The attached document provides the CCR's comments in response to the publication in the Canada Gazette, Part I, Volume 158, Number 51, on December 21, 2024, of proposed amendments to the Immigration and Refugee Protection Regulations and to the Citizenship Regulations with respect to administrative penalties for non-compliance with requirements regarding representation and advice.
The proposed new system would allow IRCC to penalize people who provide advice or representation in immigration and citizenship processes in return for payment, without being authorized. The CCR has a longstanding concern with unscrupulous and unauthorized consultants who prey on vulnerable people seeking to navigate Canada’s immigration and citizenship systems. The CCR's comments are focused on the interests of the people who are abused by such agents, as well as on possible consequences for NGOs of false and malicious complaints.