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Bill C-3 came into force in December 15, 2025 and Canadian citizenship by descent has since expanded beyond the former first-generation limit. Whilst this expanded framework has created significant new opportunities for thousands of individuals who may have Canadian lineage, born or adopted outside of Canada, recent developments have also demonstrated that obtaining Canadian citizenship by ancestry is no longer simply a matter of proving a distant family connection.
In recent months, Immigration, Refugees and Citizenship Canada (“IRCC”) has introduced important changes to the documentary requirements for proof of citizenship applications, suspended and reissued dozens of citizenship certificates that were already issued under the new legislation and revised its guidance regarding acceptable documentary proof.
For prospective applicants, particularly those tracing family history across several generations or multiple countries, these changes reinforce that careful preparation of documentary evidence is now one of the most critical aspects of a successful Canadian citizenship by descent application.
Background and Context of Bill C-3
Canada’s Citizenship Act has long imposed a strict first-generation limit on citizenship by descent, preventing many individuals born abroad from inheriting Canadian citizenship despite having genuine family ties to Canada.
Following the Ontario Superior Court’s ruling that the first-generation limit was unconstitutional in Bjorkquist et al. v. Attorney General of Canada, Bill C-3 was passed to replace the former framework with a substantially broader citizenship by ancestry regime. Individuals previously affected who could not inherit citizenship because of geography or the timing of their birth became commonly known as “Lost Canadians.”
Bill C-3 amended the Citizenship Act to address many of these historical exclusions. The amendments came into force on December 15, 2025 and allowed citizenship to be restored to many people born before that date who would have been Canadian citizens but for the first-generation limit or other outdated provisions of the legislation. These amendments generally operate both retrospectively and prospectively.
Broadly speaking, Bill C‑3 restored citizenship to individuals previously excluded by historical provisions, removed the first‑generation limit for many people born to or adopted by Canadian citizens before December 15, 2025, and expanded citizenship opportunities for internationally adopted persons and their descendants.
At the same time, the legislation introduced a new framework for future generations born or adopted after December 15, 2025. Under this new framework, Canadian parents who themselves were born abroad may be required to demonstrate a substantial connection to Canada before citizenship can pass to the next generation. In most cases, this means the Canadian parent must have accumulated at least 1,095 days (approximately three years) of physical presence in Canada before the child’s birth or adoption. The same principle applies to many future adoption cases involving Canadian parents born abroad.
Notably, these changes do not affect Canadians who are first‑generation born abroad, such as children born outside Canada to a Canadian‑born or naturalized parent. These individuals remain automatic citizens and are not required to demonstrate their Canadian citizen parents’ substantial connection to Canada.
Rising Processing Times
With the expansion of citizenship eligibility, the substantial increase in proof of citizenship applications comes with no surprise.
As of May 2026, approximately 70,400 proof of citizenship applications were reportedly awaiting decisions, with an estimated processing time of 12 months. By June, the inventory had reportedly grown to approximately 82,000 applications and the estimated processing time had increased to 15 months.
As of July 7, 2026, this queue had reached approximately 99,500 applications, representing an increase of approximately 17,500 applicants within one month. IRCC’s estimated processing time had correspondingly risen to approximately 19 months.
That said, IRCC’s processing-time estimate is dynamic and may increase or decrease as application volumes, staffing levels, operational priorities, and the complexity of pending cases change.
In most cases, simply waiting may not produce a shorter overall timeline as IRCC’s estimate is influenced by the volume of applications already in the queue and the number expected to be received, and an applicant who delays filing may later enter an even larger inventory.
Nevertheless, applicants should not rush to submit an incomplete or poorly documented application merely to obtain an earlier place in line. Applications that are not properly supported may risk being returned as incomplete, experience significant processing delays, or, ultimately, be refused where the applicant is unable to establish their proper chain of Canadian lineage.
Tightened Documentation Requirements
As processing volumes have grown, IRCC has also taken steps to clarify and tighten its documentary expectations. One of the most significant recent developments has been IRCC updating of its public guidance, including its “Apply for a Canadian Citizenship Certificate” webpage and the Proof of Citizenship Document Checklist (Form CIT 0014), to provide clearer instructions regarding the documentary evidence expected from applicants, clarifying that documents proving Canadian descent should generally originate directly from the government authority that originally created and maintains the record.
This means that birth certificates, marriage certificates, death certificates, adoption records, and other civil status documents should ordinarily be obtained as colour copies issued by:
- the relevant civil registry;
- a provincial or territorial vital statistics office;
- a national registry authority; or
- another official government body responsible for maintaining the original records.
Importantly, documents printed from genealogy databases or subscription websites, including widely used platforms such as Ancestry.com or FamilySearch is not considered sufficient to independently establish an applicant’s chain of descent.
Although these resources remain extremely valuable for locating historical records and identifying family relationships, they generally serve as research tools rather than primary documentary evidence for citizenship purposes.
For many applicants, records that may have been used as supporting evidence must now often be replaced by colour copies of official civil documents issued directly by the original record authority.
Citizenship Certificates Recently Suspended and Reissued
In June 2026, IRCC conducted a review of approximately 6,500 proof of citizenship applications approved under Bill C-3. Following the review, IRCC acknowledged that guidance on acceptable documentation was unclear and subsequently suspended 67 citizenship certificates that were issued with potentially insufficient supporting evidence.
This development highlights that while Bill C‑3 opens the door for many individuals to reclaim Canadian citizenship by descent, the evidentiary standards under Canadian nationality law remain complex, technical, and continually evolving. IRCC has now applied heightened diligence to all existing applications, and the June 2026 review demonstrates that even approved cases can be revisited if the documentation does not meet IRCC’s tightened standards.
Importance of Source Documents in proving Canadian lineage
IRCC’s emphasis on original-source documentation has reflected that Canadian citizenship applications must be supported by reliable and verifiable government records. Yet, for many families, especially those whose Canadian ancestors emigrated decades ago, reconstructing a complete evidentiary record can be challenging. In some cases, civil registration systems in the ancestor’s country of birth were not fully developed, meaning official birth or marriage records may be missing, incomplete, or never formally issued. Historical archives may also have been relocated, or destroyed due to wars, political transitions, or administrative reforms, making it difficult to trace original documents.
Compounding these challenges, an ancestor’s name may appear differently across various records, with altered spellings or inconsistent transliterations that complicate efforts to establish a clear lineage. Foreign civil‑status systems also differ significantly from Canadian standards, and matching records across jurisdictions often requires specialized knowledge of archival practices, historical naming conventions, and local record‑keeping norms.
Given these complexities, applicants often need more than the documents already in their possession. They may need to locate certified records from original issuing authorities, reconcile discrepancies across generations, and demonstrate continuity of lineage despite gaps or inconsistencies.
How Harvey Law Group Can Help
At Harvey Law Group, our team of Canadian immigration lawyers possesses extensive experience and expertise in Canadian citizenship by descent matters, including cases involving complex multi‑generation documentation. We review each client’s available records carefully, identify gaps or inconsistencies that may affect the application, and provide guidance on how to strengthen the evidentiary chain in line with IRCC’s current expectations.
Since many applications require documents issued decades ago or maintained civil‑status in foreign countries, we work closely with genealogical specialists who understand how to navigate international registries and archival practices. Their expertise helps applicants obtain certified records from original issuing authorities and reconstruct a clear, verifiable documentary history across generations.
By combining legal analysis with genealogical support, we help applicants present a coherent and well‑substantiated lineage, ensuring that the documentation submitted aligns with IRCC’s tightened standards and reduces the risk of delays or refusals.
If you are interested in exploring whether you may qualify for Canadian citizenship by descent, please contact us at contact@harveylawcorporation to arrange a free consultation. We can assess your circumstances, discuss the documentation you may need, and help determine the most appropriate next steps based on IRCC’s current requirements.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
