Canada’s immigration department has suspended an unspecified number of citizenship certificates issued under Bill C-3, the new citizenship-by-descent law for “Lost Canadians,” and has ordered some recipients to return their documents while their files are reviewed.
Immigration, Refugees and Citizenship Canada began sending physical and electronic notices last week stating that it had information indicating some recipients may not have been entitled to the certificates they received.
The notices were signed by Peggy Sun, Registrar of Canadian Citizenship, according to media reports and social media posts by affected individuals. They cited a provision of Canada’s Citizenship Regulations allowing the Registrar to require surrender of a citizenship certificate when there is reason to believe the holder may not be entitled to it.
Recipients were told they may submit additional documentary evidence. IRCC said the certificate will be returned if the review confirms entitlement.
Who may be affected
Between December 15, 2025 and March 31, 2026, IRCC issued 4,075 citizenship certificates under the new descent rules.
Nearly half of those certificates, 1,955, went to U.S.-born applicants.
The exact number of suspension letters is not known. Some immigration lawyers quoted by news outlets estimate that at least several hundred recipients may be affected, but IRCC has not publicly confirmed a number.
Some recipients had already moved to Canada, or were in the process of relocating, when they received the notices.
The notices do not amount to a formal citizenship revocation. Formal revocation under Canada’s Citizenship Act is a separate process that applies when citizenship was obtained through fraud, false representation, or knowing concealment of material circumstances.
The current letters do not allege fraud. They allege that the documentation submitted did not meet IRCC’s evidentiary standards.
Why certificates were flagged
The surrender letters identify two main documentation problems:
- The submitted documents were not from an original source authority;
- Where original source documents were unavailable, the applicant did not include a written explanation of why the documents could not be obtained and what efforts were made to locate them.
In practice, IRCC flagged applications where the ancestral chain relied mainly on records from unofficial genealogy platforms that digitize and index historical records. Those records are not the same as certified copies issued directly by the civil registrar or original authority that created the document.
The suspension may conflict with how some applicants understood IRCC’s published guidance, which allowed for “any other evidence” to show a parent’s Canadian citizenship beyond official sources.
The source also notes that Federal Court precedent may become relevant. In Somers-Edgar v. Canada, the court found that IRCC must clearly state its requirements. If IRCC intended to restrict proof of lineage to specific civil registries, the argument is that it should have stated that requirement clearly on its forms.
What Bill C-3 changed
Bill C-3 became law in December 2025 to address the situation of “Lost Canadians.”
Lost Canadians are people who believed they were Canadian citizens, or entitled to citizenship, but were not officially recognized because of earlier rules in Canadian nationality law. Some had strong connections to Canada but were never citizens, while others had Canadian citizenship and lost it unknowingly under certain provisions of the Citizenship Act.
In some cases, people only discovered the problem when applying for government pensions, healthcare, or passports.
Canada first tried to address the issue through Bill C-37, which received Royal Assent in April 2008. That law restored citizenship to some people who had lost it or never had it under older laws, but it also created a first-generation limit: citizenship by descent could pass only to the first generation born outside Canada. Children of that first generation, if also born abroad, were excluded.
In 2023, the Ontario Superior Court of Justice ruled that the first-generation limit on citizenship by descent was unconstitutional. Parliament was required to amend the Citizenship Act.
Bill C-3 came into force on December 15, 2025, removing the first-generation limit on citizenship by descent.
The change opened potential eligibility to millions of people worldwide with Canadian ancestry, especially Americans with French-Canadian or Maritime roots.
Why the legal distinction matters
Under Bill C-3, applicants are not applying to become citizens in the ordinary sense. They are applying for proof of citizenship for a status the law recognizes as having existed since birth.
That makes the status automatic and retroactive, according to the source article.
This distinction may shape any challenge by affected certificate holders. A central legal question may be whether IRCC can suspend or require return of citizenship certificates on documentary grounds after already approving the file.
Practical implications for applicants
The affected cases show that Canadian citizenship-by-descent applications under Bill C-3 may face strict evidence review, especially where the claim depends on older records across multiple generations.
Applicants should expect IRCC to scrutinize whether each link in the family chain is supported by official source documents.
A stronger file should include:
- Certified records from original issuing authorities where possible;
- Clear proof of each generation in the descent chain;
- Written explanations where original documents cannot be obtained;
- Evidence of efforts made to locate missing records;
- Careful treatment of genealogy website records, which may not be treated as equivalent to official civil records.
The issue is not whether Bill C-3 remains in force. The issue is whether the evidence submitted is enough to prove entitlement under the new citizenship-by-descent rules.
For people who already received certificates and then received surrender notices, the review process creates legal uncertainty but is not described as a formal citizenship revocation. For new applicants, the practical lesson is that files relying mainly on unofficial genealogy records may face higher risk of challenge or delay.
Source article: www.imidaily.com
