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CILA condemns IRCC for including lawyers in new Administrative Penalties and Consequences (APC) system

CILA condemns IRCC’s decision to include immigration lawyers in its new Administrative Penalties and Consequences (APC) system.

On October 28, 2026, IRCC announced it would impose up to $1.5 million in penalties to licensed and unlicensed immigration representatives who break the law.

CILA opposes this policy since it fails to meet Treasury Board regulatory standards for evidence-based rule-making, ignores current sanctions under the Immigration and Refugee Protection Act (IRPA), and duplicates the rigorous oversight already enforced by provincial and territorial law societies.

Subjecting already heavily regulated lawyers to harsh fines, procedural disadvantages, and public shaming undermines the independence of the legal profession while threatening access to justice for vulnerable individuals in need of robust advocacy.

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