Maple News reports that sweeping changes proposed under Bill C-12 could dramatically reshape Canada’s Start-Up Visa (SUV) program, placing tens of thousands of immigration applications at risk of cancellation. Introduced in Parliament on October 7, 2025, the legislation gives Immigration, Refugees and Citizenship Canada (IRCC) broad new authority to suspend or terminate pending applications across various immigration streams. While touted as a way to streamline processing and enforce compliance, the bill could erase years of effort for many foreign entrepreneurs.
At the heart of the issue is compliance with updated Ministerial Instructions (MI72) issued on April 30, 2024. These instructions set stricter standards for designated business incubators who support SUV applicants. Shockingly, nearly 80% of current business incubators designated under the program do not meet these new compliance benchmarks. As a result, between 15,000 and 25,000 SUV applications currently in backlog—out of a total of 42,200 including dependents—may be wiped out if the bill passes in its current form.
IRCC has published estimated wait times, but Maple News finds that these timelines appear inconsistent with actual outcomes. While applicants backed by fully compliant incubators may benefit from priority processing, others face waits stretching over a decade. The disconnect undermines trust and adds urgency for prospective applicants to thoroughly vet the designated entities they engage with.
Bill C-12 would institutionalize IRCC’s power to cancel immigration applications via regulation and ministerial direction—not just on a case-by-case basis but across entire categories. Unlike earlier ad hoc legislative tools, this bill embeds cancellation authority in the Immigration and Refugee Protection Act (IRPA), affecting all future and existing applications under specified conditions. The legislation offers no established pathways for compensation or reinstatement.
The potential impact is not limited to those applying through the Start-Up Visa. The bill’s structure allows for its authority to be extended to other streams, such as the Federal Skilled Worker Program or Provincial Nominee Program, should similar backlogs arise.
Although early-stage SUV applicants can still receive temporary work and residence permits while their permanent residence files are being assessed, these permits may also be canceled if the PR application is later withdrawn or rejected. A regulatory update as of January 31, 2025, grants IRCC officers the authority to revoke temporary permits linked to canceled PR applications.
Legal options for affected applicants are limited. While judicial review through the Federal Court of Canada remains a primary recourse, it is often a lengthy and expensive route with no guarantee of success. Reconsideration requests or reapplications under compliant entities offer alternatives, but come with risks, including loss of associated finances and diminished credibility.
The refusal rate for incubator-supported applications has soared to 73% in 2025, pointing to elevated volumes of non-compliant submissions. With IRCC placing hard caps — a maximum of ten new SUV applications per designated organization annually — and shrinking the number of priority incubators to just 12 out of 56, many entities are no longer viable as trusted partners for applicants.
Industry experts emphasize the importance of choosing incubators or designated organizations that fully align with MI72 standards. Applicants are urged to seek legal counsel and exercise deeper due diligence before proceeding. As the government prepares to clear the backlog in a bid to preserve program integrity, a significant share of the Start-Up Visa pathway may soon be extinguished with the stroke of a pen.
