Introduction

Truth-telling processes have gained significant momentum in Australia’s journey towards reconciliation with its First Nations peoples. The 2017 Uluru Statement from the Heart specifically called for a Makarrata Commission to oversee agreement-making and truth-telling about Australia’s history, which underscores the importance of formal mechanisms for addressing past injustices. A 2023 report by Deakin University found that community support for truth-telling was strong, with 87% of Aboriginal and Torres Strait Islander respondents and 83% of the general community in favour, reflecting a broad societal mandate for action.

Victoria has taken a leading role through the Yoorrook Justice Commission, which has been extended to June 2025 to gather evidence on systemic injustices faced by First Peoples. Meanwhile, the Australian Greens’ July 2024 Bill to establish a national Truth and Justice Commission signals growing political engagement. This Bill has been referred to the Joint Standing Committee on Aboriginal and Torres Strait Islander Affairs, with the committee expected to report in February 2025. However, the landscape for truth-telling initiatives remains uncertain, as some state-based processes face challenges following changes in government and the aftermath of the unsuccessful 2023 Voice referendum.

Against that backdrop, this paper examines international experiences with truth and reconciliation commissions (TRC), focusing on case studies from South Africa, Canada and Norway. International experience demonstrates the potential of TRCs to foster public dialogue, validate lived experiences and recommend structural changes. For parliamentarians and the general public, an examination of these experiences may foster a deeper understanding of how truth-telling mechanisms could contribute to national reconciliation, policy reform and historical accountability in Australia.

Among the case studies, South Africa’s TRC demonstrates the power of public truth-telling and reconciliation processes, combining victim testimonies with institutional reform recommendations. Its approach highlights both the potential and limitations of using restorative justice to address widespread human rights violations.

Canada’s TRC is particularly relevant to Australia, as both nations share a history of forced assimilation policies targeting indigenous peoples. The Canadian TRC’s efforts to document systemic injustices and advance reconciliation through policy recommendations have already influenced Australian discussions on truth-telling. Understanding its successes and challenges can help shape approaches that are culturally appropriate and politically viable in Australia’s context.

Norway’s TRC offers valuable insights into addressing historical and ongoing impacts of assimilation policies within a settler democracy. Its focus on indigenous and minority rights provides a comparative model for how truth-telling mechanisms can function in societies that have not experienced large-scale conflict but still grapple with the legacies of state-led assimilation. The combination of academic rigor and parliamentary mandate makes Norway’s TRC a structured and politically viable model for truth-telling mechanisms that other countries can examine and adopt.

For ease of reference, Table 1 summarises key aspects of these TRCs.

Table 1            Comparison table of TRCs

Source: Parliamentary Library

Note that the terms ‘victim’ and ‘survivor’ carry nuanced implications in truth and reconciliation contexts. The term ‘victim’ is typically used in legal and criminal justice settings, and when referring to someone who has recently experienced trauma or violence. It serves a specific legal purpose and acknowledges the harm inflicted. In contrast, ‘survivor’ often indicates someone who has progressed through a recovery process and emphasises their resilience and agency, and thus is often used in a psychosocial context. However, this is not a simple linear progression, as it factors in personal preference and social context. Some individuals may identify with both terms at different times, or switch between them depending on their healing journey. For inclusivity, this paper uses these terms interchangeably and the combined term ‘victim/survivor’.

The paper begins by exploring the concepts of transitional justice and restorative justice, which provide the theoretical foundation for TRCs. It then analyses each case study, examining the model and process of the TRC, outcomes for victims and survivors, strengths and weaknesses and overall effectiveness. Through this comparative analysis, the paper aims to identify key lessons and challenges in implementing TRCs as mechanisms for addressing historical injustices and promoting reconciliation.

Transitional justice: addressing the needs of post-conflict societies

According to the Office of the United Nations High Commissioner for Human Rights (OHCHR), ‘transitional justice’ refers to a framework of judicial and non-judicial measures implemented by societies to redress legacies of massive human rights abuses. The primary goal of transitional justice is to ensure accountability, serve justice and achieve reconciliation after periods of conflict or authoritarian rule. It aims to provide recognition and reparation to victims, promote the rule of law and build sustainable peace (see Figure 1).

Figure 1           Goals of transitional justice

Source: The US Federal Judicial Center

Clara Sandoval Villalba (University of Sussex) notes that transitional justice has 4 core processes, though there is disagreement about their components and interrelations. These include a justice process to prosecute perpetrators of mass atrocities, a reparation process to redress victims of mass atrocities, a truth process to fully investigate atrocities and an institutional reform process to prevent the recurrence of such atrocities. Besides these core processes, there are some more recent processes, such as national consultations recommended by OHCHR and disarmament, demobilisation and reintegration employed by United Nations (UN) Peacekeeping.

Besides truth commissions which are the focus of this paper, those processes involve a host of mechanisms, including:

• Criminal prosecutions: These are judicial processes aimed at holding individuals accountable for human rights violations. They can be conducted at national or international levels and are essential for establishing legal responsibility and deterring future crimes. An example is the International Criminal Tribunal for the Former Yugoslavia, a UN court of law established to address war crimes committed in the Balkans in the 1990s.
• Reparations programs: These programs aim to compensate victims for the harms they have suffered. Reparations can take various forms, including financial compensation, healthcare, education and symbolic measures, such as apologies and memorials. Reparations are crucial for acknowledging victims’ suffering and providing material support for their recovery. In Chile, following the recommendations of its TRC, an Educational and Cultural Promotion Program was implemented to promote human rights awareness and prevent recurrence.
• Institutional reforms: These reforms aim to transform institutions that were complicit in human rights abuses, such as the judiciary, police and military. Institutional reforms may include vetting and dismissing abusive officials, establishing new laws and policies and promoting human rights education. The goal is to prevent future abuses and build trust in public institutions. A report by Sarah Detzner (US Department of State) notes that security sector reforms took place at different scales in multiple post-conflict countries such as Burundi, Liberia, Madagascar and Peru.
• Amnesties: These controversial instruments can play a nuanced role within the framework of transitional justice. Reportedly the most employed device in transitional justice, they involve granting immunity from prosecution to individuals who have committed human rights violations, often as part of broader peace agreements or truth-telling initiatives. The rationale behind amnesties is manifold, ranging from encouraging perpetrators to disclose information about past atrocities, to allocating court resources to the most serious violations and exercising leniency for purely political crimes. For example, following its civil war, El Salvador enacted an amnesty law as part of the 1992 Chapultepec Peace Accords.

Historically, UN mediators have sometimes supported broad amnesties as a means to end conflicts, recognising their potential to facilitate peace negotiations by encouraging perpetrators to participate in truth-telling and reconciliation efforts. However, the UN has consistently maintained that amnesties should not apply to gross violations of human rights and serious violations of humanitarian law, such as genocide, war crimes and crimes against humanity.

The UN’s guiding principles on its transitional justice processes and mechanisms include:

Support and actively encourage compliance with international norms and standards when designing and implementing transitional justice processes and mechanisms

Take account of the political context when designing and implementing transitional justice processes and mechanisms

Base assistance for transitional justice on the unique country context and strengthen national capacity to carry out community-wide transitional justice processes

Strive to ensure women’s rights

Support a child-sensitive approach

Ensure the centrality of victims in the design and implementation of transitional justice processes and mechanisms

Coordinate transitional justice programmes with the broader rule of law initiatives

Encourage a comprehensive approach integrating an appropriate combination of transitional justice processes and mechanisms

Strive to ensure transitional justice processes and mechanisms take account of the root causes of conflict and repressive rule and address violations of all rights

Engage in effective coordination and partnerships (p. 2).

Transitional justice and restorative justice

According to the United Nations Office on Drugs and Crime (UNODC), restorative justice is a mechanism that focuses on repairing the harm caused by criminal behaviour through inclusive processes involving victims, offenders and the community. It prioritises healing and reconciliation over retribution, seeking to restore relationships and address the needs of all parties involved. While transitional justice encompasses broader societal and structural changes, restorative justice is a complementary approach and mechanism, operating at the individual and community levels, which provides a framework for resolving conflicts and fostering understanding.

Truth and reconciliation commissions

Also called a ‘truth commission’ or a ‘truth and justice commission’, a TRC is an official, non-judicial body established to uncover and document past human rights violations and injustices, often committed during periods of internal conflict, civil war or authoritarian rule. Although there are varied understandings of such commissions, Priscilla Hayner, co-founder of the International Center for Transitional Justice (ICTJ), provides a widely cited one in her book, Unspeakable truths, defining a truth commission as:

(1) focused on the past; (2) set up to investigate a pattern of abuses over a period of time, rather than a specific event; (3) a temporary body, with the intention to conclude with a public report; and (4) officially authorized or empowered by the state (p. 11).      

TRCs are a key mechanism supporting transitional justice. They are primarily built on the principles of restorative justice, operationalising restorative justice by providing platforms for truth-telling and reconciliation. They allow victims to share their experiences and perpetrators to acknowledge their actions, fostering a collective understanding of past atrocities. This process is intended to validate victims’ experiences, promote healing and facilitate societal reconciliation. The South African TRC, for example, is often cited as a model for how restorative justice can be applied in a national context, emphasising truth-telling and reconciliation over punitive measures.

While TRCs are rooted in restorative justice, they often incorporate elements of other justice types, such as distributive and procedural justice. For instance, TRCs may recommend reparations (distributive justice) to address socio-economic inequalities resulting from past abuses. They also emphasise fair and transparent processes (procedural justice) to ensure legitimacy and trust in their findings.

As Kerstin Reibold (Arctic University of Norway) notes, more and more non-transitional societies, such as Canada and Norway, have established TRCs to promote reconciliation with marginalised minorities that have experienced state-led or state-sanctioned violence.

Early examples of TRCs

The United States Institute of Peace provides an extensive list of TRCs, including their structures, mandates, findings and recommendations. The following are some early examples.

• Uganda’s Commission of Inquiry into the Disappearances of People (1974): Established during Idi Amin’s regime, this commission investigated the disappearances of Ugandans. Despite its mandate, it faced political interference and intimidation and its final report was never published, highlighting the challenges of truth-seeking without political support.
• Bolivia’s National Commission of Inquiry into Disappearances (1982): This was the first TRC in Latin America, set up to investigate forced disappearances during military dictatorships from 1964 to 1982. The commission documented 155 cases but faced obstacles such as limited resources and political resistance. It disbanded without issuing a final report.
• Argentina’s National Commission on the Disappearance of Persons (CONADEP) (1983): Created after the military dictatorship from 1976 to 1983, CONADEP investigated disappearances and documented abuses during the ‘Dirty War’. Its report, Nunca Más (‘Never again’), detailed around 9,000 cases, raising awareness and laying the groundwork for judicial proceedings against former military officials.
• Chile’s National Commission for Truth and Reconciliation (Rettig Commission) (1990): Following Augusto Pinochet’s dictatorship, this commission investigated human rights violations from 1973 to 1990. The 1991 report documented over 3,000 deaths and disappearances, recommending reparations and reforms, and playing a crucial role in promoting national dialogue about Chile’s past.

South Africa’s TRC

The South African Truth and Reconciliation Commission (TRC) was a landmark initiative established to address the atrocities committed during the apartheid era. It was set up by the Mandela Cabinet, also known as the Government of National Unity, in 1995.

For context, apartheid was a system of institutionalised racial segregation and discrimination that dominated South Africa from 1948 to 1994. Implemented by the National Party government, this regime was characterised by a series of laws and policies that systematically oppressed non-white South Africans, particularly those classified as Black, Coloured or Indian.

This regime systematically oppressed non-white South Africans through laws enforcing racial classification and spatial segregation, such as the Population Registration Act and the Group Areas Act. These laws, among others, formed the legal framework for what became known as ‘grand apartheid’, which dictated physical and political separation.

Millions of non-white South Africans were forcibly relocated to underdeveloped ‘homelands’ or townships, stripping them of citizenship and political rights. Apartheid policies extended to all aspects of life, with ‘petty’ apartheid laws segregating public facilities and criminalising interracial relationships. Despite efforts to maintain white supremacy, resistance grew, led by groups like the African National Congress (ANC). South Africa also faced international isolation through sanctions.

The transition to democracy began in the early 1990s with the unbanning of liberation movements and Nelson Mandela’s release from prison, culminating in the 1994 multi-racial elections that brought the ANC to power. As part of efforts to address apartheid’s legacy and foster unity, the TRC was established to investigate human rights abuses from 1960 to 1994.

Model and process

The TRC was established under the Promotion of National Unity and Reconciliation Act No. 34 of 1995. It was a court-like body that adopted a restorative justice approach, differing from retributive justice models like the Nuremberg trials against Nazi Germany officials.

Archbishop Desmond Tutu chaired the commission, which comprised 17 commissioners supported by approximately 300 staff members. It operated through 3 committees: the Human Rights Violations (HRV) Committee, the Amnesty Committee (AC) and the Reparations and Rehabilitation Committee. The TRC’s mandate included investigating gross human rights violations, granting amnesty to perpetrators who fully disclosed their crimes and recommending reparations for victims.

The HRV Committee was tasked with investigating and documenting abuses and providing a platform for victims to testify about their experiences. The TRC took testimony from approximately 21,000 victims and witnesses, with around 2,000 of these individuals appearing at public hearings.

The AC processed more than 7,000 applications, granting amnesty in 849 cases. This was contingent upon full disclosure of politically motivated crimes, allowing perpetrators to confess their actions in exchange for immunity from prosecution. The Reparations and Rehabilitation Committee focused on restoring victims’ dignity and formulating proposals for their rehabilitation, which included recommending financial compensation, creating memorials and providing educational support to victims and their families.

Outcomes for victims/survivors

The South African TRC had several outcomes for victims/survivors:

• Recognition and validation: The TRC provided a platform for victims to share their stories and receive recognition and validation, which was crucial for their psychological healing.
• Therapeutic impact: The act of giving testimony was reported to have had a therapeutic effect on some survivors, aiding in psychological healing and fostering forgiveness. However, a study by Dan Stein (University of Cape Town) found that the process also led to distress and anger among some participants, particularly those who had a negative view of the TRC or had a TRC-related experience to share.

• Reparations: The TRC made comprehensive recommendations for reparations, which included financial compensation, symbolic reparations and community rehabilitation efforts. This included a President’s Fund that provided financial assistance to victims who qualified for reparations. According to Christopher J Colvin (University of Virginia), this reparations policy was one of the most ambitious globally, although its implementation faced delays and challenges.
• Public perception and engagement: The TRC successfully engaged a significant portion of the South African population, with more than 10% attending hearings and 40% exposed to the process through the media.
• Institutional reforms: The TRC’s recommendations included proposals for institutional reforms to prevent future human rights abuses, promoting good governance and accountability.

Strengths and weaknesses

One of the TRC’s significant strengths was its emphasis on public participation and transparency. The public hearings allowed both victims and perpetrators to share their experiences, fostering a national dialogue about the past. This openness helped to create a comprehensive historical record and promoted a culture of human rights.

The TRC’s victim-centred approach provided a platform for victims to receive recognition and validation, which was crucial for their psychological healing. Antjie Krog, in Country of my skull, discusses how the TRC’s focus on victims’ stories helped restore dignity to those who suffered under apartheid.

The TRC’s restorative justice model, which included the possibility of granting amnesty in exchange for full disclosure, was designed to uncover the truth and foster reconciliation. Antje Du Bois-Pedain (University of Cambridge) considers this approach a pragmatic solution to the potential for widespread prosecutions, which could have destabilised the fragile transition to democracy.

Despite its achievements, the TRC faced challenges and criticisms. One major weakness was the limited accountability for perpetrators. The amnesty provision, while intended to encourage full disclosure, meant that many perpetrators escaped prosecution, leading to perceptions of impunity. According to Sam Garkawe (Southern Cross University), from a victim’s perspective, there are 4 distinct groups of criticisms about the amnesty process:

First, the amnesty process removed from victims a number of rights to which they should have been entitled. The second group of criticisms concerned the structure of the AC’s processes and the conditions and criteria for amnesty. The third group of criticisms centred around the lack of resources available to the AC to help and support victims. The final group of criticisms revolved around the contention that AC processes limited its ability to discover the ‘truth’ of what happened to victims and survivors.

High-ranking officials and key political players often did not participate in the process, which undermined the commission’s efforts to hold those most responsible accountable.

Furthermore, Nahla Valji (Centre for the Study of Violence and Reconciliation) points out that the TRC’s mandate was criticised for its focus on individual acts of violence, which left broader political and economic structures of apartheid unaddressed. This limited focus meant that the institutional violence and systemic injustices of apartheid were not fully examined.

The implementation of the TRC’s recommendations, particularly regarding reparations, was also problematic. Many victims felt that the reparations were insufficient and delayed, leading to feelings of betrayal and marginalisation. The TRC’s failure to provide adequate reparations and compensation left victims feeling marginalised and impotent, with their emotional and material welfare not fully addressed. The post-Mandela government was slow to act on the TRC’s recommendations and there were few prosecutions of individuals who did not receive amnesty.

Effectiveness

The effectiveness of the TRC in achieving its goals of truth, reconciliation and national healing is a subject of ongoing debate. On the one hand, the TRC was successful in creating a platform for dialogue and acknowledgement of past atrocities, which are essential steps towards reconciliation. The public hearings and the final report provided a detailed account of the human rights violations, contributing to a collective memory and understanding of the past. In many ways, the South African TRC set the standard for other TRCs.

On the other hand, the TRC’s impact on achieving sustainable peace and reconciliation has been questioned. Some argue that while the TRC helped to uncover the truth, it did not necessarily lead to reconciliation. The persistence of racial and economic disparities in South Africa suggests that the TRC’s efforts were insufficient in addressing the deeper, systemic issues that continue to affect the country. Furthermore, the lack of accountability for many perpetrators and the inadequate reparations for victims have left many feeling that justice was not fully served.

Canada’s TRC

The Canadian TRC was established as part of the Indian Residential Schools Settlement Agreement (IRSSA) in 2006, which was a response to numerous lawsuits filed by indigenous groups against the Canadian Government and churches for the abuses suffered in residential schools. These schools, which operated from the late 1800s until 1996, aimed to assimilate indigenous children by removing them from their families and cultures. The IRSSA was one of the largest class-action settlements in Canadian history, designed to compensate survivors and address the legacy of the residential school system.

Model and process

The Canadian TRC was a non-judicial body with a mandate to document the history and legacy of the country’s residential schools, to promote public awareness and facilitate a process of reconciliation between indigenous and non-indigenous Canadians. It was structured to operate over a 5-year period with a budget of C$60 million, later extended to 6 years with a budget of C$72 million.

One of the most distinctive features of the Canadian TRC is its origin in a legal settlement, the IRSSA. The TRC’s focus on historical colonial harms, specifically related to the Indian residential school system, sets it apart from other TRCs that address a broader range of human rights violations during periods of conflict or dictatorship.

Overseen by 3 commissioners, the Canadian TRC managed to organising 7 national events, collecting testimonies from survivors and establishing a research centre to preserve the collected materials. In addition to creating a comprehensive historical record, the commission’s aim was to recommend systemic changes to address the harms caused by the residential schools.

The TRC engaged in a multi-faceted process that involved extensive public and community engagement. Over the course of 6 years, the commission travelled across Canada, holding national and community events to hear testimonies from more than 6,500 survivors. These events provided a platform for survivors to share their experiences in a culturally appropriate and safe setting. The TRC also collected over 5 million documents from government and church archives.

The final report, released in 2015, included 94 Calls to Action. It emphasised the need for systemic changes in areas such as education, health and justice to improve the lives of indigenous peoples.

Outcomes for victims/survivors

• Acknowledgement and documentation: The TRC provided a platform for survivors to share their experiences, documenting the truth about the residential schools’ impact on indigenous peoples. This process was crucial in acknowledging the trauma and suffering endured by survivors and their families.
• Public awareness and education: Educating the Canadian public about the history and legacy of residential schools aimed to foster a broader understanding of the systemic injustices faced by indigenous communities, which is essential for reconciliation.
• Compensation and support: As part of the IRSSA, the TRC facilitated mechanisms for compensation through an independent assessment process and a common experience payment for claims of serious abuse. More than 30,000 survivors received financial compensation. The TRC also supported a Commemoration Initiative that honours and pays tribute to former residential school students.
• Calls to action: The TRC’s final report outlined steps for addressing the legacy of residential schools and promoting reconciliation. These recommendations aim to improve the relationship between indigenous and non-indigenous Canadians and address various socio-economic disparities.
• Government commitment: The Canadian Government, under Prime Minister Justin Trudeau, pledged to implement all recommendations, including adopting the UN Declaration on the Rights of Indigenous Peoples and launching a national inquiry into missing and murdered indigenous women and girls.
• Establishment of the National Centre for Truth and Reconciliation (NCTR): Created in 2007 as part of the IRSSA, the NCTR is tasked with preserving the history and stories collected by the TRC, to serve as a permanent resource for education and commemoration.

Strengths and weaknesses

One of the TRC’s primary strengths was its comprehensive documentation and public acknowledgement of the abuses suffered by indigenous peoples in residential schools. The commission’s final report provided a detailed historical record and personal testimonies from survivors, contributing to a greater public understanding of the atrocities committed. This transparency and inclusivity in gathering testimonies was crucial for validating the experiences of survivors and fostering a collective memory.

The TRC’s 94 Calls to Action covered various aspects of society and were another significant strength. They provided a clear roadmap for addressing the legacy of residential schools and advancing reconciliation, and promoted a holistic approach to reconciliation. According to Kirsten Anker (McGill University), the commission’s restorative justice principles align with traditional indigenous justice practices, thus having the potential to foster healing and reconciliation.

The Canadian TRC’s final report concluded that the residential school system amounted to cultural genocide, a term that acknowledges the systematic destruction of indigenous cultures, languages and identities. This recognition was significant in framing the historical injustices within the broader context of colonialism and its long-term impacts on indigenous peoples. In 2019, Bonny Ibhawoh (McMaster University) noted that Canada’s experience inspired Australia and New Zealand to explore similar processes, with discussions leaning towards ‘a Canadian-style TRC model’.

Despite its strengths, the TRC faced several notable weaknesses. One major criticism was the TRC’s lack of binding power to enforce its recommendations. While the 94 Calls to Action provided a comprehensive framework for reconciliation, the implementation of these recommendations has been inconsistent and slow, leading to frustration among indigenous communities. The Yellowhead Institute’s 2023 accountability update on the TRC notes that only 13 out of the 94 Calls to Action have been fully implemented, and estimates that, at this pace, it would take another 58 years for all the calls to be completed.

Another significant weakness was the TRC’s limited focus on systemic issues beyond the residential schools. In a widely cited research paper, Kim Stanton (Stanton Legal) argues that the commission’s mandate was too narrow, focusing primarily on individual experiences rather than addressing the broader systemic issues of colonialism and ongoing inequalities faced by indigenous peoples.

Some indigenous scholars and activists have also criticised the TRC for its perceived lack of genuine engagement with indigenous knowledge systems and cultural practices. Rosemary Nagy (Nipissing University) suggests that while the TRC aimed to incorporate indigenous perspectives, the process was often constrained by Western legalistic approaches.

Effectiveness of the model

Unlike some other TRCs, the Canadian TRC did not have judicial powers, such as the ability to subpoena witnesses or offer amnesty in exchange for truthful testimony. This limitation has been a point of criticism as it meant that the TRC could not compel testimony from perpetrators or hold individuals legally accountable for their actions. Instead, the TRC focused on documenting the truth and making recommendations for systemic change and reconciliation.

The TRC’s impact on achieving long-term reconciliation and justice has been mixed. While the commission succeeded in creating a platform for survivors to share their stories and in making comprehensive recommendations, the actual implementation of these recommendations has been uneven. The persistence of socio-economic disparities and systemic discrimination against indigenous peoples suggests that the TRC’s efforts have not yet led to substantial and long-term structural changes.

Anne-Marie Reynaud (Free University of Berlin) examines the tension between survivors’ expressions of anger during some TRC sessions and the TRC’s reconciliation goals. She found that while the TRC aimed to facilitate both personal healing and societal reconciliation, its implicit ‘feeling rules’ sometimes conflicted with survivors’ need to express raw emotions, which were crucial to some survivors’ individual healing processes. This warrants further discussion on how to address the complex interplay between personal healing journeys and broader reconciliation efforts.

Norway’s TRC

The Norwegian Parliament established a Truth and Reconciliation Commission in 2018 with a broad mandate to investigate the policies of ‘Norwegianisation’ and the injustices faced by the Sámi, Kven and Forest Finns. The commission’s aimed to explore the historical and ongoing impacts of these policies, which were designed to assimilate these minority groups into Norwegian society. Dagfinn Høybråten chaired the commission, which included 11 other specialists, mostly senior academics. Its work was intended to lay the groundwork for recognising the experiences of these communities and to propose measures for further reconciliation.

Model and process

The commission was tasked with proposing measures to contribute to reconciliation, focusing on cultural, social and economic aspects. Noting the commission’s composition and the location of the secretariat at the Arctic University of Norway, this TRC had a strong academic foundation.

The Canadian TRC served as a source of inspiration for the Norwegian TRC, particularly in its early stages. However, while the Canadian TRC recommended reparations and systemic changes as part of its mandate, the Norwegian TRC’s mandate did not include compensation and was more focused on historical mapping and analysing the repercussions of past policies.

In terms of process, Norway’s TRC engaged in extensive public consultation and research, collecting testimonies from over 760 individuals and conducting archival research to document the historical and contemporary impacts of ‘Norwegianisation’. This consultative process, described as a ‘Nordic method’, also distinguished it from the Canadian model.

Key outcomes

• Recognition of historical injustices: The TRC’s final report, presented to the Norwegian Parliament in June 2023, highlighted the historical and ongoing impacts of assimilation policies on indigenous and minority groups, including the Sámi, Kven and Forest Finns. The report emphasised the need for a unified knowledge platform to understand these groups’ histories and experiences. Research also pointed to higher reported mental health issues among Sámi individuals compared to the general population, reflecting the long-term trauma of assimilation policies.
• Public awareness and engagement: The TRC’s final report was presented at a public ceremony and read aloud over 37 hours to raise awareness about the historical injustices faced by these communities. The report indicated a significant knowledge gap among the general population regarding the history and current conditions of indigenous and minority groups in Norway. The TRC also identified a crisis of trust between the state and minority communities. This was attributed to the failure to fully implement minority rights and a general lack of awareness about these communities’ histories and rights.
• Recommendations for reconciliation: The TRC proposed several measures to foster reconciliation, including improving access to minority language education, protecting traditional livelihoods and enhancing awareness and understanding of minority histories and cultures among the majority population. However, there are concerns about the political will to implement these recommendations effectively.

Strengths and weaknesses

One of its key strengths was its focus on public engagement and transparency. The commission used open meetings and personal narratives as primary tools to engage with the public and gather testimonies, which helped to uncover both                individual experiences and structural causes of injustices. This approach facilitated a comprehensive understanding of the historical injustices faced by these communities and laid the groundwork for reconciliation efforts.

Despite its strengths, the Norwegian TRC faced several challenges. A significant weakness was the lack of widespread national awareness and engagement with the TRC process. The commission’s work rarely made national headlines, with only 37% of survey respondents knowing about the commission as at May 2022. The resulting uncertainty over how much the Norwegian population knew about the TRC’s findings may undermine the TRC’s efforts to foster reconciliation.

Additionally, the TRC’s recommendations faced challenges in implementation. The commission highlighted the need for systemic changes to support minority rights, but securing access to language education and traditional livelihoods remains politically challenging. The report emphasised the importance of adjusting the majority population’s self-image to accommodate minority cultures, but these efforts require long-term commitment and political will.

Effectiveness of the model

The effectiveness of the Norwegian TRC is still being evaluated, as the reconciliation process is ongoing. The long-term impact of the report’s recommendations will depend on their implementation and the Norwegian Government’s commitment to addressing the systemic issues identified by the TRC. Even the TRC’s recommendations suggest longer-term evaluations of the reconciliation process in 3, 10 and 25 years.

The Norwegian TRC is the first of the 3 Scandinavian TRCs documenting the long history of assimilation and discrimination in this region. Established by the parliament, the Norwegian TRC is considered to enjoy higher legitimacy than its counterparts in Finland and Sweden, which were created by their respective governments.

While the TRC process itself did not directly address financial compensation, Norway has established various redress mechanisms for historical injustices, including:

• a compensation fund for Sámi People created in 2000 (predating the TRC) to support cultural and educational projects for the Sámi community
• national and municipal redress schemes, some of which started in 2006, to provide collective redress and individual payments for those affected by historical policies, including institutional abuse and discrimination against minority groups.

Conclusion

Australia’s pursuit of an effective truth and reconciliation process can be informed by international experiences, which have demonstrated both the potential and limitations of commonly used mechanisms in addressing historical injustices. Case studies from South Africa, Canada, Norway illustrate varied approaches to truth-telling, reconciliation, reparations and institutional reform. While TRCs can foster national dialogue, validate victim experiences and recommend policy changes, a common denominator is that their effectiveness is often constrained by political will, implementation challenges and the complexity of systemic injustices.

For Australia, integrating lessons from these models – particularly in ensuring sustained political commitment, meaningful reparations and public engagement – will be critical in shaping an effective truth-telling process for First Nations peoples.