Bill C-12 Is Now Law: Every Immigration Change Explained (2026)

On March 26, 2026, Bill C-12 — the Strengthening Canada's Immigration System and Borders Act (S.C. 2026, c. 4) — received Royal Assent and became law. Most provisions came into force the same day.

There has been considerable confusion about what Bill C-12 actually does. Some coverage has reduced it to an "application prioritization" tool. That is incomplete. The bill touches asylum, document cancellation, information sharing, border enforcement, and parliamentary oversight. Some provisions are in force now. Others require regulations that have not yet been published.

Need to understand how these changes affect your specific situation? Book a consultation with our team.

What Bill C-12 Actually Is

Bill C-12 is a 12-part omnibus statute. Not every part is about immigration. This analysis covers the parts that affect immigration applicants, permanent residents, temporary residents, asylum claimants, and employers:

Parts covering drugs, anti-money laundering, and non-immigration criminal law are not discussed here.

The Changes That Affect You: A Plain-Language Table

The table below simplifies the key changes. For the full statutory references and effective dates, see the detailed breakdown that follows.

Detailed Breakdown by Applicant Type

If You Have a Pending Asylum Claim

Bill C-12's most significant changes are to the asylum system. Here is what you need to know:

The one-year bar (new s. 101(1)(b.1)): If you entered Canada after June 24, 2020 and made your claim more than one year after your entry, your claim is now ineligible for referral to the RPD. If you entered Canada more than once, the clock starts from the day after your first entry. This applies retroactively to claims made on or after June 3, 2025 (per the IRCC backgrounder).

You still have access to PRRA. The IRCC backgrounder confirms that claimants found ineligible under the new grounds can still apply for a Pre-Removal Risk Assessment under IRPA s. 112. PRRA is not a full hearing, but it does assess risk of persecution, torture, and cruel treatment.

Do not leave Canada during your case. Under new s. 104.1, if you leave Canada while your RPD or RAD case is active, the tribunal must suspend consideration. If you voluntarily return to the country you claimed protection from, the RPD must declare your claim abandoned. This is mandatory — the tribunal has no discretion.

Withdrawal is now an immediate removal trigger. If the Minister determines your claim has been withdrawn (based on your written notice of withdrawal), a removal order takes effect the same day unless you file for judicial review. A 12-month PRRA bar also applies.

The DCO regime is gone. The Designated Country of Origin system has been repealed. Your country of origin no longer affects your appeal rights or processing timelines. This is a positive change for claimants from formerly designated countries.

Monthly reporting starts. The Minister must now publish monthly reports on removal orders — including how many were enforced, how many were not, reasons for delays, and demographic breakdowns. These reports are tabled in Parliament.

Parts of the asylum overhaul are not yet in force. Several provisions in Part 6 — including the new front-loaded intake process (s. 100), the pre-referral abandonment mechanism (s. 102.1), and the ministerial pre-referral withdrawal power (s. 102.2) — come into force on a date to be set by Cabinet order. When these take effect, the RPD will only receive files that are fully documented and "schedule-ready." If you fail to provide required documents or appear for examination, your claim can be transmitted to the RPD for an abandonment determination before it is even referred.

What to do:

1. If you have an active claim, do not travel outside Canada
2. Ensure your file is complete — missing documents will have more serious consequences once the front-loaded intake provisions come into force
3. If you entered Canada more than a year ago and have not yet claimed, seek legal advice immediately
4. If you are considering withdrawing your claim, understand that this now triggers a removal order

Book a consultation if you have questions about how these changes affect your asylum claim.

If You Hold a Work Permit, Study Permit, TRV, or eTA

Cabinet can now cancel or suspend groups of documents. Under new ss. 87.301-87.305, the Governor in Council can order that groups of visas, permits, eTAs, TRPs, or PR cards be cancelled, suspended, or varied. This power is limited to five grounds: administrative errors, fraud, public health, public safety, or national security.

Important safeguards:

• Orders affecting people inside Canada require the recommendation of the IRCC Minister with the concurrence of the Minister of Public Safety
• Every order must be tabled in Parliament within 7 sitting days, with reasons, the number of documents affected, and a description of affected persons
• The Minister must appear before a parliamentary committee to explain the order if requested
• The variation power cannot grant PR status or grant/extend work or study permits
• Orders must be published in the Canada Gazette within 23 days
• The IRCC backgrounder confirms asylum claims are outside this Part

Individual cancellation power (new s. 20.01): Officers can also cancel, suspend, or vary individual visas and documents in "prescribed circumstances" — but those circumstances have not yet been defined in regulations. This power cannot be used to grant PR status.

Overseas re-examination (new ss. 32.1-32.2): If you hold a Canadian immigration document while outside Canada, you may be required to answer questions, produce documents, and attend examinations (including medical exams) to confirm you remain admissible or eligible. The specific circumstances triggering this obligation will be set by regulation.

What this means practically:

• Your individual permit or visa is not at immediate risk unless it was obtained through fraud or there is a public safety/health/national security concern
• If Cabinet does issue a group order, it will be public — published in the Gazette and tabled in Parliament
• If you are outside Canada, be prepared for the possibility of compliance checks once regulations are made

If You Are a Permanent Resident

Admissibility hearings require physical presence. Under new s. 44.1, the Immigration Division cannot hold an admissibility hearing if you are not physically present in Canada. If you are a PR facing a residency obligation report under s. 44 and you are outside Canada, you must return to Canada before the hearing can proceed.

Group document orders can affect PR cards and PR visas. The Cabinet cancellation/variation power under s. 87.302 explicitly lists PR cards and PR visas among the documents that can be affected. The same five grounds and parliamentary safeguards apply.

If You Are an Employer Sponsoring Workers

No direct changes to LMIA requirements. Bill C-12 does not amend the LMIA process, employer-specific work permit rules, or the Global Talent Stream.

Indirect effects to be aware of:

• If Cabinet exercises the power to suspend or terminate groups of work permit applications (on the five enumerated grounds), your sponsored workers could be affected
• The new information-sharing framework means IRCC can now share status and document information with other federal and provincial bodies under written agreements — this could affect compliance verification

Information Sharing: What IRCC Can Now Share

This is a structural change that affects everyone in the immigration system.

Within IRCC (new s. 5.4): The Minister can now share personal information within the department for any purpose related to exercising their powers and duties.

With federal and provincial partners (new s. 5.5): Under written agreements that specify the purpose, limits on secondary use, and transfer restrictions, the Minister can share:

• Identity information
• Status in Canada
• Contents or status of any document issued by the Minister (issuance, renewal, validity, cancellation, revocation, suspension, etc.)

Provincial safeguard: Provincial recipients cannot share this information with foreign entities without the Minister's written consent and compliance with the Avoiding Complicity in Mistreatment by Foreign Entities Act.

Privacy safeguard: The IRCC backgrounder confirms that a Privacy Impact Assessment must be completed for any new use of personal information within IRCC.

What this means: Expect faster cross-department and cross-province detection of inconsistencies in applications. If your status, identity, or document information in one system does not match another, it is more likely to be flagged.

What Is NOT Yet in Force

Several provisions have been enacted but will only come into force when Cabinet sets a date by order. These are primarily the front-loaded asylum intake provisions:

When these provisions come into force, the asylum intake process will change fundamentally — only fully documented, "schedule-ready" files will reach the RPD.

The Five-Year Review

Section 138 requires a comprehensive parliamentary review of the entire Act starting in 2031. A designated Senate, House, or joint committee must submit a report within 12 months recommending changes.

Separately, section 75.1 requires a specific review of the one-year asylum bar (s. 101(1)(b.1)) at the start of the fifth year. That report must include:

• Average days between entry and claim, broken down by document type
• Number of claimants found ineligible under the one-year bar
• Proportion who exited and re-entered after their first entry date
• Number who applied for PRRA, and how many were allowed or denied
• Recommendations

These reviews are concrete opportunities for counsel, advocacy groups, and stakeholders to provide input.

Common Misconceptions

"Bill C-12 is just about application prioritization." No. Application categorization is one part (Part 7). The bill also overhauls asylum eligibility (Parts 6 and 8), creates a statutory information-sharing framework (Part 5), expands border inspection authority (Part 1), and gives the Coast Guard an intelligence mandate (Part 4).

"My eligibility hasn't changed." For Express Entry, PNP, study permits, and most work permit applicants, this is true — the eligibility criteria for these programs are unchanged. But for asylum claimants, new ineligibility grounds have been added. And for all document holders, Cabinet now has power to cancel, suspend, or vary groups of documents on specific grounds.

"I should wait to see what happens before applying." For most non-asylum applicants, applying sooner is still better. The group cancellation powers are limited to five specific grounds (fraud, administrative errors, public health, public safety, national security) and require parliamentary reporting. Routine applications are not the target.

"This only affects asylum seekers." The asylum changes are the most dramatic, but the document cancellation powers, information-sharing framework, and overseas compliance checks affect all immigration streams.

What You Should Do Now

• ‍If you have an active asylum claim: Do not travel outside Canada. Ensure your file is complete. If you entered more than a year ago and have not claimed, seek legal advice immediately.‍
• If you hold a work permit, study permit, TRV, or eTA: Your document is not at immediate risk. Monitor the Canada Gazette for any group orders. Ensure your application was accurate and complete.‍
• If you are a permanent resident abroad: Be aware that admissibility hearings now require physical presence in Canada. If you have a residency obligation concern, plan accordingly.‍
• If you are planning to apply: For most programs, eligibility criteria are unchanged. Apply when you are ready with a complete, accurate application.‍
• For everyone: The information-sharing provisions mean consistency across your immigration history matters more than ever. Ensure all your documents and applications tell the same story.

Have questions about how Bill C-12 affects your specific situation? Contact us at help@leromlaw.com or call +1-416-915-0808. You can also book a consultation to discuss your case.