This article was authored by the CILA Board of Directors (2023/2024).
During the Summer of 2020, The Canadian Immigration Lawyer’s Association (CILA) welcomed Immigration, Refugees and Citizenship Canada’s (IRCC) policy response to COVID-19 pandemic closures and service disruptions at biometric collection locations across Canada. However, IRCC’s recent and unexpected announcement to resume biometrics collection for temporary residence applicants in Canada and enforce it the same day it was announced is disappointing to CILA and the interested community at large. Specifically, CILA is disheartened by IRCC’s lack of advance notice and consultation with interested stakeholders and the enforcement of policies on the same or subsequent day they are announced. This affects the level of client service expected by temporary residence applicants and their legal representatives, and further erodes trust in the Canadian immigration system.
CILA recognizes that all temporary policies introduced by IRCC will end at one point or another. Yet, when a policy response positively affects issues such as Immigration backlogs, discontinuing them without proper consultation or notice does not help decrease the Immigration backlog and allow temporary residence applicants that do not fall under the “special situation” category sufficient time to prepare and re-organize themselves to meet the tight timelines to book an appointment and update their application with proof of payment.
Moving forward, CILA wishes to see IRCC take a more collaborative approach in consulting and providing notice to stakeholders, including lawyers and special interest groups advocating for temporary residence applicants when rolling out policies that can cause further delays to processing times.