IRCC Begins Refusing PR Applications Over Cash-Paid Work

It appears IRCC may be tightening how it interprets “proof of paid work,” favouring documentation that shows traceable or auditable payment. This shift raises important questions about fairness, especially for applicants from countries where cash wages are still the norm, and formal payroll systems are less common. 

In this piece, we’ll unpack what’s happening, why it matters, and what it could mean for future PR applicants navigating this increasingly strict interpretation of proof of work. 

Key Takeaways:

• IRCC is refusing PR applications where work experience was paid in cash.

• Some refusals are issued without a Procedural Fairness Letter (PFL), denying applicants the chance to respond or clarify their evidence.

• The law doesn’t require electronic payment, only that work be paid, but IRCC appears to be interpreting “remuneration” as needing auditable records.

• Applicants from cash-based economies are most affected, as they often lack formal payroll or banking documentation.

• To reduce risk, applicants should proactively document cash income — deposit payments, gather receipts, and provide as much traceable evidence as possible.

The Claim

IRCC is tightening further screws on PR applications by refusing applications for failing to demonstrate remuneration for declared work experience.

Translation – IRCC is refusing PR applications with work experience with cash salary.

This is happening without PFLs. I am sure…

— Kubeir Kamal 🇨🇦🍁 (@AskKubeir) October 10, 2025

What’s Happening

Under most permanent residence programs, including Express Entry and the Provincial Nominee Programs, applicants must prove their work experience. Although the exact documents required can vary depending on the program, the primary document is usually a reference letter from the employer outlining job duties, duration, remuneration, and other key details. 

However, IRCC officers can, and often do, request additional evidence to verify employment if this documentation isn’t provided with the initial application. This can include pay slips, tax documents, or bank statements showing salary deposits. 

The issue arises when an applicant is paid in cash and therefore does not have digital or auditable records to back up their pay. In these cases, RCIC Kubier Kamal, suggests that IRCC is now refusing applications outright, often without issuing a Procedural Fairness Letter (PFL). That’s significant because a PFL usually gives applicants an opportunity to respond to concerns an officer has before they make a negative decision on your application.  

A PFL stems from the principle of procedural fairness, which holds that decision-makers have a legal obligation to make decisions in a procedurally fair and transparent manner. This includes: 

• The right to be heard – parties must have a reasonable opportunity to present their points of view, respond to facts presented by others, and have their arguments considered by the decision-maker. 

When a PFL is not issued, applicants are effectively denied this right to be heard. While this may provide grounds for relief through a judicial review claim, it is far from an ideal scenario, as the applicant must then challenge the decision after the fact, rather than having the opportunity to clarify or supplement their case beforehand. 

Why This Matters 

The Immigration Act and Regulations do not specify how someone must be paid for the work experience to be counted, only that the work was genuine and remunerated. Under Canada’s immigration regulations, work is defined as “an activity for which wages are paid or commission is earned.” 

So technically, whether payment was made by direct deposit, cheque, or cash shouldn’t matter, as long as the applicant can show they were compensated for their work. 

But in practice, IRCC’s new stance seems to interpret “remuneration” as something that must be traceable through official documents. This approach risks penalizing applicants from countries where cash payments are common and legitimate, and where digital banking or formal payroll systems don’t operate the same way they do in Canada. 

Adding to the problem, IRCC’s own guidance on supporting documents is vague. Take Express Entry, for example. Its official instructions on proof of work experience simply mention providing evidence, such as a reference or experience letter from an employer,. The guidance offers little clarity on acceptable alternatives or additional supporting documents. This lack of guidance causes complications for many applicants, particularly those who’ve been paid in cash or work in informal employment settings. 

What You Can Do to Avoid This

While there’s no guaranteed way to avoid refusal, applicants can take steps to strengthen their applications and reduce the risk of being caught in this new wave of refusals. 

If you’re paid in cash, make sure you’re documenting everything as clearly as possible. Whenever you receive payment, deposit the amount into your bank account right away so there’s a traceable record of income. Ask your employer to provide pay stubs or written receipts, even if they’re informal, and include these with your application. 

It’s also a good idea to submit detailed documentation upfront, rather than waiting for IRCC to request it. The more evidence you can provide, contracts, letters, tax filings, pay stubs, the less likely your work experience will be questioned later on. 

This issue is another example of how Canada’s immigration sometimes feel out of sync with modern realities. Many applicants are being held to documentation standards that don’t reflect how work and payment actually function in large parts of the world. 

And, ironically, Canada itself hasn’t fully modernized either. Cheques are still widely used here, something that continues to surprise me after 15 years. 

But for newcomers, who are often at the mercy of IRCC’s shifting standards and limited guidance, the best approach is to be proactive, detailed, and transparent. If you’re paid in cash, build a clear paper trail and include every piece of evidence you can. It might feel tedious, but in the current climate, it could make the difference between approval and refusal.  

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