On November 18, 2025, UNHCR Canada was invited to appear before the House of Commons’ Standing Committee on Citizenship and Immigration (CIMM) as part of its study of Bill C-12. Azadeh Tamjeedi, UNHCR Canada senior legal officer, presented on behalf of UNHCR. Video of the meeting can be found at this link.
Thank you for the opportunity to appear before you today on Bill C-12. As UNHCR, the UN agency serving refugees and asylum-seekers in 134 countries and territories, providing technical advice on building a strong asylum system is an integral part of our advisory role.
As of June 2025, 117.3 million people were forced to flee from their homes, with 71% being hosted by low-to-middle income countries. Closer to home, Canada, like many countries, has seen a rise in asylum claims amid increased global displacement. Ensuring a strong asylum system that can both quickly recognize those in need of protection and refuse those who do not meet the international definition of a refugee is an important goal of any asylum process. We recognize the challenges that this entails but we fully believe that Canada can meet them in a way that ensures the right to seek asylum is protected.
Regarding Bill C-12, UNHCR notes that many proposed changes depend on future regulatory amendments, and a full assessment will only be possible once the draft regulations are available. We welcome elements that reflect past UNHCR recommendations – such as streamlining eligibility processes and enabling earlier appointment of Designated Representatives for children and other vulnerable persons – both of which will contribute to a stronger and more efficient asylum system.
At this time, UNHCR would like to focus its comments and recommendations on the new ineligibility provisions. One of the main changes under the proposed bill is that individuals found ineligible under the two new provisions would receive a Pre-Removal Risk Assessment, a PRRA. Like the Immigration and Refugee Board (IRB), the PRRA could grant refugee or protected person status. It was originally designed to be used prior to removal after someone has exhausted all their options in Canada, including a hearing at the IRB. However, if the PRRA is used to conduct the first assessment of an individual’s asylum application, as this legislation proposes, it should incorporate safeguards to comply with international and domestic law. First, UNHCR recommends that a mandatory hearing be added to ensure an individual’s right to be heard.
Second, we would recommend that those deemed ineligible under these new provisions have the right to a full appeal at the Refugee Appeal Division of the IRB, which would also stay their removal until the appeal is heard. This would minimize the risk of returning a person to a place where their life would be at risk if there was an error in the PRRA decision and increase overall system efficiency.
The final recommendation is that individuals from countries that Canada does not deport to, so called moratorium countries, be granted exceptions to the new ineligibilities. If the Bill remains unchanged, when a person from a moratorium country, like Afghanistan, is deemed ineligible under one of these new provisions they will not have their case heard and will remain in limbo. These are typically strong asylum claims, and they merit an opportunity to obtain refugee protection. Moreover, certain individuals should be exempt from the one-year ineligibility bar, such as vulnerable persons and when there is a change in circumstances. This would allow for a specialized tribunal, the IRB, to handle these more complex claims.
UNHCR has long supported Canada’s refugee adjudication model and the IRB. At the same time, we recognize that finding ways to increase efficiencies while upholding access to fair procedures are legitimate objectives. We hope that Canada continues to be a champion for fast, fair, and efficient asylum systems and to lead in an environment when other countries are closing the door on the principle of asylum. We have seen firsthand how the 1951 Refugee Convention and asylum have saved millions of lives in the last 74 years. As this committee has heard, 61% of those who claim asylum in Canada are found to be refugees meaning that they have fled dangerous situations that required Canada’s protection. For this vital reason, UNHCR remains committed to working with the Canadian government and civil society to ensure that the new measures are implemented in a manner that provides protection to those who need it and builds a stronger system that can respond to the challenges of the future. Thank you.