Minister Confirms IRCC Is Not Finalizing New Bill C-3 Citizenship Applications While Review Continues
June 24, 2026
Cassandra Fultz, RCIC-IRB
IRCC Completed Review of Bill C-3 Citizenship Certificates: What Applicants Need to Know
Immigration, Refugees and Citizenship Canada (IRCC) has now confirmed that it has completed its expanded review of citizenship-by-descent applications submitted under Bill C-3.
This announcement provides the clearest explanation to date of what led to the recent citizenship certificate suspension letters sent to some applicants under the Lost Canadians provisions.
The short version is this:
- IRCC has completed its broader review.
- Approximately 6,500 applications were reviewed.
- Of the 100 cases initially identified for potential documentation concerns, 33 certificates have already been reinstated and 67 cases remain under review.
IRCC has also acknowledged that its own guidance on acceptable documentation was unclear and may have contributed to certificates being issued without sufficient evidence.
This is an important development for current applicants, future applicants, and those who were concerned that Bill C-3 itself was being suspended or reversed.
What IRCC Has Now Confirmed
According to IRCC, the issue began during a routine review in early June. During that review, IRCC identified 100 citizenship certificates issued under Bill C-3 where the supporting documentation may have been insufficient.
IRCC then began a further review to determine whether the documents in those cases were enough to establish entitlement to Canadian citizenship by descent.
In some cases, IRCC says the applications included documentation from “open sources.” This appears to refer to publicly available or third-party records, although IRCC has not provided a detailed definition in the announcement.
While that review was ongoing, the citizenship certificates in the identified cases were temporarily suspended.
IRCC then expanded the review “out of an abundance of caution” to include approximately 6,500 citizenship-by-descent applications received under Bill C-3 to date.
That expanded review is now complete.
Screenshot of IRCC's Facebook Post explaining the cause of the Canadian citizenship certificate demand letters
The Numbers
IRCC’s announcement gives us the most concrete numbers we have had so far:
- Approximately 6,500 Bill C-3 citizenship-by-descent applications were reviewed.
- 100 issued citizenship certificates were initially identified as potentially having insufficient supporting documentation.
- 33 of those certificates have already been automatically reinstated.
- 67 cases remain outstanding.
- IRCC says those 67 cases represent roughly one per cent of certificates issued under Bill C-3 to date.
- IRCC expects the next steps in those cases to be completed within a matter of days.
This is reassuring in one important respect: the issue appears to be significantly narrower than many applicants feared.
At the same time, the 67 remaining applicants are still facing serious uncertainty and should take any correspondence from IRCC very seriously.
What Happens to the 67 Outstanding Cases?
IRCC has stated that it is contacting the remaining affected clients directly.
For those cases, IRCC will either:
- confirm that the applicant is eligible for a citizenship certificate under Bill C-3; or
- request additional information to validate eligibility for citizenship by descent.
The remaining cases have not necessarily been refused or revoked. Rather, IRCC is still determining whether the evidence in those files is sufficient or whether further documentation is required.
Anyone who receives a request from IRCC should not ignore it, and should reach out for professional guidance ASAP.
IRCC Acknowledges Its Requirements Were Unclear
Perhaps the most significant part of the announcement is IRCC’s acknowledgment that its guidance was unclear.
IRCC stated:
“During the routine review in June, IRCC found that guidance on acceptable documentation for both officers and applicants was unclear and may have contributed to certificates being issued without sufficient evidence.”
This is a major point.
For weeks, applicants, lawyers, representatives, and affected families have been trying to understand whether this situation was caused by applicant error, officer error, unclear instructions, internal inconsistency, reliance on third-party records, or some combination of those factors.
IRCC has now confirmed that unclear guidance was at least part of the problem.
This matters because citizenship-by-descent applications can involve complex historical records across multiple generations. Applicants often rely on a combination of birth certificates, baptismal records, census records, immigration records, naturalization documents, archival materials, and family history records.
When the rules about acceptable evidence are unclear, inconsistent outcomes become much more likely.
Why Documentation Matters
IRCC has now reinforced its guidance to officers and provided clearer information to applicants about the documentation required for citizenship-by-descent applications.
For future applicants, the lesson is clear:
Applications should be supported by authentic, reliable, and verifiable documents issued by the original authority wherever available.
Third-party genealogy records, online family trees, Ancestry.com records, indexes, and open-source materials can be useful research tools. They can also be helpful supporting evidence.
However, they should generally not be treated as a substitute for official records where official records exist.
Where possible, applicants should obtain documents directly from the authority that created or maintains the record, such as:
- provincial or territorial vital statistics offices;
- civil registries;
- archives;
- citizenship or naturalization authorities;
- church or parish record custodians, where applicable;
- other official record holders.
If an official record cannot be obtained, applicants should document the efforts made to obtain it and provide a written explanation with supporting evidence.
Does This Mean Bill C-3 Is Still Available?
Yes.
Nothing in IRCC’s announcement suggests that Bill C-3 has been repealed, suspended, or reversed.
The expanded review is now complete, and the issue appears to be limited to a relatively small number of cases where IRCC had concerns about whether the supporting documentation established entitlement to citizenship.
Eligible applicants can still pursue citizenship by descent under Bill C-3.
However, the evidentiary expectations are now clearer, and applicants should be prepared to provide stronger documentation than some may have previously believed was sufficient.
What This Means for People Considering Applying
If you are considering applying for Canadian citizenship by descent under Bill C-3, this announcement should not scare you away from applying if you are eligible.
It should, however, make clear that the application should be prepared carefully.
This is not simply a matter of building a family tree and submitting online records. Citizenship by descent requires evidence that establishes both:
- the parent-child relationship through each generation; and
- the Canadian citizenship connection through the relevant ancestor.
In many cases, that means obtaining official records across several generations and sometimes across multiple jurisdictions.
Where records are missing, the application should explain what efforts were made to locate them and why alternative evidence is being provided.
What This Means for People Who Already Received Citizenship Certificates
If you already received your citizenship certificate and have not been contacted by IRCC, this announcement is generally reassuring.
IRCC has completed its expanded review, and only 67 cases remain outstanding.
However, it remains wise to keep all original documents, certified copies, and correspondence related to your application.
IRCC can request additional documentation in certain circumstances, and maintaining a complete record of your application is always prudent.
What This Means for People Who Received a Letter
If you are one of the people who received a letter from IRCC regarding the surrender or temporary suspension of your citizenship certificate, you should not ignore any further correspondence.
IRCC has said it is contacting affected individuals directly.
You may receive confirmation that your eligibility has been validated, or you may be asked to provide additional information.
If you receive a request for further evidence, it is important to respond with care. The response should address the specific concern raised by IRCC and provide the strongest available evidence to support your entitlement to citizenship.
Our Perspective
This announcement confirms what many observers suspected: the situation was not simply about applicants making mistakes.
IRCC has now acknowledged that unclear guidance for both officers and applicants may have contributed to certificates being issued without sufficient evidence.
That does not mean every affected applicant was ineligible.
Indeed, IRCC has already reinstated 33 of the 100 initially identified certificates.
It does mean that the evidentiary standard matters, and that applications based on citizenship by descent must be prepared with care.
For future applicants, the takeaway is not that Bill C-3 is unsafe or unavailable.
The takeaway is that documentation matters.
Need Help With a Citizenship by Descent Application?
Doherty Fultz Immigration assists clients with Canadian citizenship by descent, Lost Canadians cases, and applications under Bill C-3.
If you are considering applying, have questions about your eligibility, or have received correspondence from IRCC, we would be happy to review your situation.
