inaccuracies that Ad Standards found in anti-choice ads include:

  • Implying that abortion is available until the 9th month of pregnancy
  • Implying that full-term fetuses are routinely aborted
  • Claiming that Canadian law allows abortion up to 9 months
  • Implying that most abortions happen around 16 weeks or later, often by including pictures of later-term fetuses
  • Implying that most abortions occur later in pregnancy by showing images of later-term fetuses
  • Calling a fetus a “child” or a “person”
  • Making unsupported statements, e.g., “up to 25% of your friends, neighbours and relatives are likely missing” due to abortion
  • Using the word “committed” rather than “performed”, to imply that abortion is illegal
  • Equating legal abortion with extreme child abuse
  • Characterizing abortion as a procedure to be “performed at the patient’s request without a referral”
  • Implying that all fetuses at all stages of gestation will feel pain if the pregnancy is aborted
  • Claiming that “Canada has no abortion laws” when the 1988 R.v. Morgentaler decision that legalized abortion stands as law as decreed by the Supreme Court, and abortion is regulated in other ways (such as through the Canada Health Act)
  • Implying that fetuses at all stages of gestation will feel pain in an abortion
  • Describing a fetus as “her” (in an ad saying “What about her choice?”), which created an impression of personhood when the fetus is not yet a human being under law. Also, the suggestion that a fetus has the capacity of choice was deemed misleading.
  • Implying that a fetus could have “human” rights by showing an ultrasound picture of a fetus in connection with the word “human”, thereby blurring the distinction between pre- and post- birth and creating a misleading general impression.
  • Using language (“kill her”) that misleads and mischaracterizes the distinction in law between murder of a person and abortion of a fetus

Section 14: Unacceptable Depictions and Portrayals

Another very important part of the Code is section 14, Unacceptable Depictions and Portrayals. Anti-choice ads are often demeaning to women and trans people, and arguably even discriminatory because they may imply they are murderers or that their Charter rights should be removed.

Section 14 has several subsections that advertisements must not contravene. (Note: The following are incomplete summaries that may also miss nuance. Please consult the full text.)

Advertisements must not:

  • discriminate or condone discrimination (on usual grounds of gender, ethnicity, etc.)
  • exploit, condone, or incite violence or bullying
  • demean, denigrate, or disparage identifiable persons (or services etc.), or bring them into public contempt or ridicule
  • undermine human dignity, or display obvious indifference to conduct or attitudes that offend standards of public decency

Previous examples of Section 14 contraventions that Ad Standards found in anti-choice ads include:

  • Using the word “committed” to suggest that abortion is illegal, which demeans or denigrates women who have abortions and brings them into public contempt
  • Saying that “Abortion Kills Children”, which could seriously disturb children and therefore displays obvious indifference to conduct or attitudes that offend standards of public decency
  • Displaying or distributing graphic and disturbing images of aborted fetuses, which displays obvious indifference to conduct or attitudes that offend standards of public decency
  • Saying “This is a Child. Not a Choice. Why abortion when there are alternatives?”, which demeans and denigrates women who make the careful choice to have an abortion
  • Showing a long line of women who had abortions who all appear seriously troubled, saddened, disconsolate, and in a state of remorse and regret, which denigrates all women who had or may have an abortion
  • Equating abortion with extreme child abuse, which demeans and disparages women who have abortions and brings them into public contempt
  • Implying that women who decide to terminate their pregnancy intentionally inflict pain on their unborn fetus, which demeans and disparages women who had or may have an abortion
  • Implying that women in late stages of pregnancy routinely have abortions, which is demeaning, denigrating, and disparaging to women
  • Implying that a fetus has the capacity of choice, which in turn suggests that the fetus’s choice is taken away by a woman who chooses to have an abortion, thereby demeaning or disparaging women who had or may have an abortion
  • Blurring the distinction in law between the murder of a person and abortion of a fetus, which demeans or disparages women who have had or are contemplating an abortion

Other Code Sections that May Apply to Anti-choice Ads

Two other Code sections might be useful, depending on the ad:

  • Section 8: Professional or Scientific Claims Only one anti-choice ad, in 2010, has been found in contravention of this section. Ad Standards said the ad had made unwarranted extrapolations of abortion and birth data from Statistics Canada. In particular, it claimed that “up to 25% of your friends, neighbours and relatives are likely missing,” based on if aborted fetuses had been born to survive into adulthood, marry and have children themselves.
  • Section 11: Superstition and Fears Only one anti-choice ad, in 2014, has been found in contravention of this section. The ad said: “This is a Child. Not a Choice. Why abortion when there are alternatives?” Ad Standards said this statement played upon women’s fears in order to mislead them about abortion.

Previous Complaints and Sample Letters

Pembroke ON Billboard

This anti-choice billboard was seen in a rural area near Pembroke. (Photo is by an ARCC supporter and was posted with permission on our Facebook page.) It is not known if any complaint to Ad Standards was successful.

anti-choice billboard comparing baby to embryo

The ad appeared to contravene the Canadian Code of Advertising Standards, Section 1, Accuracy & Clarity, in two ways.

  1. It portrays a newborn baby clutching a soccer ball and equates this with a 7-week embryo. But this is highly misleading because there is a vast difference between the two in size and morphology. An embryo is not a child and does not have the characteristics or abilities portrayed in the ad.
  2. It claims a 7-week embryo is “already kicking.” In fact, pregnant people do not feel any fetal movement until 16 to 22 weeks gestation, and fetal movement itself does not begin until 12 weeks. (Even if this is interpreted to be 10 weeks after conception rather than 12 weeks after last menstrual period, that is still 3 weeks later than the billboard states.) 


Hamilton “Heartbeat” Billboard Ad – June 2019

A billboard pictured a sleeping infant with the caption “My heart started beating 3 weeks after conception. @HamiltonR2L”

The ad contravenes the Canadian Code of Advertising Standards, Section 1, Accuracy & Clarity, because there is no heart and not even a heartbeat at three weeks. There is only a fetal pole, which cannot be distinguished until 5.5 to 6.5 weeks gestation. (

A fetal pole “is the first direct imaging manifestation of the fetus and is seen as a thickening on the margin of the yolk sac during early pregnancy.” (

“What is interpreted as a heartbeat in these bills is actually electrically induced flickering of a portion of the fetal tissue that will become the heart as the embryo develops.” — Ted Anderson, president of the American College of Obstetricians and Gynecologists, speaking about the six-week abortion bans introduced in several U.S. states. (


Kelowna billboard implies abortions happen until birth – March 2019

March 2019: A billboard near the intersection of Highway 97 South and Grizzly Road in West Kelowna showed the image of a pregnant woman at full term or near full term, next to a picture of the same woman holding her baby after it is born. The caption read: ‘Our right to life does not depend on our location.’

The ad was clearly misleading and inaccurate, and in violation of the Advertising Code because it implies that women in Canada can have abortions right up to nine months of pregnancy, which is demonstrably false. Further, Ad Standards has previously ruled against several ads that made similar implications. (see the first four examples below under Section 1 – Accuracy and Clarity)

Ad Standards received numerous complaints about this ad and issued a decision on May 7, 2019, finding that the ad contravened both Section 1 and Section 14. The ad inaccurately conveyed the message that women in late stages of pregnancy routinely have abortions, and that this representation was demeaning, denigrating, and disparaging to women.

ARCC’s critique of ad:

Section 1, Accuracy & Clarity:

The ad is inaccurate and misleading because it implies that women in Canada can obtain and do obtain – perhaps routinely – abortions at full term or near full term. However, policy and practice limit abortion in Canada to 22 weeks (after last menstrual period) except in rare compelling circumstances, mostly in cases of severe or fatal fetal anomalies. The very small number of later abortions are proven by CIHI’s official statistics, compiled here by ARCC.

Section 14, Unacceptable Depictions and Portrayals

The ad is demeaning and disparaging to women because it implies they choose to abort their pregnancy when it is full term or near full term. It’s also demeaning because the woman’s head is cut off in the picture, reducing her to just her body as an instrument of childbearing. A woman’s body is not a “location.”

The anti-choice movement often claims that Canada’s lack of a law against abortion means that third-trimester abortions commonly occur for any reason at all, which is also the implication behind this ad. That claim is not just false, but malicious and hateful against both women and doctors.


Ottawa radio ad about fetal heartbeats – October 2018

In Ottawa, the radio station LiVE 88.5 FM ran an anti-abortion ad since early October. A supporter got in touch with them and they responded: “We air the commercial because it is our responsibility to act as custodians of free speech.”

But the reason that anti-choice ads should not be run is because they almost always feature false information, and/or demean women. Ad hosts need to vet dubious ads with Ad Standards before they run the ad.  We received no reports of complaints to Ad Standards, and there is no known decision by Ad Standards.

Here’s the text of the ad:

“Did you know that there are over 100 000 abortions every year in Canada? That’s almost 300 abortions a day. Did you know that an unborn child’s heart starts beating 21 days after conception? And that individualized brainwaves of unborn children have been recorded as early as 6 weeks and 2 days? Canada is aborting it’s future one life at a time. To find out more about abortion, visit this message was brought to you by Action Life Ottawa.”

ARCC’s critique of ad:

Section 1, Accuracy & Clarity

Obstretician/gynecologist Dr. Jen Gunter wrote about American “fetal heartbeat” bills in 2016 (

Dr. Gunter says: “The earliest cardiac activity is seen in a fetal pole and using any other term means that you are lock step with a campaign of misinformation and it’s wrong.”

In other words, it is NOT a heartbeat at 21 days because there is no heart yet.

A fetal pole “is the first direct imaging manifestation of the fetus and is seen as a thickening on the margin of the yolk sac during early pregnancy.” (

“It’s actually the structure that becomes that fetus, but at this point of development in no way resembles a human being.” (

The ad employs medical terminology yet uses the terms “unborn child” and “unborn children.” Embryos and fetuses are not children. There is no “child” when fetal pole cardiac activity is detected, and no “child” when abortion occurs.

Section 14, Unacceptable Depictions and Portrayals

The sentence: “Canada is aborting it’s future one life at a time” is demeaning to women and transgender people who need abortion. Safe, legal abortion protects THEIR future and that of their families. Women are full human beings with Charter rights, not incubators.

Further, the ad is misleading and demeaning because it erases the critical role of pregnant women. There would be no cardiac or brain activity without the person carrying the embryo/fetus, which is in no way viable outside the womb at 21 days and not till about 24 weeks.


Billboard campaign – “Canada has no abortion laws” – August 2018

Ad Standards issued a decision on Oct 17 against the anti-choice billboards and signs “Canada has no abortion laws”, on the basis that the ad contravenes Section 1 of the Advertising Code, “Accuracy and Clarity”. Ad Standards said:

“In the unanimous opinion of the members of Council, the claim in question disregarded the reality that by overturning the Criminal Code provisions outlawing abortions in Canada, the Supreme Court of Canada in 1988 imposed new law by which abortion became legal in Canada. For the advertiser to state, or at the least clearly imply, that no laws applicable to abortion exist today in Canada is a misstatement of the law in Canada. The law of the land was enunciated in the R. v. Morgentaler case by the Supreme Court of Canada, the highest legal authority in Canada. Coupled with regulations imposed by Canadian authorities on the conduct of abortions in Canada, the Supreme Court’s decision in R. v. Morgentaler makes it clear that, contrary to the advertising claim, binding Canadian law that permits abortion in Canada does, in fact, currently exist.” 

Background: The anti-choice group “We Need a Law” contracted with Pattison Outdoor Advertising to display these billboards in 30 cities/locations across Canada – despite the fact that Pattison has an Advertising Policy that says ads must not contravene the Canadian Code of Advertising Standards. Unfortunately, Pattison still approved and ran the ad, and company president Randy Otto insisted they won’t take down the ad unless/until Ad Standards issues a decision against the ad. In addition to the Pattison billboards, Lamar Advertising in London ON ran the ad on buses.

ARCC’s critique of the ad was quite different than that of Ad Standards:

On its face, the ad statement that “Canada has no abortion laws” is accurate. However, that is not enough. It’s about the implication the ad makes and what’s missing. Section 1 of the Advertising Code, “Accuracy and Clarity”, is broadly worded to disallow representations that may be perceived by the audience in a misleading way, i.e., the general impression conveyed by the advertisement is key. Ads must also not omit relevant information that results in a deceptive or misleading ad.

The perceived misleading messages the ad sends are that abortion is completely unregulated, there’s something wrong with abortion, and there should be laws restricting abortion. Further, the ad omits to say that abortion is in fact regulated by the Canada Health Act, the Canadian Medical Association, the provincial Colleges of Physicians & Surgeons, medical discretion, best practices, and clinical protocols. Just like any other healthcare. In fact, no healthcare treatment has criminal or civil laws governing it, as that is unnecessary, including for abortion.

Also, the ad may contravene Section 14 of the Advertising Code (Unacceptable Depictions and Portrayals) because abortion is a fundamental right for women, protected by Charter rights of bodily security, life, liberty, conscience, privacy, and equality. The advertiser “We Need a Law” advocates for laws restricting abortion, which means they advocate for removing women’s human rights. Under Section 14, this would be condoning discrimination, as well as demeaning or degrading to women. The same applies to transgender people who can get pregnant, as they are protected under anti-discrimination laws.


Graphic Images – July/August 2018

The anti-choice groups CCBR and “Show the Truth” were active in numerous cities over the summer of 2018 displaying their graphic imagery of alleged aborted fetuses, and/or delivering graphic flyers to households. The majority of activity was in the metro Toronto area, but there were reports of activities from Ottawa, Peterborough, Oshawa, Oakville, Pickering, Waterloo, Burlington, Winnipeg, Regina, Calgary, Vancouver, New Westminster, Burnaby, and other cities.

Ad Standards apparently did not rule on this particular instance because it had previously issued a decision against aborted fetus imagery in the form of graphic flyers delivered to households by the Canadian Centre for Bio-Ethical Reform (CCBR), as well as on the side of trucks driving through traffic. However, CCBR openly flouts Ad Standards decisions against its messaging.


Lethbridge “Fetal Pain” Ads – March 2018

Ads implying that full-term fetuses were being aborted in Canada and suffering pain from abortion were placed on bus benches in the City of Lethbridge Alberta in March 2018.  The ads were removed by the city in April 2018 after numerous complaints.

On May 30, Ad Standards upheld a complaint about the ad, saying it was misrepresentative, scientifically inaccurate, and demeaning and disparaging to women.

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