(Disponible uniquement en anglais)
Letter 1
Via email: erin.ogorman@cbsa-asfc.gc.ca
Canada Border Services Agency
191 Laurier Avenue West, 6th Floor
Ottawa, ON K1A 0L8
Dear Ms. O'Gorman
Re: Immigration compliance deadlines for Iranian nationals affected by communications blackout in Iran
The Canadian Bar Association’s Immigration Law Section writes to raise urgent and systemic concerns arising from the ongoing communications blackout and deteriorating conditions in Iran. These circumstances have materially impaired the ability of Iranian nationals and their representatives to comply with statutory and administrative requirements under the Immigration and Refugee Protection Act1 and its regulations, and as such, stand as barriers to procedural fairness.
The Canadian Bar Association is a national association representing over 40,000 lawyers, notaries, law teachers, and law students across Canada. The Immigration Law Section comprises over 1,000 practitioners advising individuals, families, and employers in all areas of immigration, refugee, and citizenship law. Members of the Section work daily within the immigration system and are uniquely positioned to observe how legal and administrative frameworks operate in practice.
Issue
Since January 9, 2026, a state-imposed telecommunications blackout in Iran has prevented Iranian nationals from communicating with counsel and obtaining documentation required to comply with immigration-related deadlines administered by the Canada Border Services Agency.
These barriers are systemic and external to individual conduct. Reliance on case-by-case relief in this context creates inconsistency, delay, undeserved hardship, and unnecessary enforcement risk, even when applicants act in good faith.
Under section 9(3) of the Canada Border Services Agency Act and delegated authority under the Immigration and Refugee Protection Act, ministerial direction may be issued to address systemic barriers affecting compliance.
Recommendation
The CBA Immigration Law Section recommends that the Canada Border Services Agency:
- issue or seek ministerial direction providing blanket extensions of time for CBSA-administered immigration deadlines affecting Iranian nationals from January 9, 2026, onward;
- apply the measure across enforcement and compliance contexts; and
- commit to reviewing and extending the measure as circumstances require.
Conclusion
A systemic response will promote fairness and proportionality while supporting effective enforcement. The Canadian Bar Association’s Immigration Law Section would welcome continued engagement with the Agency on these issues and remains available to assist further as needed.
Yours truly,
(original letter signed by Noel Corriveau for Jatin Shory)
Jatin Shory
Chair, Immigration Law Section
End Notes
1 Immigration and Refugee Protection Act, SC 2001, c 27.
Letter 2
Via email: paul.thompson@hrsdc-rhdcc.gc.ca
Employment and Social Development Canada
140 Promenade du Portage
Gatineau, QC K1A 0J9
Dear Mr. Thompson
Re: Employment-related immigration deadlines for Iranian nationals affected by communications blackout in Iran
The Canadian Bar Association’s Immigration Law Section writes to raise urgent and systemic concerns arising from the ongoing communications blackout and deteriorating conditions in Iran. These circumstances have materially impaired the ability of Iranian nationals and their representatives to comply with statutory and administrative requirements under the Immigration and Refugee Protection Act and its regulations, and as such, stand as barriers to procedural fairness.
The Canadian Bar Association is a national association representing over 40,000 lawyers, notaries, law teachers, and law students across Canada. The Immigration Law Section comprises over 1,000 practitioners advising individuals, families, and employers in all areas of immigration, refugee, and citizenship law. Members of the Section work daily within the immigration system and are uniquely positioned to observe how legal and administrative frameworks operate in practice.
Issue
Since January 9, 2026, a state-imposed telecommunications blackout in Iran has severely restricted internet access, international calling, and document transmission. As a result, Iranian nationals and their counsel are unable to communicate reliably, obtain required documentation, or provide confirmations necessary to comply with employment-related immigration processes administered by Employment and Social Development Canada.
These barriers arise entirely from circumstances outside the control of applicants and representatives and affect a large number of files in the same way and for the same reason. Requiring individualized extensions in this context is inefficient and ineffective, resulting in unnecessary delay, undeserved hardship, administrative burden, and a risk of non-compliance despite good-faith efforts by applicants.
Section 5(2) of the Department of Employment and Social Development Act1, together with delegated authority under the Immigration and Refugee Protection Act, permits the issuance of operational directions to address systemic barriers that prevent fair and effective program delivery.
Recommendation
The CBA Immigration Law Section recommends that Employment and Social Development Canada:
- issue or seek ministerial direction providing blanket extensions of time for ESDC-administered immigration-related deadlines affecting Iranian applicants from January 9, 2026, onward;
- apply the measure across all relevant program streams; and
- commit to reviewing and extending the measure as circumstances require.
Conclusion
Systemic relief will reduce administrative burden, promote fairness for affected applicants, and support effective program administration. The Canadian Bar Association’s Immigration Law Section would welcome the opportunity to continue this discussion and to assist further as needed.
Yours truly,
(original letter signed by Noel Corriveau for Jatin Shory)
Jatin Shory
Chair, Immigration Law Section
End Notes
1 Department of Employment and Social Development Act, SC 2005, c 34.
Letter 3
Via email: Manon.Brassard@irb-cisr.gc.ca
Immigration and Refugee Board of Canada
Minto Place, Canada Building
344 Slater Street, 12th Floor
Ottawa, ON K1A 0K1
Dear Ms. Brassard
Re: Request for Board-wide procedural relief for Iranian applicants affected by communications blackout in Iran
The Canadian Bar Association’s Immigration Law Section writes to raise urgent and systemic concerns arising from the ongoing communications blackout and deteriorating conditions in
Iran. These circumstances have materially impaired the ability of Iranian nationals and their representatives to comply with statutory and administrative requirements under the Immigration and Refugee Protection Act1 and its regulations, and as such, stand as barriers to procedural fairness.
The Canadian Bar Association is a national association representing over 40,000 lawyers, notaries, law teachers, and law students across Canada. The Immigration Law Section comprises over 1,000 practitioners advising individuals, families, and employers in all areas of immigration, refugee, and citizenship law. Members of the Section work daily within the immigration system and are uniquely positioned to observe how legal and administrative frameworks operate in practice.
Issue
Since January 9, 2026, a state-imposed telecommunications blackout in Iran has prevented many Iranian applicants from communicating with counsel, transmitting documents, or participating meaningfully in proceedings before the Immigration and Refugee Board.
These barriers are systemic, external to individual conduct, and affect a large number of proceedings in the same manner. Requiring individualized procedural relief in these circumstances creates predictable hardship, risks inconsistent outcomes, increases the already strained mental health of applicants, risks loss of status, and imposes an unnecessary administrative burden on an already backlogged system, each undermining procedural fairness and efficient adjudication.
The Board has authority under section 151 and paragraphs 159(g) and (h) of the Immigration and Refugee Protection Act, to manage its procedures in a manner that ensures fairness and the orderly conduct of proceedings.
Recommendation
The CBA Immigration Law Section recommends that the Immigration and Refugee Board:
- issue a Special Order providing blanket extensions of time for all procedural deadlines affecting Iranian applicants from January 9, 2026, onward;
- apply the extensions across all divisions and proceeding types; and
- commit to reviewing and extending the measure as circumstances evolve.
Conclusion
An institution-wide procedural response will promote fairness, consistency, and the efficient administration of justice. The Canadian Bar Association Immigration’s Law Section would welcome continued engagement with the Board on these issues and remains available to assist further as appropriate.
Yours truly,
(original letter signed by Noel Corriveau for Jatin Shory)
Jatin Shory
Chair, Immigration Law Section
End Notes
1 Immigration and Refugee Protection Act, SC 2001, c 27.
Letter 4
Via email: Harpreet.Kochhar@cic.gc.ca
Immigration, Refugees and Citizenship Canada
365 Laurier Avenue West
Ottawa, ON K1A 1L1
Dear Dr. Kochhar:
Re: Urgent systemic relief for Iranian applicants affected by communications blackout in Iran
The Canadian Bar Association’s Immigration Law Section writes to raise urgent and systemic concerns arising from the ongoing communications blackout and deteriorating conditions in Iran. These circumstances have materially impaired the ability of Iranian nationals and their representatives to comply with statutory and administrative requirements under the Immigration and Refugee Protection Act1 and its regulations, and as such, stand as barriers to procedural fairness.
The Canadian Bar Association is a national association representing over 40,000 lawyers, notaries, law teachers, and law students across Canada. The Immigration Law Section comprises over 1,000 practitioners advising individuals, families, and employers in all areas of immigration, refugee, and citizenship law. Members of the Section work daily within the immigration system and are uniquely positioned to observe how legal and administrative frameworks operate in practice.
Issue
Since January 9, 2026, a state-imposed telecommunications blackout in Iran has severely restricted internet access, international calling, and document transmission. As a result, Iranian nationals and their counsel are unable to communicate reliably, obtain required documentation and/or instructions, or comply with statutory and administrative deadlines under Canada’s immigration system.
These barriers arise entirely from circumstances outside the control of applicants and representatives and affect a large number of applications in the same way. Requiring case-by-case extensions in this context creates predictable hardship, increases the risk of inconsistent outcomes, increases the already strained mental health of applicants, increases the risk of loss of status, and imposes an unnecessary administrative burden on an already backlogged system.
The Immigration and Refugee Protection Act provides mechanisms specifically designed to address these circumstances. Sections 25.1(1) and 25.2(1) authorize the Minister to grant exemptions from any applicable requirement of the Act or Regulations if believed to be justified by humanitarian or public policy considerations. Delegated authority under sections 4 and 6 of the Act further permits coordinated implementation across administering bodies.
Recommendation
The CBA Immigration Law Section recommends that Immigration, Refugees and Citizenship Canada:
- exercise its authority under sections 25.1(1) or 25.2(1) of the Immigration and Refugee Protection Act to provide blanket extensions of time for all deadlines affecting Iranian applicants falling on or after January 9, 2026, across all temporary and permanent application streams;
- confirm that such extensions apply to deadlines imposed by IRCC and by other bodies acting under delegated authority, including the Canada Border Services Agency, Employment and Social Development Canada, and the Immigration and Refugee Board;
- commit to reviewing and extending these measures for as long as circumstances in Iran continue to impair applicants’ ability to comply; and
- implement or extend Temporary Special Measures for Iranians with expanded eligibility and duration beyond February 28, 2026.
Conclusion
Extraordinary circumstances require proportionate and systemic responses. Where non-compliance arises from conditions wholly outside the control of applicants and their counsel, fairness, efficiency, and confidence in the immigration system are best served through coordinated public policy measures rather than individualized relief.
The Canadian Bar Association’s Immigration Law Section would welcome the opportunity to discuss these issues further and to assist the Department in developing responsive and legally sound measures.
Yours truly,
(original letter signed by Noel Corriveau for Jatin Shory)
Jatin Shory
Chair, Immigration Law Section
End Notes
1 Immigration and Refugee Protection Act, SC 2001, c 27.