Weekly

Explore the latest ImmPulse Weekly for key Canadian immigration insights—or browse past editions to catch up.

ImmPulse Weekly

Reporting Period | November 3-7, 2025

Media Commentary & Policy Reflections

‘Ottawa is creating an emergency’: Quebec minister on temporary immigration cuts

Quebec’s immigration minister blasted Ottawa’s latest cuts to temporary immigration, especially tighter TFWP caps, as creating an “emergency” for businesses, even as Quebec lowers PR targets to 45,000 a year. He said Quebec sought a grandfather clause to keep existing TFWs but was refused, warning of regional labour crises amid a roughly 50% drop in new TFW arrivals this year. (Global News)

Liberals and the NDP passed Bill C-3 (citizenship-by-descent) at third reading, overturning opposition amendments and restoring the government’s original plan to let Canadians born abroad pass citizenship to children born overseas via a residency test; the 177–163 vote sends the bill to the Senate as Ottawa seeks a six-month extension beyond the Nov 20 court deadline that struck down the two-generation cut-off. (Toronto Star)

Canada is slowing immigration growth to a steadier pace: permanent residents will stay around 380,000 a year to 2028, and temporary entries (like workers and students) will be tighter. Quebec plans about 45,000 new permanent residents in 2026 and is simplifying programs to support French-language integration. (Toronto Star)

Many MPs say their constituency offices now function like “immigration clinics,” with immigration files dominating caseloads (often 80–95%), because people can’t get answers through IRCC’s regular channels. Analysts attribute this to the 2012 service changes, which closed 19 local offices and redirected inquiries to a call centre and web portal. As of 2018, only 22% of the 1.7 million calls were answered by an agent, leaving MPs to handle complex cases. (Canadian Affairs)

Program Delivery & Immigration Highlights

Canada is pivoting from growth to stabilization: PR targets hold near 380,000 for 2026–2028 with a bigger economic share and more selection via PNPs, while Express Entry stays competitive. Two one-time transitions (in-Canada skilled workers and protected persons) sit outside the plan and could push actual landings higher. On the temporary side, inflows are trimmed (fewer new workers and students) to drive the TR population below 5% by 2027. Net effect: in-Canada talent and employers using PNP pathways are best positioned; overseas applicants face tighter competition and more scrutiny. (Source)

Quebec’s new plan for 2026 focuses on managing immigration at a pace that matches its capacity to integrate people in French. For 2026, the province aims for about 45,000 new permanent residents and 85,000–124,000 temporary admissions. The only skilled-worker route will be the Regular Skilled Worker Program (PSTQ); the PEQ streams end November 19, 2025, and three pilot programs will close on January 1, 2026. The pause on private (collective) refugee sponsorship is extended to December 31, 2029, and certain LMIA applications in Montréal/Laval remain paused to December 31, 2026. A new French rule will also roll in: after three years in Québec, foreign workers will need to show basic spoken French (level 4) to keep working, with checks starting December 17, 2028. (Source)

IRCC’s 2024 Express Entry fact sheet shows 468,073 profiles created (73% program-eligible), with 45% meeting category-based criteria; IRCC ran 52 draws and issued 98,903 ITAs, including 19 category-based rounds that produced 43,475 ITAs (43% of the total). CRS scores clustered in the 301–500 range and 91% of invitees held ≥3-year post-secondary credentials. Top invited occupations spanned tech and services (software engineers/designers, food service supervisors, software developers/programmers, administrative assistants, secondary-school teachers), with Ontario the leading destination, followed by B.C. and Alberta. Processing met the 6-month standard for CEC/FSWP, and PNP processing dropped from 7 to 6 months. Economic outcomes remained strong: for the 2017 cohort, median employment income rose from $58,700 (one year after landing) to $82,000 (five years). (Source)

IRCC introduced new operational guidance, effective January 31, 2025, that implements regulatory powers allowing officers to individually cancel temporary resident documents, eTAs, TRVs, work permits, and study permits on a case-by-case basis. Further instructions for serious inadmissibility scenarios will follow. (Source)

NWT will reopen its PNP intake on November 10, 2025, following the restoration of its full 300-nomination allocation for 2025. The updated guidelines remove limits on employer applications, lift work-permit expiry restrictions, and reinstate the prior one-year work-experience requirement. The intake closes November 24, 2025, with up to 103 applications processed based on urgency and then date received. (Source)

CBSA’s Pacific Region, as part of B.C.’s new RCMP-led Extortion Task Force, has launched immigration investigations into 78 foreign nationals and removed three individuals linked to the probe; the 40-member task force coordinates across CBSA, RCMP, and multiple local police services, with CBSA emphasizing swift removals in organized-crime cases. (Source)

IRCC revised the countries that trigger an immigration medical exam (IME) for temporary residents. IMEs are now required if you’ve lived in or visited Argentina, Colombia, Uruguay, or Venezuela; they are no longer required for Armenia, Bosnia and Herzegovina, Iraq, Latvia, Lithuania, or Taiwan. These changes apply only to applications submitted on or after November 3, 2025 (Source)

IRCC revised the countries that trigger an immigration medical exam (IME) for temporary residents. IMEs are now required if you’ve lived in or visited Argentina, Colombia, Uruguay, or Venezuela; they are no longer required for Armenia, Bosnia and Herzegovina, Iraq, Latvia, Lithuania, or Taiwan. These changes apply only to applications submitted on or after November 3, 2025 (Source)

IRCC added clarifications on: reusing PAL/TALs in the 2025 allocation period, joint programs, when to close files not accepted for processing, sample PAL/TAL formats, exceptions that also require an Organization/Entity ID, and what to do if the study-permit cap is met. (Source)

IRCC updated the Agri-Food Pilot guidance to address unclear and contradictory wording in the “Employment requirement” section and align it with the client-facing website. (Source)

IRCC marked National Francophone Immigration Week (Nov 3, 2025), thanked Francophone newcomers, noted progress toward the 8.5% target for French-speaking PRs outside Quebec, and pledged a new joint action plan with provinces to grow Francophone immigration. (Source)

IRCC extended the public policy for open work permits to December 31, 2025 for foreign nationals in a PNP expression-of-interest pool who are working in a province/territory and hold a provincial/territorial support letter (permits up to 2 years). Manitoba and Yukon participate via LOIs; Alberta has exited, but applicants there with support letters issued by Dec 31, 2024 remain eligible. (Source)

IRCC updated its operational guidance on restoring temporary resident status under IRPR R306 and R182, clarifying officer instructions, fee requirements, and processing language. (Source)

The definition of off-campus work has been updated to reflect regulatory changes to off-campus work hours for international students, increasing them from a maximum of 20 hours per week to 24 hours per week. (Source)

IRCC deleted the “Forms related to permanent residence” instruction page and now directs users to the general “Find an IRCC application package or form” page and the Permanent Resident Program instructions instead. (Source)

Recent Case Law

Issue: Whether refusals under the Start-Up Business Class (SUBC), based on a finding that an essential member’s primary purpose was to obtain status (IRPR 89(b)) and on concerns about venture seriousness/progress, were reasonable and procedurally fair; and whether derivative refusals of the remaining co-applicants could stand.

Facts: Four co-founders of “Deep Dent” (AI dental-analytics) applied under SUBC with a letter of support from a designated entity. After an initial ownership-structure PFL (cured), a second PFL raised IRPR 89(b) concerns tied to public-facing credibility: website errors/incompleteness, domain registration through a friend, inconsistent pricing across site/“/new” pages/pitch deck, thin client-engagement evidence, and low LinkedIn activity pre-PFL. The team filed an extended response with numerous appendices (product development, marketing plan, JV, IP, financing). The officer was not persuaded and refused the essential member under 89(b); the other three were refused by operation of the essential-member rule (IRPR 98.08(2)).

Applicants’ Arguments and the Court’s Disposition:

1. “Lack of seriousness” finding is unreasonable (para 5).

    • Argument: They surpassed SUBC’s “minimum requirements,” showing significant progress (especially after a founder arrived in Canada), so there was no basis to doubt seriousness.
    • Court’s response: Dismissed. The officer’s reasons were cogent and open on the record: continuing website defects (errors, sample/missing pages), inconsistent pricing between webpages and pitch deck, vague launch timing for the “new” site, scant pre-PFL LinkedIn activity, and weak corroboration of outreach/traction. It was reasonable to give little weight to post-PFL posting flurries and to documents with gaps (e.g., unsigned/undated agreements, JV signature page missing, non-provisional patent not filed, tax compliance not evidenced). The Court would not re-weigh.

 

2. Procedural fairness breach, no guidance on how to dispel IRPR 89 concerns (para 6).

      • Argument: Without clear guidance on the “test” for 89(b), they didn’t know the case to meet.
      • Court’s response: Dismissed. The second PFL spelled out the concerns with specificity (progress, website quality/ownership, LinkedIn engagement, client contact/marketing). Applicants received an extension and submitted a fulsome response. In this visa context (lower end of the fairness spectrum), the process was fair; the absence of ministerial “threshold” guidance does not make the assessment unfair where the PFL itself framed the case to meet.

 

3. Legitimate expectations, approval should follow because IRCC guidance lacks a threshold (para 7).

    • Argument: Program materials and guidance created an expectation of approval once a commitment and basic eligibility materials were provided.
    • Court’s response: Dismissed. Legitimate expectations cannot create substantive rights or a promise of approval. No clear, unambiguous representation guaranteed a result. The PFL made plain that primary-purpose/seriousness was in issue; the officer was entitled to assess the record against IRPA/IRPR.

 

Court Findings: The officer reasonably concluded that the essential member’s primary purpose was status-seeking rather than engaging in the committed business, given persistent credibility/progress gaps in public-facing and documentary evidence. The other three refusals, tied by regulation to the essential-member outcome, were also reasonable. No breach of procedural fairness; no legitimate expectations.

Outcome: Judicial review dismissed for all four applicants; no certified question.

Why This Case is Important:

  • IRPR 89(b) in practice: Public-facing credibility (website coherence/quality, consistent pricing, domain control), verifiable traction (client contact, executed Canadian agreements), and concrete IP/tax/finance steps weigh heavily.
  • PFL responses: Length is not persuasion, officers may discount reactive, cosmetic fixes or unsupported assertions.
  • Essential-member cascade: If the essential member fails 89(b), IRPR 98.08(2) can sink co-applicants.
  • Fairness & expectations: Detailed PFLs and time to respond typically satisfy fairness; program guides do not guarantee approval.

Issue: Whether a TRV refusal with a five-year misrepresentation bar and a linked Start Up Business Class work permit refusal were reasonable.

Facts: A PFL alleged that an employment letter had been altered. The applicant said the discrepancy arose from a clerical/printing mistake. The officer nevertheless found misrepresentation, refused the TRV with a bar, and also refused the SUV work permit.

Court Findings: On this record, the misrepresentation finding was not reasonably supported; the work-permit refusal could not stand once the primary finding fell.

Outcome: Judicial review granted; decisions set aside and remitted to a different officer.

Why This Case is Important: Shows close scrutiny of misrepresentation findings and confirms that derivative refusals collapse where the underlying determination is unsustainable.

Issue: Whether an officer reasonably refused an Express Entry application after removing “arranged employment” CRS points and whether there was any breach of procedural fairness.

Facts: The applicant claimed CRS points for arranged employment based on an employer letter. The officer found the letter did not clearly promise qualifying employment aligned to the PR grant, removed the points, and the score dropped below the cut-off. A later reconsideration request was refused separately.

Court Findings: The officer’s interpretation of the letter and the points rules was within the range of reasonable outcomes. The reasoning was coherent, and no fairness breach was established on the record before the Court.

Outcome: Application dismissed.

Why This Case is Important: Reinforces strict documentary requirements for arranged-employment points and confirms that a separate reconsideration outcome is not automatically before the Court unless specifically challenged.

Issue: Whether the IAD’s humanitarian and compassionate analysis, especially best interests of the child (BIOC), was reasonable.

Facts: The appellant faced removal. Children’s circumstances and potential relocation were central. The IAD dismissed the appeal.

Court Findings: The IAD did not meaningfully grapple with key child-focused evidence and failed to adequately explain the balancing, rendering the decision unreasonable.

Outcome: Judicial review granted; remitted for redetermination.

Why This Case is Important: Emphasizes robust, child-centred reasoning in H&C removal appeals and the need to link evidence to conclusions.

Issue: Whether refusal of an Express Entry PR application for lack of proof of qualifying work experience was reasonable and procedurally fair.

Facts: The applicant relied on skilled work abroad but did not provide adequate duties evidence with the application. The officer refused without seeking further information; a later reconsideration was pursued separately.

Court Findings: It was reasonable to conclude the statutory criteria were unmet. No duty arose to invite the applicant to “fix” the record before refusing.

Outcome: Judicial review dismissed.

Why This Case is Important: Confirms applicants must submit clear duties evidence up front; officers may refuse where core requirements are not met on the filed record.

Issue: Whether refusal of an H&C PR application for an elderly caregiver was reasonable, particularly in the BIOC analysis and treatment of children’s statements.

Facts: An 82-year-old grandmother living with and caring for Canadian grandchildren sought PR on H&C grounds. Prior judicial review had sent the matter back once already.

Court Findings: The decision gave cursory treatment to detailed statements by the children and failed to grapple with evidence going to their day-to-day interests; this was unreasonable.

Outcome: Judicial review granted; remitted to a different officer.

Why This Case is Important: Signals that child-authored evidence at the heart of BIOC must be specifically addressed; superficial treatment will not suffice.

Issue: Whether the RAD’s decision upholding an IFA and dismissing a refugee claim was reasonable.

Facts: The claimant’s case was rejected, with the RAD finding a viable internal flight alternative. The claimant challenged the RAD’s analysis.

Court Findings: The RAD’s reasoning met the required standard; no reviewable error was shown.

Outcome: Judicial review dismissed.

Why This Case is Important: Illustrates deference to adequately reasoned RAD IFA analyses that squarely address the evidentiary record.

Issue: Whether refusal of an Express Entry PR application based on concerns about genuineness of claimed work experience was reasonable.

Facts: The officer doubted the authenticity of the applicant’s overseas work history and refused PR.

Court Findings: The officer’s credibility findings were tied to the record and clearly explained; no fairness breach.

Outcome: Judicial review dismissed.

Why This Case is Important: Demonstrates deference to officers’ credibility assessments when reasons connect evidence to conclusions.

Issue: Whether refusal of a work-permit application based on qualification/role-fit concerns was reasonable.

Facts: The officer found the applicant’s profile did not meet the offered role’s requirements and refused the application.

Court Findings: The assessment and explanation were within the range of reasonable outcomes on the evidence.

Outcome: Judicial review dismissed.

Why This Case is Important: Confirms latitude for officers in assessing job-offer/qualification fit where reasons address the key discrepancies.

Issue: Whether cancelling TRVs and imposing a five-year misrepresentation barafter reopening a closed file and issuing fairness correspondence through a prior agent, was reasonable and procedurally fair.

Facts: TRVs were previously issued and the file closed. The office later reopened the matter, raised misrepresentation by PFL to an agent’s email, and imposed a five-year bar. The applicants’ response timing and notice were in dispute.

Court Findings: Procedural fairness was breached: reopening a concluded file with severe consequences required real notice and a meaningful chance to respond; that did not occur on these facts.

Outcome: Judicial review granted; set aside and remitted.

Why This Case is Important: Important guidance on fairness when reopening closed matters and proceeding to a s.40 finding; meaningful participation rights must be respected.

Latest Draws

manitoba express entry

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.

Contact Us

Get in touch

in**@*************ed.com

Click on the blurred section to reveal the full email address. 

Suite 2079 – 325 Front Street West, Toronto, ON, M5V 2Y1

Business hours
Monday to Friday: 9 a.m. to 5 p.m.
Saturdays:
Sundays: Closed

Find us on social media:

View our full Privacy Policy.

Subscribe to

ImmPulse Weekly