IRCC Finally Gives Answers on Bill C-3 Canadian Citizenship-by-Descent Fiasco

The department now says unclear guidance on acceptable documentation may have contributed to some citizenship certificates being issued without enough evidence.

In the June 30 update, IRCC said it initially identified 100 citizenship certificates issued under Bill C-3 where supporting documentation may have been insufficient. The department then expanded its review to approximately 6,500 citizenship-by-descent applications received under the new law. That review is now complete.

According to IRCC, 33 of the 100 identified citizenship certificates have been automatically reinstated after the department confirmed the applicants met the legal requirements for Canadian citizenship by descent.

The remaining 67 cases are still outstanding, and IRCC says it is contacting those clients directly to confirm their eligibility for a citizenship certificate under C-3, or where needed, ask for additional information to validate their eligibility. The department expects that process to be completed in a matter of days.

These 67 outstanding cases represent roughly one percent of total certificates issued under Bill C-3 to date, according to the department.

The department has “reinforced guidance” to officers and provided clearer information for applicants about what documentation is required.

What Happened with Bill C-3 Citizenship Certificates?

Bill C-3 came into effect on December 15, 2025. The law changed Canada’s citizenship-by-descent rules by removing the first-generation limit in some situations.

Before Bill C-3, Canadian citizenship by descent was usually limited to the first generation born outside Canada. That meant a Canadian citizen could generally pass citizenship to a child born abroad only if the Canadian parent was born or naturalized in Canada.

Bill C-3 expanded access to citizenship for many people born before December 15, 2025, including some descendants of “Lost Canadians” and people born abroad in the second or later generation before the law came into force.

For many people with Canadian parents, grandparents, great-grandparents, or earlier direct Canadian ancestors, the change opened a path to apply for a citizenship certificate as proof of Canadian citizenship.

Interest surged quickly, especially among Americans with Canadian ancestry. For applicants who qualify, citizenship by descent is not a points-based immigration program, so it doesn’t depend on an Express Entry draw, job offer, work permit, or employer sponsorship. It is recognition of citizenship that may already exist under Canadian law. For those who meet the requirements, it forms the easiest and fastest possible pathway to gaining Canadian citizenship.

Or, at least, it should have been easy and fast.

But – in June, some people who had already received citizenship certificates under the new rules were told by IRCC that their citizenship status was under review. Some were asked to return their citizenship certificates while IRCC reviewed whether they were entitled to them.

The letters caused alarm because these were not pending applicants waiting for a decision. These were people who had already been assessed, approved, and issued proof of Canadian citizenship. Some had applied for Canadian passports or made plans to relocate to Canada, so this abrupt U-turn by IRCC disrupted lives.

Why Were Some People Asked to Return Citizenship Certificates?

IRCC says a routine review in early June identified 100 citizenship certificates issued under Bill C-3 where the supporting documentation may not have been sufficient.

Those certificates were temporarily suspended while IRCC reviewed whether the applicants had provided enough evidence to establish entitlement to Canadian citizenship by descent.

In some cases, IRCC said this included reviewing documentation from “open sources.”

The review was then expanded to approximately 6,500 applications received under Bill C-3 “out of an abundance of caution and to ensure the consistent assessment of eligibility.”

This is a significant update because, until now, it was unclear how many people were affected and what had triggered the situation. Earlier reporting had confirmed that some applicants were being asked to return certificates, but the government had not clearly explained why the documents had been issued in the first place if IRCC later believed there may not have been enough evidence.

That question is not fully answered, but IRCC has now revealed unclear guidance was a key element.

What IRCC Says Went Wrong

IRCC now says guidance on acceptable documentation was unclear for both officers and applicants. That matters because citizenship-by-descent applications can involve complex family records, especially where the claim depends on older birth, marriage, adoption, name change, church, court, or archival records. In some cases, applicants may be tracing citizenship through multiple generations and across more than one country.

Moving2Canada previously reported that some applicants were notified that the documents they provided in their applications did not come from the original source authorities responsible for creating or maintaining records. This typically includes civil registries, vital statistics offices, provincial archives, courts, and other official bodies. The concern was that some applicants may have relied on alternative records or genealogy documents to support their claim.

IRCC’s new update suggests the problem was not limited to applicants misunderstanding the rules. The department is now acknowledging that guidance for officers and applicants was unclear.

This helps explain why some people may have received citizenship certificates, only to be told later that their files required more review. The document checklist for proof of citizenship applications has since been updated.

What Happens to the 67 Outstanding Cases?

IRCC says it is now taking next steps with the 67 outstanding cases. The department says it will either confirm the applicant’s eligibility for a citizenship certificate under Bill C-3 or ask for more information to validate eligibility for citizenship by descent.

IRCC says this process is expected to be complete within “a matter of days,” so applicants shouldn’t have to wait much longer to get an answer.

Applicants who are affected should wait for direct communication from IRCC. Those who are not contacted by IRCC do not need to take action at this time.

Does This Mean Bill C-3 Had Changed?

No. All amendments to the Citizenship Act from Bill C-3 remain in effect.

The June 30 update is about how IRCC reviewed some citizenship certificate applications under the new law. It does not reverse or change Bill C-3 and the new citizenship by descent rules. People who believe they became Canadian citizens because of Bill C-3 can apply for a citizenship certificate to find out for sure.

What Should Applicants Do Now?

If you already received a citizenship certificate under Bill C-3 and have not heard from IRCC, you do not need to do anything at this time.

If IRCC contacts you directly, read the request carefully and respond by the deadline. If the department asks for more evidence, the strongest approach is likely to provide official source documents wherever possible.

That may include birth certificates, marriage records, adoption records, legal name change documents, court records, citizenship records, or archival documents from the authority that created or maintains the record.

If a document cannot be obtained, applicants should be prepared to explain why and show evidence of attempts to obtain it. This could include correspondence with archives, civil registries, vital statistics agencies, churches, courts, or other issuing authorities.

Applicants with older or complicated family lines, especially those involving pre-1947 issues, maternal lines, adoption, name changes, or missing records, may want to speak with a regulated Canadian immigration consultant before responding to IRCC.

What Questions Remain in the Bill C-3 Fiasco?

IRCC’s update provides some important information, but several questions remain. It is still not clear why the guidance was unclear when Bill C-3 represented such a major change to Canadian citizenship law. It is also not clear why some people were issued citizenship certificates before those documentation concerns were resolved.

The government has not fully explained why affected applicants were left in uncertainty before a public explanation was provided.

Prime Minister Mark Carney said last week that people who were told to surrender proof of citizenship deserved answers. IRCC has now provided some of those answers, but the situation has still raised serious questions about communication and confidence in the proof-of-citizenship process, and in immigration processing more broadly.

For applicants, the key takeaway is that all amendments to the Citizenship Act from Bill C-3 remain in effect and the vast majority of certificates issued under the new law have not been affected by the review.

For IRCC, the challenge now is rebuilding trust after a rollout that left some recently recognized Canadians lacking confidence in the immigration department of their new government. And – left others navigating the immigration process with an understandable doubt in IRCC’s administrative capacities.