Canada moved the goalposts for proof of citizenship applicants, lawyers say

Canadian citizenship certificate holders have been instructed to surrender their certificates for having broken rules they were never told.

On June 13, 2026, an unknown number of Canadian citizen by descent certificate holders received letters from the Registrar of Citizenship requiring them to surrender their certificates, under the authority of Citizenship Regulations 26(1), as their claims to citizenship had come under question.

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In a representative letter reviewed by CIC News, the reason given for the demand was that the application’s supporting documentation was “not from the original source authorities responsible for creating or maintaining historical records, such as civil registries, vital statistics agencies, or other authorized government bodies.”

But the citizenship department’s own documentation, which instructs applicants on how to complete the documentation and sets out what is required, nowhere specifies the above requirement.

“This is the first time the government has said that the documentation must be only from ‘original source authorities,’” said Ala Bujac, a lawyer at Cohen Immigration Law, when she reviewed the same letter in an interview with CIC News on June 17, 2026.

“Up until they issued these letters, there also had been no specific mention in any regulatory framework on the list of ‘original source authorities,’” Bujac added.

She explained that applicants who received the letters would have the opportunity to respond with additional documents, which would be reviewed as their file was investigated, but questioned whether the letter provided adequate justification for the actions taken by the government.

“The letter says the applicant didn’t provide the necessary documents. But the government had not established clear official guidelines specifying which documents and issuing authorities would be mandatory for such applications.”

The government’s official document checklist, CIT 0014, says that birth certificates need to have been “issued by the original government authority” in the country of birth, but makes no mention of the need to have obtained them from original source authorities.

The official document checklist also describes a much broader set of documents that can be accepted as proof, including listing items such as

• “any other evidence that your parent is a Canadian citizen”;
• “pre-birth orders, court orders, surrogacy agreements, hospital records”; and
• “any other proof of citizenship/immigration status in Canada or another country, such as immigration documents, visas, passports, etc.”

It is a standard principle in Canadian immigration law that the government is expected to assess applications on the basis of the standards it established at the outset.

Nevertheless, the mandate for surrender is authorized under Citizenship Regulations 26(1), which instruct the Registrar to require a person to surrender their citizenship certificate “if there is reason to believe that the person may not be entitled to the certificate.”

It is possible, however, that this provision of the Citizenship Regulations is unconstitutional: it could be subject to legal challenge under the Canadian Charter of Rights and Freedoms.

Those who received the letters had been issued their proof of Canadian citizenship certificates in response to applications following the government’s process applicable to citizens by descent, submitting a paper application on form CIT 0001 along with supporting documentation and forms.

Many who received the letters were among the first of a new wave of citizenship by descent applicants, following changes to the Citizenship Act in December 2025, which expanded eligibility for citizenship by descent to individuals born around the world, including millions of Americans with Canadian ancestry.

Over the past few months, thousands of individuals with Canadian ancestry have been applying, including many whose families have lived entirely in the United States for four or more generations.

Due to the removal of the generational limit to inheriting Canadian citizenship, some applicants had ancestors born in Canada in the mid 19^th century, prior to the advent of modern record keeping practices, and had gone to great lengths to document a chain of descent from their Canadian-born ancestors.

Applicants who have received such letters are required to surrender their certificates immediately, and requested to respond to the government with additional documentation in support of their citizenship claim.

Those whose claims are found successful will have their certificates returned to them. Unsuccessful claimants will have their certificates cancelled.

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