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ImmPulse Weekly

Reporting Period | October 27-31, 2025

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Media Commentary & Policy Reflections

United States to photograph Canadian travellers when they enter and exit at all land borders, airports

Starting December 26, 2025, U.S. Customs and Border Protection will begin photographing all non-U.S. citizens, including Canadians, at both entry and exit across air, land, and sea ports. The final rule, published October 27, 2025, removes prior age exemptions, so the requirement applies to all ages; U.S. citizens may opt out, but non-citizens cannot. This is part of the U.S. biometric entry-exit system, designed to reduce overstays and identity fraud, with a phased rollout scheduled through 2026. Travellers should expect more cameras at crossings and potentially longer processing at some ports, and ensure their identification is consistent. (CBC News)

Canada’s education sector, led by the Canadian Bureau for International Education, is launching a national digital campaign to rebuild the “Canada” brand and lure international students back after steep declines tied to federal caps and tighter work/PR rules. The article reports enrolment and applications have plunged: there are now just over 800,000 international students (down from ~1 million in 2023), new arrivals in Jan–Aug 2025 fell by 132,505 to 89,430, Saskatchewan Polytechnic saw a 40% drop (triggering layoffs and program cuts), and sector-wide there have been 35 campus closures, 863 program suspensions/cancellations, and 10,000+ layoffs at Ontario colleges. The pitch reframes Canada as a high-quality, safe destination, emphasizing study-first messaging while acknowledging fewer PGWP/PR guarantees, and calls for myth-busting and coordinated federal-provincial support to stabilize recruitment. (Toronto Star)

Canada’s recent pullback on immigration, especially fewer temporary residents, helped take some heat off the job and rental markets right when new U.S. tariffs were adding stress. With a bit less population pressure, unemployment likely stayed closer to 7% (instead of nearer 8%), and rent increases cooled slightly. They’re not anti-immigration: the message is keep immigration, but pace and target it better so housing, services, and skills match what the economy can handle. (Toronto Star)

Program Delivery & Immigration Highlights

Ontario’s October 31, 2025, OINP update confirms that regulations were amended to expand the factors the program may use to return an application before nomination, letting OINP focus on current labour-market priorities; applicants/representatives will be notified and the full fee refunded, and this builds on the July 2 changes that introduced return authority. The amended O. Reg. 421/17 lists concrete considerations such as federal nomination allocation, application volumes vs targets, federal PR intake status, compliance risks, provincial/federal policy priorities, unemployment and regional labour needs, housing availability/cost, capacity to fund health/social services, whether the applicant can lawfully work or is working in Ontario, job-offer approval status, language ability, employment/wage history, education, and Canadian work/education.

(Source 1)

(Source 2)

B.C. expects over 1 million job openings in the next 10 years (2025–2035) as the workforce grows from about 2.9 million to 3.3 million. The most extensive hiring will be in healthcare, professional/tech jobs, retail, construction, and finance/real estate. Most roles, approximately 3 out of 4, will require college, university, trades training, or solid work experience. The forecast assumes slower population growth (due to lower federal immigration targets) and may not fully reflect new, fast-tracked projects, so that the numbers could shift. Bottom line: if you work in health care or tech, or you’re training for these fields, B.C. looks like firm ground over the next decade.

(Source)

IRCC issued an October 27, 2025, program delivery update creating temporary special processing measures for people directly affected by Canada’s 2025 wildfires, covering Canadian citizens, permanent residents, and temporary residents. The measures for temporary residents take effect on July 2, 2025. For citizens and permanent residents, these measures are retroactive to April 1, 2025. All measures remain in place until November 30, 2025. This update replaces the 2023 wildfire measures and provides IRCC officers with operational instructions on how to handle impacted cases.

(Source)

Recent Case Law

Issue: Was IRCC’s finding of misrepresentation (and resulting inadmissibility) reasonable where the sponsor denied having a child while applying to sponsor his sister under the “lonely Canadian” stream (IRPR 117(1)(h))?

Facts: The sponsor (Mr. Lah) became a Canadian citizen in 2023. He had earlier identified a daughter in his own PR process but later stated “no children” when sponsoring his sister in 2023 under IRPR 117(1)(h), where having a sponsorable relative would make the sister ineligible. A PFL issued; Mr. Lah said he misunderstood custody/IRCC rules due to sole custody to the mother and past medical-exam issues. IRCC rejected the PR for misrepresentation and imposed a 5-year bar under IRPA s.40(2).

Court Findings: The officer reasonably concluded the omission was deliberate given multiple explicit denials of having children that made the sister appear eligible. On JR the Court’s role is not to reweigh facts; the decision fell within the range of reasonable outcomes under Vavilov.

Outcome: Application dismissed; no certified question.

Why This Case is Important: Confirms strict treatment of sponsor misstatements in “lonely Canadian” sponsorships; clarifies that even plausible misunderstandings won’t rescue a decision that is otherwise reasonable on the record.

Issue: Was it unreasonable or procedurally unfair to refuse a Quebec Investor Class PR application based on lack of intent to reside in Quebec after an in-person interview?

Facts: The Bangladeshi applicant applied in 2019; IRCC later requested settlement planning evidence and interviewed him in June 2024. The refusal found he had not shown intent to reside in Quebec.

Court Findings: Intent to reside is a discretionary, subjective assessment; GCMS notes form part of reasons. The officer probed vague answers; no bias or unfairness. Decision coherent and responsive.

Outcome: Application dismissed; style of cause corrected; no certified question.

Why This Case is Important: Reiterates that, post-CSQ, the sole federal criterion is intent to reside; courts defer heavily to officers’ interview-based assessments when reasons are supported in GCMS.

Issue: Did the IAD reasonably find it lacked jurisdiction to hear a PR’s removal-order appeal because s.64 IRPA barred appeals for serious criminality given the sentence imposed, despite subsequent criminal proceedings reducing the sentence?

Facts: Mr. Rebelo, in Canada since age 3, lost PR status after an ID finding of inadmissibility for serious criminality based on a manslaughter conviction with an eight-year sentence. On successful criminal appeal he pled to a lesser offence and received six months less a day, but the IAD dismissed his appeal for want of jurisdiction.

Court Findings: New evidence tendered on JR was inadmissible; exceptions (Access Copyright) didn’t apply. The reasonableness review focused on whether the IAD’s interpretation of s.64 (appeal bar) and departure from earlier approaches (e.g., Nabiloo) was justified; applicant’s arguments about harsh consequences did not show unreasonableness.

Outcome: Application dismissed. (Reasonableness upheld; no certified question indicated.)

Why This Case is Important: Affirms that IAD jurisdiction turns on the sentence for serious criminality and that later criminal outcomes do not necessarily reopen IAD jurisdiction; clarifies limited scope for extra-record evidence on JR.

Issue: Was a TRV refusal under R179(b) unreasonable where the officer cited Canadian family ties and purpose of visit but failed to analyze countervailing ties in the country of residence?

Facts: Iranian mother and adult son sought one-month TRVs to visit spouse/stepfather in Canada. Refused for “significant family ties in Canada” and purpose inconsistent with a temporary stay.

Court Findings: Officer’s reasons/GCMS did not discuss family ties in Iran; failure to conduct a “push/pull” analysis is a reviewable error. Reasons must show both sides were weighed; court cannot speculate.

Outcome: JR allowed; reconsideration by a different officer; no certification.

Why This Case is Important: Strong reminder that TRV R179(b) assessments must expressly weigh home-country anchors against Canadian ties; template refusals lacking that analysis are vulnerable.

Issue: Was a study-permit refusal for insufficient financial resources unreasonable or procedurally unfair due to lack of reasons?

Facts: Officer refused under R216(1)(b)/R220(b), not satisfied the applicant had funds to sustain herself and pay tuition; applicant argued HSBC statements were ignored and reasons were lacking.

Court Findings: Reasonableness standard applied; on the record the decision was justified, intelligible, and satisfied Vavilov; fairness reviewed akin to correctness showed no breach.

Outcome: Application dismissed.

Why This Case is Important: Reiterates high deference to officers on financial sufficiency assessments and that generic reasons, read with GCMS, can satisfy reasonableness and fairness.

Issue: Was a TRV refusal to an SUV applicant unreasonable where the officer doubted funds and said purpose wasn’t consistent with a temporary stay?

Facts: Iranian applicant with pending SUV PR sought a visitor visa to meet lawyers/incubator; refusal for insufficient funds and purpose concerns.

Court Findings: Record did not clearly connect the employer commission to the long-term account; provenance unexplained; inadequate documentation of funds alone supported refusal; decision met reasonableness hallmarks.

Outcome: Application dismissed; no certification.

Why This Case is Important: Shows courts uphold TRV refusals where financial documentation is inconsistent/incomplete, even for founders tied to SUV processes.

Issue: Was refusal of a work permit (pending SUV PR) unreasonable where the applicant argued the Commitment Certificate showed urgent need for her presence in Canada?

Facts: Start-up co-founder/CMO with York Angel Investors’ Commitment Certificate sought an early work permit; officer refused; applicant said evidence of urgency was overlooked.

Court Findings: After reviewing the record (including the Certificate), the Court found no missed evidence; assertions about start-ups needing pre-launch marketing presence were unsupported; decision reasonable under Vavilov.

Outcome: Application dismissed; no certified question.

Why This Case is Important: Clarifies that Commitment Certificates don’t automatically establish “urgency” for work permits; applicants must adduce concrete, record-based evidence of necessity.

Issue: Are a CBSA “Phone Call Record” and a Final Disposition Letter in the Public Complaints Mechanism reviewable, and was the final decision reasonable/fair (including bias concerns)?

Facts: US citizen alleged verbal/physical abuse, mistreatment of wife/pets, property damage, and improper refusal of entry at land POE; CBSA investigated via narrative reports and video; ARDG issued a Final Disposition Letter finding complaints unfounded.

Court Findings: The Phone Call Record was an interlocutory step, not a reviewable “decision”; only the Final Disposition Letter carried legal consequences. On the merits, the letter was intelligible/justified; alleged bias failed, superintendent wasn’t the decision maker and any role overlap was cured by independent ARDG review.

Outcome: Application dismissed.

Why This Case is Important: Clarifies what is “amenable to JR” within CBSA’s complaints process and affirms deference to ARDG fact-finding where the record (including video) supports the outcome.

Issue: Was a spousal PR refusal (genuineness) and a misrepresentation finding reasonable where the applicant failed to disclose US refusals and inconsistencies arose at interview?

Facts: Sponsored spouse married in 2023; application filed Nov 2023; interview held April 2024; officer found marriage not genuine and misrepresentation. Applicant argued ineffective representation and that misrep was only about lack of details.

Court Findings: The central finding was marriage not genuine; misrepresentation also upheld—omitting prior US refusals is material and distinguishes cases where refusals were disclosed but incomplete. Decision reasonable under Vavilov.

Outcome: Judicial review dismissed; no certification.

Why This Case is Important: Reinforces rigorous scrutiny of spousal genuineness and confirms that total non-disclosure of prior visa refusals is a material misrepresentation.

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