Understanding the Strong Borders Act Bill C-2 and Its Implications for Canadian Immigration

On June 3, 2025, the Government of Canada introduced the Strong Borders Act (Bill C-2), a significant legislative proposal aimed at enhancing border security and modernizing Canada’s immigration and asylum systems. This bill proposes amendments to the Immigration and Refugee Protection Act (IRPA) and the Department of Citizenship and Immigration Act, introducing changes that could reshape the immigration process for applicants, stakeholders, and legal representatives. Below, we explore the key provisions of the Strong Borders Act and their potential impact on applicants, focusing on the new authorities granted to Immigration, Refugees and Citizenship Canada (IRCC) and the implications for those pursuing Canadian immigration benefits.

Key Provisions of the Strong Borders Act

The Strong Borders Act introduces several amendments designed to streamline immigration processes, strengthen system integrity, and enhance national security. The following are the primary changes outlined in the proposed legislation:

1. Enhanced Information Sharing
   The amendments authorize IRCC to share client information—such as identity, immigration status, and documentation—with federal, provincial, and territorial partners through signed agreements. Additionally, the changes facilitate data sharing between IRCC programs (e.g., using permanent residence application data for citizenship applications) and allow for regulations to enable cooperation across federal departments. These measures aim to improve efficiency and coordination but raise considerations about privacy and data security for applicants.
2. Strengthened Control Over Immigration Documents
   The Act grants IRCC expanded powers to cancel, suspend, or modify groups of immigration documents in the public interest, particularly for reasons related to public health or national security. IRCC may also pause the acceptance of new applications or halt the processing of existing applications in its inventory. These authorities provide the government with greater flexibility to respond to emerging challenges but introduce significant uncertainty for applicants.
3. Modernization of the Asylum System
   The proposed changes aim to make the asylum system more efficient and accessible by simplifying the online application process and standardizing procedures at ports of entry and inland IRCC offices. Complete claims will be referred more quickly to the Immigration and Refugee Board of Canada (IRB), with decisions made only when claimants are physically present in Canada. The Act also introduces measures to remove inactive cases, expedite voluntary departures, and provide representatives to support vulnerable claimants, such as minors or those unfamiliar with the process.
4. New Ineligibility Provisions for Asylum Claims
   To protect the asylum system from sudden surges in claims, the Act introduces two ineligibility measures:
   • Asylum claims made more than one year after an individual’s arrival in Canada (post-June 24, 2020) will not be referred to the IRB. This applies to all individuals, including students and temporary residents, regardless of whether they left and re-entered Canada.
   • Asylum claims made by individuals entering from the United States at the land border between ports of entry will not be referred to the IRB if filed more than 14 days after entry.
     Affected individuals may still apply for a Pre-Removal Risk Assessment (PRRA) to ensure they are not returned to a country where they face harm.

Implications of IRCC’s Expanded Powers to Cancel Applications

One of the most significant aspects of the Strong Borders Act is the authority granted to IRCC to abruptly cancel, suspend, or pause immigration applications already in process. While these powers are intended to safeguard public interest, they introduce a layer of uncertainty for applicants who have invested significant time, financial resources, and emotional energy into their immigration journey.

For many foreign nationals, the decision to pursue Canadian immigration involves substantial commitments, such as paying application fees, hiring legal representation, obtaining documentation, and, in some cases, relocating or making career sacrifices. The possibility that IRCC could halt or cancel applications mid-process—potentially for broad reasons like public health or national security—may create concerns about the predictability and reliability of Canada’s immigration system.

This increased uncertainty could arguably give rise to claims of detrimental reliance, where applicants assert that they made decisions based on reasonable expectations of a stable and transparent immigration process, only to face unexpected disruptions. For instance, an applicant who has spent years preparing for permanent residency might face financial and personal losses if their application is paused or canceled without clear recourse. While the government’s intent is to enhance system flexibility and security, applicants may perceive these measures as undermining the fairness and consistency of the immigration process.

Applicants and their legal representatives should remain vigilant about these developments, as the implementation of the Strong Borders Act could affect processing times, eligibility criteria, and application strategies. Those currently navigating the immigration system may benefit from consulting with experienced immigration counsel to understand how these changes could impact their specific circumstances and to explore options for mitigating risks.

We note that The Strong Borders Act is not law, it is only a new Bill that has been introduced in Parliament. We will monitor its development over the coming months.