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April 2, 2020

Immigration Document Collection Affected by COVID-19 – Good for Immigration Canada Allowing for Reasonable Exceptions During an Unreasonable Time!

Posted by Mario Bellissimo - Bellissimo Law Group PC

Canadian immigration is critical to the functioning of our country.  Immigration, Refugees and Citizenship Canada (IRCC) has been placed in an unenviable position of balancing this essential flow of permanent and temporary migrants while doing their best to protect the health and safety of all Canadians and foreign nationals.  It is also important to highlight what may seem obvious but there is processing of immigration applications outside of Canada and processing of immigration applications within Canada.  Both lines of processing are impacted and both raise their own challenges.  The Canadian Bar Association is having ongoing meetings with IRCC and has provided ongoing updates.  We are also seeing a number of unfolding updates in our own practice each day with our clients.

What have we learned?

First and significantly, IRCC has confirmed to their credit all applications continue to be processed.  Yet, naturally with the spread of COVID-19 applicants are facing challenges in obtaining the required application documents.   IRCC though is receiving incomplete applications. Such applications will be retained for 90 days and will be reviewed in an additional 60 days. If required, officers will provide a further 90 days for outstanding documents to be obtained and provided. Where incomplete applications are submitted, notes should be provided to indicate documents which cannot be obtained due to COVID-19.

This includes the requirement to provide photos where applicable. Specific indication was also given that for spousal sponsorship applications where a marriage certificate cannot be obtained, records of solemnization of marriage will be accepted in the interim, with certificates to follow. 


With regards to biometrics, IRCC has not yet decided whether biometrics will be available at the Port of Entry.

Confirmation of Permanent Residence & Landing

IRCC has advised that for those outside of Canada who have received their Confirmation of Permanent Residence (COPR) prior to 18 March 2020 may still travel to Canada. For those inside Canada who have received their COPR and have yet to land as permanent residents, are being advised not to flagpole. IRCC is investigating methods to land new permeant residents without the need to be in-person, including signing of the COPR by the applicant. COPRs are otherwise still being issued.

Permanent Residency Applications & Express Entry

In light of the difficulties in submitting complete applications, IRCC may suspend Express Entry draws; this is however yet to be confirmed. In the interim they are exploring the possibility of accepting electronic education credential assessments and language test results from the issuing bodies.  Other permanent residency applications are still being accepted. IRCC however noted that due to decreased staff in the mail rooms, there is an increasing backlog in applications.

Permanent Resident Cards

New Permanent Resident (PR) cards are being sent inland while renewed PR cards are being sent directly to applicants or their representatives. While in-person interviews remain suspended, IRCC is considering alternative options.

Entering Canada to work

IRCC’s current position is that all foreign workers are being permitted to enter.  For applicants with recently issued work permits or work permit approval letters who are yet to enter Canada, IRCC recommends that they obtain and carry confirmation from their employer that the position is still available when entering Canada.

IRCC is yet to provide guidance for those people who are intending to enter Canada in order to work but who do not hold a work permit and are unable to provide the above evidence. This includes those people who are visa exempt or work permit exempt who are planning to enter Canada with an International Mobility Worker Unit (IMWU) opinion, a PNP work permit support letter, or an LMIA.

Expiring Study Permits and Work Permits

IRCC is still in the process of developing a solution or possible special policy bulletin for work permit (WP) or study permit (SP) holders who have permits due to expire with the expiry of their passport and who are unable to obtain a new passport due to suspension of services at Consulates or Embassies.

Existing study permit holders who are travelling to Canada must confirm their designated learning institution is still offering classes.

Inland Refugee Applications

With regards to inland refugee claims, IRCC has indicated that the only signature currently required from applicants is on the Use of Representative Form. No other forms are currently required, instead IRCC is requesting a photo/ copy of the biographical page of the applicant’s passport and answers to 15 questions.

Impressive.  A novel response to a novel virus.