Newsletter Archive
IRCC's Proactive Disclosure of Decision Notes in Refusal Letters
- by Ronalee Carey Law
February 2026
Having an application refused by IRCC is disappointing or even heartbreaking. The disappointment is often accompanied by confusion over the boilerplate language in refusal letters. This language provides the applicant with no information about why their application was refused, beyond very general terms.
On July 29, 2025, IRCC started to provide ‘officer decision notes’ attached to the refusal letters for some applications. IRCC stated that this change was intended to make it easier for applicants to access their personal information in their applications and to improve IRCC’s commitment to greater transparency.
The ‘officer decision notes’ are notes recorded by the immigration officers as they process an application. These notes should, in theory, include the officer’s reasoning for their decision, the officer’s consideration of the supporting evidence, or the lack thereof, and other concerns raised against the positive determination of the application.
Prior to this policy change, refused applicants would need to file an Access to Information and Privacy (ATIP) request to obtain the notes or apply for judicial review with the Federal Court, after which the notes would have been provided as part of the litigation process. The inclusion of the ‘officer decision notes’ should alleviate the applicants' burden of extra steps and additional costs of accessing these notes.
The reality, however, is that the notes are not all that helpful. We recently received a refusal letter for a visitor visa application. The decision letter states:
Thank you for your interest in coming to Canada. I have reviewed your temporary resident visa (visitor visa) application and supporting documentation to assess whether you meet the requirements for a visitor visa (https://www.canada.ca/en/immigration-refugees-citizenship/ services/visit-canada/eligibility.html). This includes assessing whether you are coming to Canada temporarily for the reason(s) you describe in your application. I have determined that your application does not meet the requirements of the Immigration and Refugee Protection Act (IRPA) (https://laws-lois.justice.gc.ca/eng/acts/I-2.5/index.html) and Immigration and Refugee Protection Regulations (IRPR) (https://laws-lois.justice.gc.ca/eng/regulations/sor-2002-227/ index.html). I am refusing your application.
- I am not satisfied that you will leave Canada at the end of your stay as required by paragraph 179(b) of the IRPR (https://laws-lois.justice.gc.ca/eng/regulations/SOR-2002-227/ section-179.html). I am refusing your application because you have not established that you will leave Canada, based on the following factors:
- The purpose of your visit to Canada is not consistent with a temporary stay given the details you have provided in your application.
- Your immigration status outside your country of nationality or habitual residence.
The ‘reasons’ given for the denial of the application, provided in a separate document, were as follows:
Reasons for the refusal of your application: To help you understand why your application was refused, below are the Officer Decision Notes (ODN) specific to your application as they are displayed in IRCC’s system. These notes were entered by the officer who assessed and made the final decision on your application.
I have reviewed the application. I have considered the following factors in my decision. The purpose of the applicant's visit to Canada is not consistent with a temporary stay given the details provided in the application. Based on the applicant's immigration status outside their country of nationality or habitual residence, I am not satisfied that they will leave Canada at the end of their stay as a temporary resident. Weighing the factors in this application, I am not satisfied that the applicant will depart Canada at the end of the period authorized for their stay. For the reasons above, I have refused this application.
The ‘reasons’ still do not explain how the officer’s decision was made with consideration of the supporting evidence. There is no connection between the evidence we supplied and the officer’s reasoning. We can not even be sure that the officer reviewed what was provided.
As stated in the policy announcement, it is one of IRCC’s commitments to deliver its services with greater transparency. However, it is unclear how much the disclosure of these ‘officer decision notes’, as they are now, improves the transparency of IRCC decisions.
The Limits of AI in Immigration Law
- by Ronalee Carey Law
January 2026

We added a new member to our family early this year. Her name is Roberta. She has quickly become a cherished member of our little tribe. We love watching her to see what she will do next. The pets still don’t quite know what to make of her, but for the most part, will move aside for her as she makes her way from room to room.
Roberta is a robot vacuum. And she not only vacuums, but she also mops. She has the cutest little mop pads that she spins around. When she’s done her work, she empties her accumulated dirt and dirty mop water into a container in her home base. She sends us a notification when these need to be emptied.
Robot vacuums are amazing things, and a testament to human ingenuity and engineering. However, Roberta has not completely replaced me. Roberta’s sensors keep her a certain distance from objects like furniture, and she can’t move things like potted floor plants to vacuum behind them. So, a few times a month, I still lug out the traditional vacuum and mop and clean where Roberta can’t.
Artificial intelligence is very much like Roberta. It has its uses and its limitations. As I wrote in a previous newsletter, ‘Why I’m not Worried my Job Will be Taken Over by a Robot’, chatbots and other forms of artificial intelligence cannot provide emotional support through a stressful immigration journey. Though AI has come a long way since I wrote that newsletter in 2018, it still needs human oversight. At our firm, we use an AI writing assistance tool called Grammarly. It’s great for spotting spelling and grammatical mistakes and can suggest improved sentence flow. I use these tools all the time; Grammarly works much better than traditional word processing tools. However, Grammarly wanted me to put a comma between ‘vacuum’ and ‘mop’ in the preceding paragraph. Putting a comma there would have changed the meaning of the sentence in a way that wouldn’t have reflected what I wanted to say. So, I clicked ‘dismiss’ to get rid of the accusatory blue line Grammarly put under those words.
Grammarly is the only AI tool our law firm currently uses. As technology companies continue to push and advertise AI, we have considered other tools. Each time, we’ve found a number of concerns to the technology that makes us choose not to proceed.
Security Issues
AI programs consistently scan and store the information they encounter. What does the program have access to? Does the program store client information and if yes, where and how long? Where are the storage servers located (what country) and what laws apply to the government of that country accessing that stored information? Can we manually delete that information (and do we as a firm have time to do so)?
One question that often gets overlooked when considering security is: Does the company offering the program have its own servers for data storage, or does it contract this out?
Fireflies.ai, a note-taker program, came highly recommended to us. Its security compliance levels are high, but its list of sub-processors is long. We would need to continuously monitor data breaches across US companies, as well as US laws governing government access to AI databases. This would certainly be of major concern to any of our LGBTQIA+ clients coming from the USA in the current political climate.
Further, other staff at Ronalee Carey Law were able to review a meeting transcript via a forwarded link, without having to log in.
A call to The Law Society of Ontario’s Practice Management Helpline confirmed that any transcript the AI notetaker made would need to be reviewed for mistakes and that clients would need to be notified of the use of the AI and would need to give permission.
We decided it wasn’t worth the headache!
Environmental and Humanitarian Concerns
We also had concerns about the energy and water AI consumes. Being considerate of the environment is not a new concern for our firm. In 2021, I wrote an article about Climate Migrants. It's no surprise then, that we would want to limit the use of something contributing to the cause. The United Nations and MIT Technology Review have both discussed the rapid need for AI programs to become more energy and water-efficient before expansion. META AI data centre is currently running water taps dry and filling what does run with dark sediment for those who live nearby. The major companies are giving no thought to local water systems or environment.
We’d rather leave the energy and water for life-saving AI programs like early cancer detection.
Hallucinations – AI programs make things up
AI programs are designed to make users happy. It doesn’t weed through sources to check for source quality. It simply finds things randomly tossed into the internet’s abyss that match what you ask for and spits it out at you or mashes things together from different sources like a game of MadLibs. You may have heard the sentiment “Don’t trust Wikipedia”, but you can follow Wikipedia to the source material, which may or may not be of good use to you. The same can be said for the information AI provides, but we don’t hear “Don’t trust ChatGPT” from those around us (yet).
Sometimes the hallucinations can be funny, like when Google AI told users to glue pizza, or eat rocks. X users also report that Google’s search engines are having issues with basic calculations that have functioned for a decade.
It’s harder to differentiate the hallucinations when they give real-sounding names and references. However, Stanford University reports that AI hallucinations happen in 1 out of every 6 inquiries or more.
Of course, with AI usage rampant, legal hallucinations have already hit Ontario courts. In May 2025, Ontario Court Justice Joseph Kenkel had to reject a lawyer’s legal arguments for citing an fictious case. Justice Myers considered holding a different lawyer in contempt of court for the same issue. The BBC also warns that reliance on the use of AI damages your thinking skills and lowers your ability to think critically and problem-solve.
As the technology advances, we will likely adopt more AI tools within our firm. We would be happy to spend more time providing a high level for care for our clients by allowing technology to handle more repetitive tasks (with human review, of course). Until then, we will watch what human ingenuity continues to produce.
Bill C-3 is now in Effect – A Boon for Genealogists?
- by Ronalee Carey Law
December 2025
Bill C-3: An Act to amend the Citizenship Act (2025) came into effect this month. This amendment to Canada’s Citizenship Act means that citizenship can be obtained through descent without a limit to the number of generations between individuals born before December 15, 2025, and their Canadian ancestor. Children born after December 15, 2025, will only be able to obtain citizenship if they are born outside of Canada to a Canadian parent who spent at least three years in Canada before the child’s birth.
During Parliament’s debate on the bill, one opposition party expressed concern about the potential scope of the bill, noting that 150,000 to 300,000 individuals could potentially be eligible for citizenship.
Increasingly, our office is being approached by individuals from the USA who have discovered via ancestry.com that they have a Canadian ancestor. Individuals who have benefited from the legislative changes do not need to apply for citizenship – they are considered citizens by birth. They need only apply for a citizenship certificate to obtain proof of citizenship. With this, they can apply for their Canadian passport. In their citizenship certificate application, they must provide documentation establishing their identity, and birth records for themselves and their parent, grandparent, great-grandparent, and so forth, back to the ancestor born in Canada.
Official birth records are required. This can pose a problem, as citizenship claims can predate official government record-keeping. Death records, marriage records, census excerpts, baptismal records, and US immigration records are other documents that can assist the Canadian Immigration department in ascertaining the claim for Canadian citizenship, especially when names vary across documents.
One group affected by the changes to the law are Acadians, descendants of French settlers who arrived in Canada in the 1600s and 1700s, who the British deported to the USA. The Canadian government has helpfully provided information on how to access documents related to Acadian ancestors on their genealogy webpage.
Other applicants could consider consulting a genealogical society. The Canadian government has published a list of societies in Canada, as well as religious organizations that kept birth archives. Library and Archives Canada also maintains a list of freelance researchers who can be hired for a fee to assist in genealogical research.
What happens if you don't move to Canada after becoming a Permanent Resident?
- by Ronalee Carey Law
November 2025
One of the lasting impacts of the COVID-19 pandemic has been an interruption in plans to settle in Canada after obtaining permanent residence status. After being approved to settle in Canada, many individuals I’ve met with found they could not make the move. Finding employment, obtaining housing, and disrupting already disrupted schooling created too heavy a burden for many families. These individuals are now nearing the end of their initial five-year period after obtaining permanent residence, raising concerns that they may not have met the residency obligation.

