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CILA offers recommendations on how IRCC can improve its PR portals

By CILA on December 1, 2021

The past two years have seen the introduction of several new Immigration Refugees and Citizenship Canada (IRCC) Portals.

These include the Permanent Residence Portal, the Citizenship Portal, the TR to PR Pathway Portal, the Refugee Portal and the IRCC Portal for TRVs and Study Permits. These portals were created in large part to address the many systemic issues with the antiquated IRCC Secure Account (formerly called “MyCIC”), the Authorized Representative Portal and the Employer Portal. Though these new portals are an improvement over the still existing old portals, they have been introduced without sufficient testing or user feedback, resulting in a new set of headaches for applicants. 

Lets consider the issues with the new Permanent Residence Portal.

In-Canada applicants are now supposed to be landed as permanent residents using the Permanent Residence Portal. The portal requires that applicants confirm that they are in Canada, a requirement for being landed. Some applicants have then been forced to wait weeks or months between the time they confirm their location in Canada and the time when their signed Confirmation of Permanent Residence document (eCOPR) is issued. IRCC has advised that if an applicant leaves Canada prior to issuance of the eCOPR this will place their landing on hold. This effectively leaves applicants hostage in Canada until their landing is completed. If their status is about the expire, it also necessitates that they apply to extend their status. This is not the best use of everyone’s time, including IRCC’s already overextended resources.

Many applicants complain that the electronically issued and signed eCOPRs are being issued with errors. IRCC has advised that applicants should not use eCOPRs with errors to apply for a permanent SIN or provincial health insurance. They advise that applicants should submit an Application to Amend their eCOPR. Current processing times for an Application to Amend are listed as 6 months. This is unrealistic for applicants who require provincial health insurance or who need to advise Service Canada of their new status for a new permanent SIN. Applicants become permanent residents once their eCOPRs are signed. Errors on the part of IRCC in issuing eCOPRs should not affect their new status. IRCC’s stance on requiring an amended eCOPR to apply for a SIN or provincial health insurance is unreasonable. IRCC has stated that they are looking into this issue but no solution has been provided to date. 

Though PR cards for some applicants landed via the Permanent Residence Portal are being issued in large part much faster than for those applicants landed by e-mail, many families are receiving PR cards for only some family members and not others. Sometimes they are being told that the PR cards were sent to the wrong address, though the correct address was listed in the portal. Applicants are also not able to list an address that the system perceives as a business address as their home address, even if it is their home address. Many applicants are having to wait over 9 months for their initial PR cards, unable to travel for fear of being denied re-entry to Canada. 

This is a nightmare for many applicants who have already been separated from their families overseas owing to the pandemic, border closures, travel restrictions, and prolonged processing times. A solution, even if only an interim solution, is needed before the holidays. PR Travel Documents are not a solution, as processing times are uncertain, and applicants can’t risk being stranded overseas unable to return.  

The Permanent Residence Portal is also where applicants can now file a whole series of immigration applications. Unfortunately, there is no user guide to explain the many practical issues with the new portal, including a character limitation which necessitates the use of creative (or nonsensical) abbreviations; a requirement for the inclusion of a national ID even when none exists; scans of professionally taken photos (though selfies are permitted for the purpose of landing); a size limitation of 4 MB on supporting documents; no way to print a summary of the online forms; a poor layout of the online forms; paper Document Checklists; and many issues creating accounts, logging in, and resetting passwords. The portal also does not allow an applicant to see their application once it has been submitted. 

The Permanent Residence Portal also does not allow In-Canada Spousal Sponsorship Applicants to simultaneously apply for an Open Work Permit. They must wait until a file number is generated and then file the work permit application online through their IRCC Secure Account, a different and separate portal. This means that they do not benefit from maintained status and will have to file an Application to Extend their status as a Visitor if they do not receive a file number and file an Open Work Permit application prior to the expiry of their status. This is in addition to their eventual Open Work Permit application. Again, this is a waste of time and IRCC’s resources.

Positives about the Permanent Residence Portal include the ability for Applicants to download the documents uploaded to double check that they are correct documents, the certainty that their application has been submitted and received by IRCC, and a relatively user-friendly experience. 

IRCC is on the right track with the new Permanent Residence Portal, but there are still many improvements to be made.

Here are CILA’s recommendations:

  • Allow PRs to be able to board flights to Canada with valid eCOPRs or the emailed IRCC Landing Letter;
  • Create an in-Canada PR Travel Document option with posted processing times;
  • Issue a multi-use PR Travel Document with the eCOPR that does not have to be affixed to a passport;
  • Allow applicant to approve COPR content before an officer signs it like the old in-person landing interview;
  • Provide a hotline and/or appointments at local IRCC offices to process amendments to COPR’s in-person;
  • Create a centralized webpage listing all IRCC Portals and which applications must be submitted through which portal;
  • Create a clear user guide on setting up portal accounts, linking accounts with representative portals, how to address the system issues with the new portals such as character limitations;
  • Offer contact information for Portal Tech Support;
  • Create a dashboard that allows applicants to monitor and/or link applications across multiple portals;
  • Offer the ability to select the correct Document Checklist for the type of Application and for only the required forms and supporting document categories to appear based on that specific type of Application; 
  • Provide the ability to view and print a Summary of all online forms; 
  • Create public resource and alternate application methods for applicants who are unable to access portals due to language and/or technology knowledge barrier. This is a disability and access to justice issue for less skilled applicants.