Explore the latest ImmPulse Weekly for key Canadian immigration insights—or browse past editions to catch up.
The province now requires international medical graduates to have attended an accredited Ontario high school for at least 2 years to be considered in Round 1 of CaRMS matching, a change critics say will exclude most immigrant physicians; however, IMGs remain eligible for Round 2. Ontario is the only jurisdiction with this specific rule, prompting condemnation from ITPC and concern from the OMA; WES flags the policy amid a shortage of ~2.5M Ontarians without a family doctor. The Health Minister’s office defends the move as supporting Ontario-educated IMGs and points to “Practice Ready Ontario”; in 2024–25, Ontario offered 1,032 CMG and 432 IMG residency positions.
At a House immigration committee, Conestoga president John Tibbits faced pointed questions about booming foreign enrolment, 84,000 students in four years, with 2023 intake exceeding U of T + UBC + UCalgary combined, and a jump in operating surplus from $3M (2015) to $252M (2024), amid reports of students in “slumlord housing” and using food banks. Tibbits rejected profit motives (“no money to be made”), saying growth met labour needs and that at least $500M was reinvested in infrastructure and supports.
Annual inspections fell 57% from 3,365 (2020) to 1,435 (2024), with 77% of >12,000 checks “paper-based only”; meanwhile, approvals more than doubled, ~51,000 in Q3-2024 vs 15,507 in Q3-2021, and employer fines hit $6.8M (Jan–Sep 2025), already above 2024. ESDC says remote reviews include payroll and hours checks, and paper-based inspections aren’t used where abuse/health-safety is alleged; 649 inspections (Apr–Sep 2024) found ~89% employer compliance across ~20,000 approved employers. Advocates warn that fewer on-site visits, amid rapid program growth, weaken oversight and worker protections, urging structural fixes (e.g., reducing reliance on closed permits/expanding PR pathways).
At committee on the “lost Canadians” bill, MP Michelle Rempel Garner proposed limiting jus soli to children with at least one citizen/PR parent; the amendment failed on Liberal/Bloc votes. The party is floating tougher measures (e.g., scrapping the TFWP; limiting judges from considering immigration status) and has long backed ending birthright citizenship (2018 policy), though it’s unclear if this will enter the platform. Ministers Sean Fraser and Marc Miller rejected curtailing citizenship rights. With immigration rising as a voter concern (27% name it a top-three issue; 38% of Conservatives vs 18% of Liberals), expect the debate to persist.
Ottawa dropped earlier C-2 plans to let Canada Post open mail, expand warrantless police access to data, and restrict cash transactions, measures criticized on privacy/Charter grounds, while keeping provisions to restrict asylum access, increase control over immigration documents, expand export inspections, grant Coast Guard security powers, and broaden info-sharing with U.S./governments. Public Safety Minister Anandasangaree framed the concessions as needed for passage in a minority Parliament; C-2 is not rescinded. Conservatives called it an embarrassing climbdown, the NDP’s Jenny Kwan and Migrant Rights Network said it still mirrors C-2, and U.S. reception remains unclear.
Ottawa tabled the Strengthening Canada’s Immigration System and Borders Act to tighten border controls (new Customs Act powers requiring CBSA-ready facilities at ports and access to export goods), expand Coast Guard security roles, enable RCMP sharing of sex-offender data, add asylum ineligibility rules and processing improvements, and strengthen IRCC authorities to cancel/suspend documents or pause intake and enhance information-sharing with partners. It also targets fentanyl and illicit finance via faster control of precursor chemicals, tougher AML/ATF measures, and FINTRAC’s addition to FISC. Backing this is the $1.3B Border Plan, including $743.5M/5yrs for asylum capacity and hiring 1,000 RCMP and 1,000+ CBSA personnel.
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Manitoba’s 2025 nomination allotment was boosted by 1,489 to 6,239 (up from the initial 4,750, which was 50% lower than 2024), with the province saying the increase strengthens capacity to meet labour market needs and strategic priorities.
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IRCC has extended the TR to PR Open Work Permit public policy to December 31, 2026. Eligible principal applicants with valid temporary status (or eligible to restore) and a work permit expiring within 4 months may apply online under this policy if, at PR filing, they were authorized to work, met the language requirement, and hold an IRCC confirmation/AOR. The policy now includes family members abroad for parallel OWPs; mixed-location files are coordinated domestically, with overseas dependants processed by the migration office. Permits are issued/extended to the earlier of passport expiry or Dec 31, 2026, and the $100 OWP holder fee is waived.
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IRCC has extended the Federal EMPP to December 31, 2025 (from June 12, 2025) and introduced an intake cap of 950 complete applications for the Federal EMPP Job Offer Stream that can be put into processing. Updated program-delivery instructions are posted for both EMPP and Federal EMPP.
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The province scrapped the five-year certification renewal for journeypersons in most compulsory trades (blaster remains an exception) and cut the trade-qualifier exam fee to $350 (down from $644.15) to reduce red tape and costs. It also notes the automatic recognition (since July 2) of Alberta and Quebec provincial certifications in Red Seal trades, with no extra approvals needed, even without a Red Seal endorsement. Prior renewals cost $73.53 every five years, with 11,829 processed from 2019 to 2024.
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IRCC has updated instructions to reflect the applicable fees for travel document applications submitted abroad to return to Canada.
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ESDC reports reduced reliance on the TFW Program, applications down 50% overall and 70% in the low-wage stream following Sept-2024 measures, while strengthening compliance: 1,435 inspections in FY 2024–25 found 10% non-compliance, penalties doubled to $4.88M, and 36 employers were banned, including a record $1M fine with a 10-year ban in the fish/seafood sector; the program remains a last-resort option and represents 1% of the workforce.
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Issue: Whether a 36-month delay in deciding a grant-of-citizenship application, justified only by “pending security screening” with no active steps, meets the mandamus test (Kalachnikov/Apotex; Conille) and whether “special reasons” exist to award costs.
Facts: The Applicant, an Iranian national and Canadian PR since 2020, applied for citizenship in August 2022; he had previously passed security screening for a study permit and for PR. IRCC repeatedly told him the file awaited security screening. GCMS shows criminality “Passed” on January 31, 2023, and routine six-month bring-forwards; as of July 22, 2025, security was still “under review.” By the hearing, IRCC confirmed security passed on September 23, 2025, but criminality had expired, requiring re-fingerprinting.
Court Findings: The Court applied Kalachnikov/Apotex and Conille: the 36-month delay exceeded what the process requires; the Applicant was not responsible; and the Minister offered no satisfactory justification. IRPA’s security objectives do not excuse unexplained, open-ended security checks; outsourcing parts of screening (e.g., to CSIS) does not absolve IRCC of its public duty. The Court adopted its reasoning in Jebelli and Almasi on blanket “security pending” delays and found the balance of convenience favoured the Applicant (democratic participation, professional prejudice; family separation).
Outcome: Mandamus granted. Order: (1) IRCC to notify the Applicant of the updated criminality result within 30 days of receiving it; (2) render a decision on citizenship as soon as possible and no later than 60 days after receiving the criminality result. Costs of $1,500 awarded to the Applicant; no certified question.
Why This Case is Important: It crystallizes that (i) “security screening pending” cannot, without evidence of active steps, justify multi-year delays; (ii) IRCC cannot rely on partner-agency timelines to escape accountability; and (iii) costs may be awarded where repeated, unexplained inaction forces unnecessary litigation and causes cascading re-checks. The Court expressly aligns with Jebelli and Almasi in treating blanket security delays as unjustified.
Issue: Whether an officer’s refusal of a Start-Up Business Class PR application, grounded on (a) the Applicant’s purported lack of personal involvement in Canada and (b) similarities between his business plan and “CABusinessplan,” leading to a conclusion he primarily sought status, was reasonable under Vavilov.
Facts: The Applicant, founder/CEO of a mobile app connecting physiotherapists with clients, applied on July 8, 2021, with support from the Manitoba Technology Accelerator. He received PFLs dated January 2 and April 18, 2024, and responded to both. The officer nonetheless refused, drawing negative inferences including from “CABusinessplan.”
Court Findings: On reasonableness review, the officer’s approach, centring on similarity to another plan and alleged limited personal involvement, “coloured” the assessment of the business evidence and culminated in the status-seeking conclusion. That conclusion lacked the hallmarks of reasonableness (justification, transparency, intelligibility) and was not justified in relation to the record and the relevant constraints.
Outcome: JR allowed; refusal set aside; matter remitted to a different officer; no certified question. (Hearing July 22, 2025; reasons October 8, 2025.)
Why This Case is Important: In SUV files, inferring “status-seeking” from plan similarities or perceived limited involvement requires clear, cogent explanation that engages with the substance of the business evidence. Where the inference is not transparent or justified, the decision will be set aside under Vavilov.
Issue: Mandamus to compel a PR decision in a PGP file after an IAD remittal, does delay run from original filing (2021) or from IAD’s October 2023 reopening?
Facts: Sponsor initially ineligible on income; IAD set aside IRCC’s refusal and ordered reopening (Oct 11, 2023). IRCC sought documents, confirmed sponsor’s eligibility, and referred the file to CNISS; security screening ongoing since February 3, 2025.
Court Findings: Delay assessment resets at the IAD reopening; fewer than 24 months had elapsed, within the 26-month posted time for PGP and not unreasonable. CNISS screening since Feb 2025 is not inordinate; granting mandamus would improperly short-circuit security screening and queue order.
Outcome: Application dismissed; no costs; no certified question.
Why This Case is Important: Clarifies that, post-IAD/JR, the “clock” for mandamus runs from the reopening decision; emphasizes deference to security screening timelines and queue integrity.
Issue: Reasonableness of refusing a Self-Employed Persons Class PR application for failing to show intention/ability to be self-employed and make a significant contribution (IRPR s.88(1)).
Facts: Iranian visual artist residing in Istanbul applied in 2021 with a business plan to work as an artist/teacher in Canada; officer found plan lacked concrete details, English proficiency evidence was limited, and “significant contribution” was not addressed.
Court Findings: Reading reasons contextually, it was open to the officer to conclude the plan was aspirational, lacked market commitments or projections, and did not demonstrate the required elements under s.88(1).
Outcome: JR dismissed.
Why This Case is Important: Confirms a “reasons-first” Vavilov review for SEPC refusals and that generic or aspirational business plans and limited language evidence can reasonably ground refusal on the conjunctive s.88(1) criteria.
Issue: H&C refusal for out-of-status spouse/child where officer minimized best interests of child and proposed unrealistic “alternative solutions.”
Facts: Officer refused H&C on basis that step-children were not “family members” and because the sponsor failed to declare them, while suggesting options the Court found implausible on this record.
Court Findings: Reasons inadequately addressed the child’s best interests and relied on unrealistic alternatives; the decision fell short of Vavilov reasonableness.
Outcome: JR allowed; remitted to a different officer.
Why This Case is Important: Reiterates that BIOC analysis must be substantive and that speculative “alternatives” cannot substitute for a robust H&C assessment.
Issue: Reasonableness and fairness of refusing a Spousal Open Work Permit under R200(1)(b) for insufficient funds/readiness and concerns about leaving Canada.
Facts: Indian applicant sought SOWP to join spouse on PGWP; GCMS noted large unexplained deposits in spouse’s Canadian account, lack of provenance for applicant’s own funds, no evidence of salary deposits, and no plan for employment.
Court Findings: Applying Vavilov, the officer’s analysis of financial sufficiency/readiness was internally coherent and tied to the record; no reviewable fairness breach was shown.
Outcome: JR dismissed.
Why This Case is Important: Confirms officers may scrutinize provenance and liquidity (not just balances) and can reasonably infer insufficiency where deposits are unexplained or not corroborated by payroll flows.
Issue: JR of (1) study permit refusal and (2) five-year s.40(1)(a) misrepresentation finding for failing to disclose prior U.S. visa refusals.
Facts: Applicant did not declare U.S. refusals; officer treated omission as deliberate concealment and refused SP; a separate misrep decision followed.
Court Findings: Honest-mistake arguments failed on this record; the officer’s inferences and misrep finding were open and sufficiently reasoned under Vavilov.
Outcome: JR dismissed.
Why This Case is Important: Reinforces the breadth of s.40(1)(a): non-disclosure of material visa history supports both refusal and inadmissibility; “innocent error” is narrowly applied.
Issue: Reasonableness and procedural fairness of a second study-permit refusal after an earlier consent remittal, concerns about funds and temporary intent, and whether officer fairly put new issues.
Facts: First refusal was settled at leave; on reconsideration, officer again refused (June 2024) citing financial sufficiency and intent. Applicant alleged fairness defects.
Court Findings: The decision was unreasonable; fairness breached where new or determinative concerns were not put to the applicant during reconsideration despite the prior settlement context.
Outcome: JR allowed; redetermination by a different officer.
Why This Case is Important: After a consent remittal, officers must meaningfully engage with the record and put new determinative concerns; perfunctory re-refusals risk being set aside.
Issue: Reasonableness of refusing to reopen a work-permit refusal for misrepresentation where applicant blames an undeclared consultant; scope of “innocent error” exception.
Facts: WP refused April 9, 2024 for fraudulent documents and s.40(1)(a) misrep; reconsideration request asserted consultant deceit/forgery, but representative was never declared.
Court Findings: Innocent-error exception is narrow; applicant abdicated her responsibility to ensure accuracy. It was reasonable to refuse reopening and maintain misrep.
Outcome: Application dismissed; no certified question.
Why This Case is Important: Confirms applicants remain responsible for what is filed, even by third parties, and that consultant misconduct rarely negates a s.40(1)(a) finding.
Issue: Whether the Court should grant an extension of time to file for judicial review of an STCA port-of-entry exclusion decision; absent that, whether the Court has jurisdiction to hear the ALJR.
Facts: Jamaican father and minor son presented at the Lacolle POE on October 22, 2024 to claim refugee protection; CBSA denied entry under the STCA and issued exclusion orders on October 23, 2024. The ALJR was filed November 8, 2024, one day past the 15-day IRPA s.72(2)(b) deadline.
Court Findings: The leave order did not grant an extension, so the applications judge could determine that issue; applicants failed the Hennelly factors (no evidence of continuous intention and no reasonable explanation beyond counsel error asserted only in argument). Oral/written argument is not evidence.
Outcome: Application dismissed for want of a granted extension; Court lacks jurisdiction without it.
Why This Case is Important: Reaffirms that missing the s.72(2)(b) timeline is fatal unless Hennelly is met with evidence (not submissions); a silent leave order doesn’t implicitly extend time.
For comprehensive legal analysis or strategic case support, contact Greenberg Hameed PC.
The content of this bulletin is for informational purposes only, and is not intended to provide or be relied on as legal advice.
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