Bill C-3 Citizenship Changes Leave Permanent Resident Applicants in Limbo
Changes to Canadian citizenship law under Bill C-3 have caused Immigration, Refugees and Citizenship Canada to place permanent resident applications on hold for those who may qualify for citizenship. With citizenship certificate processing times reaching 34 months, affected applicants face extended delays and uncertainty.
Recent changes to Canadian citizenship law under Bill C-3, which makes individuals who can prove they have a Canadian ancestor eligible for citizenship, have left some permanent resident (PR) applicants facing significant delays. Immigration, Refugees and Citizenship Canada (IRCC) has quietly placed PR applications on hold for people who could qualify for citizenship under the new legislation.
Under IRCC policies, an individual cannot be both a permanent resident and a Canadian citizen at the same time. If someone applies for proof of citizenship while also applying for permanent residence, their PR application is placed on hold while the citizenship application is assessed. If citizenship is confirmed, the permanent residence application is considered withdrawn; if not, it returns to its original place in the queue. Additionally, an IRCC officer can put a PR application on hold even without a citizenship application if there are compelling reasons to believe the applicant is already a citizen.
Michel Pottier and his wife, Lindsey Jade Higgins, are among those navigating this administrative gap. The couple applied for spousal family class sponsorship in September 2025. After discovering she had a Canadian great-grandmother, Higgins applied for proof of citizenship by descent in October 2025. By September 2026, Pottier learned that his wife's permanent resident application had been put on hold because she might be eligible for citizenship.
The processing timelines compound the difficulty for couples like Pottier and Higgins. The wait time for family sponsorship of spouses outside Canada is currently 18 months, whereas the wait time for citizenship certificate applications has reached 34 months. Affected applicants are now stuck in this nearly three-year processing backlog, leaving them separated for extended periods and uncertain whether their PR applications will resume or be withdrawn. Those who already hold permanent resident status, however, will not lose it while waiting for a citizenship certificate.
Due to systems limitations, IRCC cannot say how many permanent residence applications have been put on hold due to potential citizenship eligibility. Between Dec. 15, 2025, and Aug. 31, 2026, IRCC approved 7,900 applications for Canadian citizenship certificates under the new legislation. During the same period, another 22,570 people born abroad to a Canadian parent received citizenship certificates.
The surge in applications has overwhelmed archives in Canada and the U.S., which have been swamped with requests from applicants seeking birth certificates and other records to prove Canadian ancestry. In early October, the Association of Canadian Archivists wrote to Immigration Minister Lena Metlege Diab requesting funding and assistance for archives handling the influx.
Critics and legal professionals have raised concerns about the lack of clarity surrounding the policy. Montreal immigration lawyer Lisa Middlemiss stated that IRCC has not issued guidance to lawyers on how to interpret this gray zone. NDP immigration critic Jenny Kwan noted that the impact of Bill C-3 on permanent resident status was not something Parliament contemplated when debating the legislation.