The law that's about to reshape how Canada handles asylum claims, immigration documents, and processing timelines isn't fully written yet. The headline statute — Bill C-12, the Strengthening Canada's Immigration System and Borders Act — received Royal Assent on March 26, 2026. But most of what will actually change for applicants lives in the regulations underneath it, and the first batch of those regulations is open for public comment until May 31, 2026. After that, IRCC starts moving from drafts to in-force rules, with most provisions taking effect on January 1, 2027.
Eleven days remain. Here's what's actually in scope, who can file a comment, and what the regulations will mean for you.
Why the comment period matters
When a statute like Bill C-12 passes, the government still has to draft the operational rules: what counts as a "qualifying entry," how the new authorities can be used, what documentation IRCC needs, what counts as a complete application, and what triggers a refusal under the new powers. Those rules are the regulations. They're published in the Canada Gazette and put out for a fixed comment window before they're finalized.
The May 31 deadline is the close of the initial regulatory package — the first tranche IRCC is using to operationalize the asylum and document-management changes in Bill C-12. The government has been explicit that supporting regulations will be introduced in phases starting summer 2026, with the bulk of provisions coming into force January 1, 2027.
Comments filed before May 31 are formally on the record. They don't bind IRCC, but they do shape final wording — especially when they come from people who actually use the system: applicants, immigration lawyers, employer counsel, refugee-serving organizations, and provincial ministries.
What's in the first regulatory package
The initial package operationalizes four areas of Bill C-12.
Asylum eligibility rules. Two new eligibility limits are already in effect for claims made on or after June 3, 2025: a one-year deadline from first entry into Canada (for entries after June 24, 2020), and a 14-day deadline for claims made by people who crossed between ports of entry on the Canada–US land border. The regulations being consulted on right now define how IRCC will verify entry dates, handle disputed entry records, and treat claims where the applicant has multiple entries on file.
Group decision-making authority. Bill C-12 gave the Minister authority to cancel, suspend, or modify groups of immigration documents — for example, all study permits issued to students at a non-compliant designated learning institution, or all visitor visas to nationals of a country with a major security event. The regulations will set out the procedural requirements: who has to be notified, how appeals work, what the threshold for a group order is, and how the Canada Gazette publication requirement is satisfied.
Information sharing between government agencies. Bill C-12 expanded the legal authority for IRCC, CBSA, and other federal departments to share applicant information. The regulations specify what data can be shared, with whom, and how long it can be retained. This is the area where privacy advocates and immigration lawyers have submitted the most extensive comments.
Asylum claims processing simplification. IRCC has signaled it will use the regulations to streamline the online asylum application — removing duplicate questions, simplifying eligibility screening, and reducing the average claim from 24 to 12 months. The regulations being consulted on are the procedural backbone for that change.
Who should consider filing a comment
The consultation is open to anyone — you don't have to be a lawyer, an organization, or a Canadian citizen to submit. The submissions that get traction are the ones that propose specific wording or specific procedural fixes, not the ones that argue against the law itself (that fight was lost when Parliament passed it).
You may want to comment if you're:
- An asylum claimant or supporter who can identify documentation gaps in the eligibility verification framework — for example, what happens when someone's entry date is on a lost passport.
- A study permit holder at a DLI under compliance review — your concerns about the group document cancellation procedure should be on the record.
- An immigration lawyer or RCIC whose clients will be processed under the new rules — your operational suggestions on AOR timing, biometrics coordination, and webform handling carry weight.
- An employer of foreign workers with concerns about how group orders might affect work permits tied to a specific facility or company.
- A privacy or civil-liberties advocate with views on the information-sharing regulations.
- A provincial government stakeholder whose nomination program intersects with the federal authorities being expanded.
If your concern is more general — you think Bill C-12 is a bad law — the comment period isn't the venue. Write your MP instead.
How to actually file a comment
The official channel is the Canada Gazette consultation pages for the proposed regulations. IRCC also accepts submissions through the department's email consultation address listed in the regulatory impact analysis statement (RIAS) attached to each draft.
Useful structure for a submission:
- Identify the specific regulatory provision by section number — don't write generally about "the asylum changes." Write about, say, "the entry-date verification standard in section 3(2)."
- State the problem in one sentence. What's the practical issue with the wording?
- Propose specific alternative language if you can. Even an imperfect alternative gives the drafters something to react to.
- Cite evidence. A specific case, a published study, a piece of immigration tribunal jurisprudence — anything that grounds the comment in fact.
- Keep it short. A focused 500-word comment is read. A 30-page submission is skimmed.
Comments don't need to be on letterhead. They don't need a lawyer. They need to be on time, on point, and on the record.
What happens after May 31
After the comment window closes, IRCC's regulatory drafters revise the package, prepare a final RIAS responding to the comments received, and publish the finalized regulations in the Canada Gazette. The first batch is expected to come into force in summer 2026, with later tranches phased through to January 1, 2027.
The other tracks of Bill C-12 implementation — including the federal court case-management changes that already affect judicial review timelines — are running in parallel. Together, they amount to the most consequential operational shift to Canadian immigration law in over a decade.
If you're currently in the system, the most useful thing you can do this week is read the overview of Bill C-12's four pillars and then look at the specific regulations governing the part of the system you actually rely on. If a provision looks wrong or unworkable to you, you have until May 31 to say so — in writing, on the record.
The single most-cited comment in past IRCC regulatory consultations has been a one-page submission from a small refugee-serving NGO that proposed specific alternate wording for a procedural definition. Length doesn't matter. Specificity does. If you have one concrete sentence to add or change, that's worth submitting on its own — you don't need a full brief.
Resources
For the law itself: Bill C-12 overview | Federal court case-management changes
For ongoing policy context: Express Entry overhaul 2026 | Immigration Levels Plan 2026–2028 | 2027–2029 levels consultation