Canada’s immigration department has suspended an unspecified number of citizenship certificates it issued earlier this year under Bill C3, the ‘Lost Canadians’ legislation designed to restore citizenship to descendants of Canadians excluded under earlier laws, ordering recipients to return their certificates while authorities re-examine their files.
The Immigration, Refugees and Citizenship Canada (IRCC) department began sending physical and electronic notices last week, stating that it has information indicating recipients may not have been entitled to the certificates they received.
“The purpose of this letter is to inform you that I have information in my possession that indicates that you may not be entitled to hold a Canadian certificate of citizenship,” read the notices, signed by Peggy Sun, Registrar of Canadian Citizenship, according to multiple media reports and social media posts by affected individuals.
The letters cite a provision of Canada’s Citizenship Regulations that allows the Registrar to require surrender of a certificate when there is reason to believe the holder may not be entitled to it.
The notices informed recipients that they may submit additional documentary evidence, and that IRCC will return the certificate if the review confirms entitlement.
Who Is Affected
Between December 15, 2025 and March 31, 2026, IRCC issued 4,075 citizenship certificates under the new descent rules. Nearly half, 1,955, went to US-born applicants.
The exact number of suspension letters sent is not yet known, though some immigration lawyers, speaking to various news outlets, estimate that at least several hundred recipients have been affected; IRCC has not publicly confirmed the number.
Some recipients had already relocated to Canada or were in the process of doing so when they received the notice last week, leaving them in legal limbo.
The notices don’t amount to a citizenship revocation; a formal revocation of citizenship under Canada’s Citizenship Act is a separate legal process that applies when citizenship was obtained through fraud, false representation, or the knowing concealment of material circumstances.
The current letters do not allege fraud but rather allege that the documentation submitted did not meet IRCC’s evidentiary standards.
Why Some Certificates Were Flagged
The surrender letters identify two specific documentation failures: the submitted documents were not from an original source authority, and, when original source documents were unavailable, the applicant did not include a written explanation of why those documents could not be obtained and of the efforts they made to locate them.
In practice, IRCC flagged applications whose ancestral chains were built primarily on records from unofficial genealogy platforms that digitize and index millions of historical records. The records such platforms provide are not the same as certified copies issued directly by the civil registrar that originally created the document.
The suspension may sit uneasily with IRCC’s published guidance, which leaves the door open to “any other evidence” demonstrating a parent’s Canadian citizenship beyond official sources.
Federal Court precedent may provide a legal basis to contest this development. In a recent case, Somers-Edgar v. Canada, the court found that the burden falls on IRCC to clearly articulate its requirements. As such, if the department intended to restrict proof of lineage to specific civil registries, it was legally obligated to explicitly state that limitation on its forms.
“Lost Canadians”
Slava Apel, of CanadaRBI, says this move “is in alignment with the changes around the world where the Canadian minister is moving towards the sentiment that the ‘lost Canadians’ must prove a link to Canada in each generation.”
While he anticipates that “the majority of the ‘lost Canadians’ are applying from the USA, one must also take a look at the lack of benefits. Having both US and Canadian passports exposes one to more taxation instead of less, dual reporting, and potentially exit tax from the USA if they’re moving to Canada.”
He supports the right of the lost Canadians to regain access, “but in a measured way where everyone gets a fair assessment. This was not a blanket action that everyone who has received the certificate will have it revoked or have had it revoked. As the new information comes out about the individuals, inadmissibility issues may have something to do with the revocation, i.e., a member of a terrorist group.”
The Long Road to Bill C3
Bill C3 became law in December 2025 as a remedy for a multigenerational legal problem. It describes Lost Canadians as individuals who believed themselves to be Canadian citizens or entitled to citizenship but were not officially recognized as citizens due to particular, often obscure, aspects of Canadian nationality law.
Although these individuals may have already had strong connections to Canada, they were either never citizens throughout their lives, or had Canadian citizenship and lost it unknowingly under certain provisions of the Citizenship Act.
In many cases, Lost Canadians were unaware that they were not citizens, or that they had lost their citizenship, until they applied for government pensions, sought healthcare, or applied for passports.
Canada made its first legislative attempt at a remedy in 2008. Bill C37, which received Royal Assent in April 2008, amended the Citizenship Act to grant Canadian citizenship to those who lost or never had it under certain provisions of existing and former legislation.
That law, however, introduced a first-generation limit: citizenship by descent could only pass to one generation born outside Canada. Children of that first generation, if also born abroad, were excluded.
In 2023, the Ontario Superior Court of Justice ruled that the first-generation limit on citizenship by descent was unconstitutional, requiring Parliament to amend the Citizenship Act. This paved the way for Bill C3, which came into force on December 15, 2025, removing the first-generation limit on citizenship by descent.
The change opened citizenship eligibility to potentially millions of people worldwide with Canadian ancestry, particularly Americans with French-Canadian or Maritime roots.
Under the law, applicants under Bill C3 are not applying for citizenship, but rather applying for proof of citizenship for a status that the law recognizes they have held since birth, thereby making it automatic and retroactive.
That distinction might shape how affected recipients contest the suspension. Whether IRCC can revoke citizenship certificates on documentary grounds after having already approved the underlying file could emerge as the central legal question courts would ultimately need to resolve.
