IRCC claims only 1% of citizenship by descent applicants impacted, in first official statement on certificate surrenders

Immigration, Refugees and Citizenship Canada (IRCC) has released its first detailed statement on the review of citizenship certificates issued under Bill C-3, saying it initially flagged just 100 certificates with potential eligibility issues.

Of these 100, the citizenship department has automatically reinstated 33 upon confirming that they met legal requirements. The remaining 67 cases are still outstanding.

Get a Free Consultation on Applying for Proof of Canadian Citizenship

The remaining 67 cases (which IRCC describes as roughly one per cent of all certificates issued under C-3 so far) are still being worked through. In "a matter of days," these applicants will either have their citizenship certificates reinstated or be contacted by the department directly and asked for more information if needed.

Per the department’s statement, the additional expanded review of roughly 6,500 applications received to date under the broadened citizenship by descent eligibility criteria is now complete.

According to IRCC, a routine review in early June identified 100 certificates issued under Bill C-3 that had potentially insufficient supporting documentation. In some of those cases, the evidence included documentation from “open sources”.

IRCC then began a closer review of the flagged files to confirm whether the documentation was enough to establish entitlement to citizenship by descent, temporarily suspending those certificates while that verification took place.

The 33 applicants whose certificates were reinstated saw their documents unsuspended on the strength of the documentation already in their files, with the statement describing the reinstatements as automatic once entitlement was confirmed.

What IRCC says caused the problem

The statement points to the department's own guidance as a contributing factor.

IRCC says that during the June review, it found the guidance on acceptable documentation, both for its officers and for applicants, was unclear, and that this may have contributed to certificates being issued without sufficient evidence.

The department says it has since reinforced the guidance given to officers and provided clearer information for applicants about the documentation they need to supply.

How the review unfolded

The statement follows several weeks of developments that began when IRCC asked recent recipients to surrender their certificates for review.

The department went on to pause the processing of some applications and, more recently, to freeze new approvals while it reviewed certificates already granted.

As the review progressed, IRCC began returning some of the certificates it had asked people to surrender. The episode also drew legal criticism, with some lawyers arguing the department had shifted the documentary standard after approval and others raising concerns that the forced surrender of certificates could be unconstitutional.

What this means for applicants

In concert with the department's acknowledgment that application guidance for citizenship applications was unclear, IRCC's updated instructions around the needed documents for citizenship by descent will carry forward—meaning that all new applicants will have to meet the updated documentary standard.

The updated instructions explicitly call for certified supporting documents of Canadian lineage (from verified source authorities) and place a greater emphasis on detailing efforts to find supporting documentation when the required document is not available.

In addition to the above, the finalization of citizenship certificates may resume following a freeze on final processing of applications cited by Immigration Minister Lena Diab on June 23. Diab quoted the review of "all applications" as part of the department's pause on finalizations, suggesting that both are closely linked. The department did not, however, officially confirm that processing would resume.

Get a Free Consultation on Applying for Proof of Canadian Citizenship