Maple News reports that IRCC announced on June 30 it had completed the review of roughly 6,500 citizenship-by-descent applications filed under Bill C-3. Finalization of these files is expected to resume within the next few days. Overall, 100 certificates were flagged for potentially insufficient supporting documentation; of these, 33 have been reinstated after IRCC confirmed entitlement based on evidence already on file, while the remaining 67 — about one percent of all C-3 certificates issued to date — remain under review and will be reinstated or contacted for additional information in coming days.
IRCC says the issue stems from its own guidance. During the June review, officers found that instructions on acceptable documentation for both applicants and staff were unclear, which may have led to certificates issued with insufficient evidence. Recipients whose certificates were suspended retained their Canadian citizenship and could continue to work while their files were reassessed. Many certificates have already been reinstated based on evidence already on file.
Legal experts have raised fairness concerns about requiring surrender of certificates issued under IRCC’s prior guidance. The principle of legitimate expectation — that applicants are entitled to rely on published government guidance — has been cited in Canadian courts. IRCC has not fully addressed this point, and some expect it could be tested in Federal Court.
Going forward, eligibility under Bill C-3 remains unchanged: individuals with a qualifying Canadian parent, grandparent, or earlier ancestor retain their entitlement. What changes is the standard of documentary proof. IRCC acknowledges its previous guidance was unclear and is applying greater scrutiny to every file. Applicants are advised to provide documentation beyond the minimum and to include corroborating records from credible sources, ideally showing why original documents could not be obtained.
In particular, explanations for missing documents will carry more weight if they detail the steps taken to obtain records and why they could not be found. This shift means applicants in the queue may have an opportunity to update their submissions to align with the clarified guidance, but it could also push processing times for proof of Canadian citizenship higher in the near term.
Lastly, while IRCC confirmed routine post-approval reviews of citizenship-by-descent applications, this episode signals a tighter, more cautious approach. Approved applications may still be subject to review, even after initial approval, though the department appears less inclined to issue surrender letters as broadly going forward. In short, eligibility remains intact, but applicants must present a rock-solid, well-documented case to secure and preserve their citizenship status.