The Immigration Law Section of the Canadian Bar Association urges Immigration, Refugees and Citizenship Canada to address the serious and systemic issue of legal representative exclusion.

The problem, the Section says, “is particularly pronounced in recent program changes and policies related to the COVID-19 pandemic including implementation decisions and online filing procedures that did not appropriately build in a role for representatives.”

The Section’s submission lists several recent examples of exclusion of representatives in new digital platforms, including the initial versions of the online citizenship grant, permanent residence card renewal and other portals and platforms that do not allow representatives to submit applications on behalf of their clients. This is concerning for many reasons.
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