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Canada has temporarily paused finalizing some new citizenship-by-descent applications under Bill C-3.
A few dozen applicants who had already been approved received letters asking them to surrender their citizenship certificates while their files are re-examined. Applicants who have moved to Canada can still work during the review but cannot use a Canadian passport. The law has not changed. What has changed is what IRCC expects to see in the file.
The pause came without much warning.
People who applied for citizenship by descent under Bill C-3, received approval, and in some cases already moved to Canada found letters in their files asking them to return their citizenship certificates. IRCC confirmed on June 18, 2026 that it had temporarily stopped finalizing some new applications in the same category while an internal review was underway.
The eligibility rules under Bill C-3 are unchanged. The issue is documentary. IRCC is applying stricter scrutiny to what counts as sufficient proof of lineage, and some files that passed an initial review are now being re-examined.
For new applicants who have not yet submitted, there is still time to build the kind of file that can withstand this level of review on the first attempt.
What Is the Processing Pause?
IRCC has temporarily stopped finalizing some new citizenship-by-descent applications. The pause follows an internal review launched to determine how approved applications with what the department now considers insufficient documentary evidence passed through initial processing.
The pause affects only a subset of applications. Not every citizenship-by-descent file is paused. The measure appears to target applications where the documentary evidence is under question.
IRCC has stated that it is taking steps to ensure applications are assessed fairly and lawfully, although the department’s full statement has not been made public. No end date for the pause has been confirmed.
What Are the Surrender Letters?
Separate from the processing pause, a few dozen applicants who had already been approved and received citizenship certificates were sent letters asking them to return those certificates while their files are re-examined.
The letters cite a regulation that allows the Registrar of Canadian Citizenship to request the return of a certificate when there is reason to question entitlement. The specific concern identified in the letters relates to gaps in the documentary evidence submitted with the applications.
Key points about the surrender letters:
- Applicants who received a surrender letter are still considered Canadian citizens while the review is underway.
- Applicants who have already moved to Canada can continue working during the review period.
- Those applicants cannot use a Canadian passport while the citizenship claim is under review.
- Anyone who received a surrender letter will be given an opportunity to submit additional documentary evidence.
- If the review confirms Canadian lineage, the certificate will be returned.
What IRCC Is Treating as Insufficient Evidence
Immigration Minister Lena Diab identified two document types as lacking sufficient evidentiary weight:
- Transcripts sourced from genealogy websites.
- Copies obtained through genealogy platforms rather than directly from the issuing authority.
IRCC’s position is that birth certificates, marriage certificates, and other vital records should come from the government, religious institution, or civil authority that originally issued them. Printouts or exports from third-party ancestry services may not carry the same evidentiary weight.
This does not mean genealogy research has no role in a citizenship-by-descent application. It means the research should be used to locate the records. The records themselves should then be obtained as originals or certified copies from the issuing authority.
Why the Surge in Applications Made This Inevitable
Bill C-3 took effect on December 15, 2025. Since that date, people born before December 15 who can trace and prove direct lineage, generation by generation, to a Canadian ancestor may claim citizenship without meeting a residency requirement.
The change triggered a significant surge in applications, particularly from Americans tracing Canadian roots. Provincial archives were overwhelmed by requests for old vital records. The proof-of-citizenship queue grew quickly. As of June 2026, more than 82,000 applications were pending, and the wait time had climbed to approximately 15 months.
With that volume came pressure on archives, processing officers, and the evidentiary standards applied to each file. Some applications that may have passed initial review under lighter scrutiny are now being reconsidered as IRCC conducts its internal review.
Some of the 82,000 pending applications may experience even longer waits as a result of the pause.
What Lawyers and Experts Are Saying
Legal observers have raised two concerns following the surrender letters.
The first is procedural. Some applicants and immigration lawyers argue that IRCC approved these applications using the same evidence it is now questioning. Their concern is that the government may have changed the evidentiary standard after approval.
The second is constitutional. Some legal experts have argued that requiring a person to surrender a certificate before any finding of ineligibility has been made may raise constitutional concerns because the certificate is the document used to prove status and obtain a passport.
Those constitutional questions remain unresolved. Cambria Law Firm is monitoring the issue as it develops.
What New Applicants Need to Do Differently
The law has not changed. Bill C-3 remains in force. What has changed is what a defensible application file looks like.
Use Original Records From Issuing Authorities
Every birth certificate, marriage certificate, death certificate, or other vital record used to establish lineage should come directly from the government registry, church, or civil authority that issued it. Do not rely on genealogy website printouts as the primary evidence.
Document Every Failed Search
If an original record cannot be located because it was destroyed, lost, or predates reliable civil registration, include a written explanation of the search effort. State what was searched, when the search was conducted, who conducted it, and what the result was.
Build the Lineage Generation by Generation
Bill C-3 requires proof of an unbroken line of descent from a Canadian ancestor. Every generation needs supporting documents. A single undocumented link creates a gap that IRCC may question.
Use Genealogy Platforms as Research Tools Only
Ancestry.com, MyHeritage, Findmypast, and similar services can help locate records. They should not replace original or certified records from the issuing authority.
What If You Already Received a Surrender Letter?
If you received a surrender letter, your citizenship status has not been revoked. Under Canadian citizenship law, you remain a Canadian citizen while the review is underway.
What you cannot do during the review: use a Canadian passport.
What you can do during the review: continue working in Canada if you have already moved here.
What happens next: IRCC will give you an opportunity to submit additional documentary evidence before making a final determination. If your lineage is confirmed, your certificate will be returned.
Contact Cambria Law Firm immediately if you received a surrender letter. The additional evidence submission is your opportunity to resolve the issue, and the source and quality of the documents will matter.
What If Your Application Is Pending?
If your citizenship-by-descent application is still pending, the processing pause may affect the wait time. It is not yet clear which files are affected or how long the pause will last.
You do not need to take immediate action unless IRCC contacts you. However, if your application relied on records sourced from genealogy websites instead of original issuing authorities, gathering certified records now may put you in a stronger position if IRCC requests additional evidence.
How Cambria Law Firm Can Help With Citizenship by Descent
- We review your existing application and assess whether the documentary evidence meets the standard IRCC is now applying.
- We identify gaps in the generational chain and advise on how to fill them with records from the original issuing authority.
- We prepare additional documentary evidence submissions for applicants who received surrender letters.
- We build new applications using original and certified records rather than genealogy website printouts.
- We monitor IRCC updates on the processing pause and advise you when a change affects your file.
- Free consultation. Vick Sidhu reviews your lineage documents and advises on file readiness before submission.
Frequently Asked Questions
Does the processing pause mean my citizenship-by-descent application is cancelled?
No. A processing pause is not a cancellation. Your application remains in the queue. The pause affects the timing of some decisions while IRCC conducts its internal review.
I received a surrender letter. Am I still a Canadian citizen?
Under Canadian citizenship law, yes. Applicants who received a surrender letter are still considered Canadian citizens while the review is underway. The letter affects the certificate used to prove status, but it does not itself revoke citizenship.
Can I travel on my Canadian passport if I received a surrender letter?
No. IRCC is advising applicants who received surrender letters that they cannot use a Canadian passport while their citizenship claim is under review. Do not attempt to use the passport until the review is resolved and the certificate is returned.
I used Ancestry.com records in my application. Does that mean my file will be paused?
Not necessarily. A file that used genealogy records as supplementary evidence may be treated differently from one that relied on those records as the primary or only proof. The stronger approach is to obtain original or certified records from the issuing authority.
How long will the processing pause last?
IRCC has not confirmed an end date. The pause has been described as temporary and connected to an internal review.
My lineage goes back several generations. How do I obtain original records for relatives who died 100 years ago?
Start with provincial vital statistics offices and archives. Many provinces have digitized historical birth, marriage, and death records. Church records may also be available for events that predate civil registration. If a record cannot be located, document the search effort in writing and include that explanation with the application.
