Regulations Amending the Citizenship Regulations, No. 2 (2025): SOR/2025-278

Canada Gazette, Part II, Volume 159, Number 27

Registration
SOR/2025-278 December 12, 2025

CITIZENSHIP ACT

The Minister of Citizenship and Immigration makes the annexed Regulations Amending the Citizenship Regulations, No. 2 (2025) under paragraph 27.2(a)^{footnote a} of the Citizenship Act^{footnote b}.

Ottawa, December 1, 2025

Lena Metlege Diab
Minister of Citizenship and Immigration

Regulations Amending the Citizenship Regulations, No. 2 (2025)

Amendments

1 Subparagraph 4(c)(iii) of the Citizenship Regulations, No. 2^{footnote 1} is replaced by the following:

• (iii) if the applicant is the child’s legal guardian, evidence that establishes their status as such,

2 (1) Subparagraph 5(c)(ii) of the French version of the Regulations is replaced by the following:

• (ii) une preuve établissant que l’un de ses parents avait, au moment de l’adoption, qualité de citoyen,

(2) Paragraph 5(c) of the Regulations is amended by adding the following after subparagraph (ii):

• (ii.1) if, at the time of the adoption, only one of the parents of the child was a citizen — and that parent of the child was a citizen under any of paragraphs 3(1)(b), (c.1), (e), (g) to (j) and (o) to (r) of the Act and was born outside Canada — evidence that establishes that that parent of the child was physically present in Canada for at least 1,095 days before the adoption,
• (ii.2) if, at the time of the adoption, only one of the parents of the child was a citizen — and that parent of the child was a citizen under paragraph 3(1)(f) of the Act and was born outside Canada to a parent who was a citizen at the time of the birth of that parent of the child — evidence that establishes that that parent of the child was physically present in Canada for at least 1,095 days before the adoption,
• (ii.3) if, at the time of the adoption, both of the parents of the child were citizens under any of paragraphs 3(1)(b), (c.1), (e) to (j) and (o) to (r) of the Act and were born outside Canada — and, in the case of a parent of the child who was a citizen under paragraph 3(1)(f) of the Act, that parent of the child was born to a parent who was a citizen at the time of the birth of that parent of the child — evidence that establishes that at least one of those parents of the child who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption,
• (ii.4) if, at any time, only one of the parents of the child was a citizen and that parent of the child was a citizen under any of the provisions referred to in clauses 3(3)(b)(i)(A) to (H) of the Act or both of the parents of the child were citizens under any of those provisions, evidence that establishes that at least one of those parents of the child who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption,

3 (1) Paragraph 6(b) of the French version of the Regulations is replaced by the following:

• b) une preuve établissant que l’un de ses parents a obtenu qualité de citoyen le 1^er janvier 1947 — ou le 1^er avril 1949 dans le cas d’un parent qui a obtenu qualité de citoyen à cette date par suite de l’adhésion de Terre-Neuve-et-Labrador à la Fédération canadienne — dans le cas d’une adoption avant l’une de ces dates ou avait, au moment de l’adoption, qualité de citoyen dans le cas d’une adoption faite le 1^er janvier 1947 ou subséquemment;

(2) Section 6 of the Regulations is amended by adding the following after paragraph (b):

• (b.1) if, at the time of the adoption, only one of the parents of the person was a citizen — and that parent of the person was a citizen under any of paragraphs 3(1)(b), (c.1), (e), (g) to (j) and (o) to (r) of the Act and was born outside Canada — evidence that establishes that that parent of the person was physically present in Canada for at least 1,095 days before the adoption;
• (b.2) if, at the time of the adoption, only one of the parents of the person was a citizen — and that parent of the person was a citizen under paragraph 3(1)(f) of the Act and was born outside Canada to a parent who was a citizen at the time of the birth of that parent of the person — evidence that establishes that that parent of the person was physically present in Canada for at least 1,095 days before the adoption;
• (b.3) if, at the time of the adoption, both of the parents of the person were citizens under any of paragraphs 3(1)(b), (c.1), (e) to (j) and (o) to (r) of the Act and were born outside Canada — and, in the case of a parent of the person who was a citizen under paragraph 3(1)(f) of the Act, that parent of the person was born to a parent who was a citizen at the time of the birth of the parent of the person — evidence that establishes that at least one of those parents of the person who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption;
• (b.4) if, at any time, only one of the parents of the person was a citizen and that parent of the person was a citizen under any of the provisions referred to in clauses 3(3)(b)(i)(A) to (H) of the Act or both of the parents of the person were citizens under any of those provisions, evidence that establishes that at least one of those parents of the person who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption;

4 (1) Paragraph 7(b) of the French version of the Regulations is replaced by the following:

• b) une preuve établissant que l’un de ses parents a obtenu qualité de citoyen le 1^er janvier 1947 — ou le 1^er avril 1949 dans le cas d’un parent qui a obtenu qualité de citoyen à cette date par suite de l’adhésion de Terre-Neuve-et-Labrador à la Fédération canadienne — dans le cas d’une adoption avant l’une de ces dates ou avait, au moment de l’adoption, qualité de citoyen dans le cas d’une adoption faite le 1^er janvier 1947 ou subséquemment;

(2) Section 7 of the Regulations is amended by adding the following after paragraph (b):

• (b.1) if, at the time of the adoption, only one of the parents of the person was a citizen — and that parent of the person was a citizen under any of paragraphs 3(1)(b), (c.1), (e), (g) to (j) and (o) to (r) of the Act and was born outside Canada — evidence that establishes that that parent of the person was physically present in Canada for at least 1,095 days before the adoption;
• (b.2) if, at the time of the adoption, only one of the parents of the person was a citizen — and that parent of the person was a citizen under paragraph 3(1)(f) of the Act and was born outside Canada to a parent who was a citizen at the time of the birth of that parent of the person — evidence that establishes that that parent of the person was physically present in Canada for at least 1,095 days before the adoption;
• (b.3) if, at the time of the adoption, both of the parents of the person were citizens under any of paragraphs 3(1)(b), (c.1), (e) to (j) and (o) to (r) of the Act and were born outside Canada — and, in the case of a parent of the person who was a citizen under paragraph 3(1)(f) of the Act, that parent of the person was born to a parent who was a citizen at the time of the birth of the parent of the person — evidence that establishes that at least one of those parents of the person who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption;
• (b.4) if, at any time, only one of the parents of the person was a citizen and that parent of the person was a citizen under any of the provisions referred to in clauses 3(3)(b)(i)(A) to (H) of the Act or both of the parents of the person were citizens under any of those provisions, evidence that establishes that at least one of those parents of the person who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption;

5 (1) Subparagraph 8(c)(ii) of the French version of the Regulations is replaced by the following:

• (ii) une preuve établissant que l’un de ses parents avait qualité de citoyen au moment où la décision prononçant l’adoption a été rendue à l’étranger,

(2) Paragraph 8(c) of the Regulations is amended by adding the following after subparagraph (ii):

• (ii.1) if, at the time of the adoption, only one of the parents of the child was a citizen — and that parent of the child was a citizen under any of paragraphs 3(1)(b), (c.1), (e), (g) to (j) and (o) to (r) of the Act and was born outside Canada — evidence that establishes that that parent of the child was physically present in Canada for at least 1,095 days before the adoption,
• (ii.2) if, at the time of the adoption, only one of the parents of the child was a citizen — and that parent of the child was a citizen under paragraph 3(1)(f) of the Act and was born outside Canada to a parent who was a citizen at the time of the birth of that parent of the child — evidence that establishes that that parent of the child was physically present in Canada for at least 1,095 days before the adoption,
• (ii.3) if, at the time of the adoption, both of the parents of the child were citizens under any of paragraphs 3(1)(b), (c.1), (e) to (j) and (o) to (r) of the Act and were born outside Canada — and, in the case of a parent of the child who was a citizen under paragraph 3(1)(f) of the Act, that parent of the child was born to a parent who was a citizen at the time of the birth of that parent of the child — evidence that establishes that at least one of those parents of the child who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption,
• (ii.4) if, at any time, only one of the parents of the child was a citizen and that parent of the child was a citizen under any of the provisions referred to in clauses 3(3)(b)(i)(A) to (H) of the Act or both of the parents of the child were citizens under any of those provisions, evidence that establishes that at least one of those parents of the child who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption,

6 (1) Paragraph 9(b) of the French version of the Regulations is replaced by the following:

• b) une preuve établissant que l’un de ses parents a obtenu qualité de citoyen le 1^er janvier 1947 dans le cas où la décision prononçant l’adoption a été rendue à l’étranger avant cette date ou avait qualité de citoyen au moment de cette décision dans le cas d’une adoption faite le 1^er janvier 1947 ou subséquemment;

(2) Section 9 of the Regulations is amended by adding the following after paragraph (b):

• (b.1) if, at the time of the adoption, only one of the parents of the person was a citizen — and that parent of the person was a citizen under any of paragraphs 3(1)(b), (c.1), (e), (g) to (j) and (o) to (r) of the Act and was born outside Canada — evidence that establishes that that parent of the person was physically present in Canada for at least 1,095 days before the adoption;
• (b.2) if, at the time of the adoption, only one of the parents of the person was a citizen — and that parent of the person was a citizen under paragraph 3(1)(f) of the Act and was born outside Canada to a parent who was a citizen at the time of the birth of that parent of the person — evidence that establishes that that parent of the person was physically present in Canada for at least 1,095 days before the adoption;
• (b.3) if, at the time of the adoption, both of the parents of the person were citizens under any of paragraphs 3(1)(b), (c.1), (e) to (j) and (o) to (r) of the Act and were born outside Canada — and, in the case of a parent of the person who was a citizen under paragraph 3(1)(f) of the Act, that parent of the person was born to a parent who was a citizen at the time of the birth of the parent of the person — evidence that establishes that at least one of those parents of the person who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption;
• (b.4) if, at any time, only one of the parents of the person was a citizen and that parent of the person was a citizen under any of the provisions referred to in clauses 3(3)(b)(i)(A) to (H) of the Act or both of the parents of the person were citizens under any of those provisions, evidence that establishes that at least one of those parents of the person who was a citizen under any of those provisions was physically present in Canada for at least 1,095 days before the adoption;

7 (1) The portion of subsection 11(1) of the Regulations before paragraph (a) is replaced by the following:

Application — paragraph 3(1)(b) of Act

11 (1) An application to renounce the citizenship of a person who became a citizen under paragraph 3(1)(b) of the Act, for the sole reason that one or both parents are persons referred to in any of paragraphs 3(1)(k) to (n) of the Act, and who did not become a citizen by way of grant, as defined in subsection 3(9) of the Act, must be

(2) The portion of subsection 11(2) of the Regulations before paragraph (a) is replaced by the following:

Application — paragraphs 3(1)(f), (g) or (k) to (r) of Act

(2) An application to renounce the citizenship of a person who became a citizen under paragraph 3(1)(f) or (g) of the Act or under any of paragraphs 3(1)(k) to (r) of the Act, and who did not become a citizen by way of grant, as defined in subsection 3(9) of the Act, must be

(3) Section 11 of the Regulations is amended by adding the following after subsection (2):

Application — An Act to amend the Citizenship Act (2025)

(3) An application to renounce the citizenship of a person who became a citizen as a result of the coming into force of An Act to amend the Citizenship Act (2025), who was born before the day on which that Act came into force and who did not, before that day, become a citizen by way of grant, as defined in subsection 3(9) of the Act, must be

• (a) made in the prescribed form; and
• (b) filed in the manner determined by the Minister together with the following information and materials:
  • (i) evidence that establishes the date and place of birth of the person in respect of whom the application is made,
  • (ii) evidence that establishes that the person became a citizen as a result of the coming into force of An Act to amend the Citizenship Act (2025),
  • (iii) an official document of a country other than Canada, or other evidence, that establishes that the person is a citizen of that country or, if the application is approved, will become one, and
  • (iv) a photograph of the person in the format specified on the prescribed form.

Application on behalf of minor child

(4) If an application referred to in subsection (3) is made on behalf of a child who is a minor, it must also be

• (a) signed by each of the child’s parents or legal guardians, unless evidence is included that establishes that it is impossible or not feasible for them to do so;
• (b) if the application is signed by the child’s legal guardians, filed along with evidence that establishes their status as such;
• (c) countersigned by the child if the child has attained the age of 14 years on or before the day on which the application is made, unless evidence is included that establishes that the child is prevented from understanding the significance of the application because of a mental disability.

Coming into Force

8 These Regulations come into force on the day on which section 6 of An Act to amend the Citizenship Act (2025) chapter 5 of the Statutes of Canada, 2025, comes into force, but if they are registered after that day, they come into force on the day on which they are registered.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Issues

Amendments to the Citizenship Regulations, No. 2 (the Regulations) are required to support the new framework governing citizenship by descent and extension of citizenship to more “Lost Canadians”, their descendants and those impacted by the first-generation limit to citizenship by descent as introduced into the Citizenship Act by An Act to amend the Citizenship Act (2025).

Background

On January 1, 1947, the Canadian Citizenship Act came into force, marking the beginning of Canadian citizenship as a legal status. The Act established three ways to acquire Canadian citizenship: by birth on soil — if a person was born in Canada; by descent — if a person was born outside Canada to a Canadian parent; and by naturalization — if a person immigrated to Canada and then naturalized as a citizen.

“Lost Canadians” is a term that refers to individuals who lost or never acquired Canadian citizenship due to outdated or discriminatory provisions in previous citizenship legislation. These include provisions under which an individual’s gender or wedlock status, place of birth, or naturalization status could affect whether that person could derive, acquire, or lose Canadian citizenship. For example, under the 1947 Canadian Citizenship Act, children born outside Canada could not acquire Canadian citizenship if they were born out of wedlock to a Canadian father.

A new Citizenship Act came into force on February 15, 1977, replacing the 1947 Act and introducing a number of changes to citizenship by descent, including eliminating many of the discriminatory provisions present in the 1947 Act.

However, the 1977 Act also included a retention requirement for people born outside Canada in the second or subsequent generations. Specifically, section 8 of the 1977 Act resulted in the automatic loss of citizenship for certain persons if they did not make an application and meet certain requirements before turning 28 years of age. The requirements to retain citizenship included having to live in Canada for one year immediately prior to submitting an application, or having established a substantial connection to Canada prior to their 28th birthday. If an individual did not apply to retain their citizenship and/or did not meet these requirements, they automatically lost their citizenship on their 28th birthday. Many people subject to the section 8 retention requirements were unaware of the requirements and unknowingly lost their Canadian citizenship. This provision was repealed in 2009.

While the vast majority of “Lost Canadians” had their citizenship restored or acquired citizenship as a result of legislative changes in 2009 and 2015, those who were born outside Canada to a Canadian parent in the second or subsequent generation, including those who had failed to retain their citizenship under section 8 of the 1977 Act, did not acquire citizenship or have their citizenship restored. This is because the amendments to the Citizenship Act introduced in 2009 also included a first-generation limit to citizenship by descent. This meant that anyone who was not already a citizen on April 17, 2009, and who was born outside Canada in the second or subsequent generation, did not become a citizen. This included the descendants of newly fixed “Lost Canadians” who remained excluded from citizenship.

Under the first-generation limit, in order to be an automatic citizen from birth, a person born outside Canada must have a Canadian parent who was either born in Canada or who was naturalized as a Canadian citizen (with some limited exceptions for the children and grandchildren of Crown servants). As a result, those born abroad in a second or subsequent generation after April 17, 2009, were not automatic citizens and would have had to apply for a grant of citizenship if they wished to become a citizen.

Recognizing the need to restore or give citizenship to the remaining cohorts of “Lost Canadians,” and those impacted by the first-generation limit, and to provide a pathway to citizenship for those born or adopted abroad in the second or subsequent generation to a Canadian parent who has a substantial connection to Canada, Parliament adopted Bill C-3 on November 20, 2025.

Bill C-3, An Act to amend the Citizenship Act (2025), revised the Citizenship Act (the Act) to

• (a) ensure that citizenship is conferred on all persons who were born outside Canada to a Canadian parent before the coming into force of this enactment;
• (b) confer citizenship on persons born outside Canada after the first generation, on or after the coming into force of this enactment, to a Canadian parent who has established a substantial connection to Canada before the person’s birth;
• (c) allow persons born abroad and adopted before the coming into force of this enactment to access the direct grant of citizenship under section 5.1 of that Act if their Canadian parent was also born or adopted abroad;
• (d) allow persons born abroad and adopted on or after the coming into force of this enactment to access the direct grant of citizenship under section 5.1 of that Act if their Canadian parent was also born or adopted abroad and has established a substantial connection to Canada before the person’s adoption;
• (e) restore citizenship to persons who lost their citizenship because they did not make an application to retain it under former section 8 of that Act or because they made an application under that section that was not approved; and
• (f) allow certain persons who become citizens as a result of the coming into force of this enactment to access a simplified process to renounce their citizenship.

Objective

The purpose of these amendments to the Regulations is to extend access to the simplified scheme for renunciation of citizenship for certain persons who become citizens as a result of Bill C-3 but who do not wish to be citizens and to require evidence to be provided with an application to establish that a Canadian parent of a person born abroad and adopted has a substantial connection to Canada at the time of the adoption in order to support the amendments to the Citizenship Act introduced by Bill C-3.

Description

Amendments to the Regulations extend access to the simplified renunciation process to certain persons who become citizens as a result of the coming into force of An Act to amend the Citizenship Act (2025) and who were born before the day on which that Act came into force. Access to the simplified renunciation process is needed for those who may not wish to be citizens because it may adversely impact their other citizenship or their right to benefits in their other country of citizenship. These amendments will also provide specific procedural requirements for minors accessing the simplified renunciation process.

The amendments also require evidence to be provided in support of applications under section 5.1 of the Citizenship Act that establishes that a Canadian parent of a person born abroad and adopted, who themselves was also born or adopted abroad, was physically present in Canada for at least 1 095 days before the date of adoption.

Regulatory development

Consultation

The amendments to the Citizenship Act introduced in Bill C-3 respond to a decision by the Ontario Superior Court of Justice that the first-generation limit for most persons born abroad to a Canadian parent is unconstitutional. These amendments were consulted on throughout the summer and fall of 2025.

Indigenous engagement, consultation and modern treaty obligations

Immigration, Refugees and Citizenship Canada (IRCC) consulted the Cabinet Directive on the Federal Approach to Modern Treaty Implementation and determined that the amendments are not expected to have an impact on modern treaty obligations. It was also determined that directed Indigenous consultation was not required.

Instrument choice

The Regulations outline the manner in which a person may renounce their citizenship via a simplified scheme. Amendments to the Regulations are needed to allow for a simplified renunciation process for certain persons who will become citizens as a result of Bill C-3, but who do not wish to be Canadian citizens. The Regulations also prescribe how an application for a grant of citizenship as an adopted person is made and what evidence is required to support the application.

Regulatory analysis

Benefits and costs

An important first step in developing a cost-benefit methodology is establishing a baseline scenario against which options may be measured. For this analysis, the baseline scenario is a scenario where (1) certain persons who would become citizens of Canada by automatic operation of law (as a result of recent changes to the Citizenship Act) do not have a simplified process whereby they can divest themselves from this status; and (2) Canadian parents of persons born abroad and adopted who were themselves also born or adopted abroad are not required under the Regulations to provide evidence to support that they meet the substantial connection requirement before the adoption as part of an application. The baseline scenario is then compared with the regulatory scenario where (1) certain persons who do not wish to be Canadian citizens as a result of the recent amendments to the Citizenship Act have access to a simplified renunciation process; and (2) the Regulations prescribe that Canadian parents of persons born abroad and adopted who were themselves also born or adopted abroad are required to establish that they have a substantial connection to Canada prior to the date of adoption as part of their application.

The costs and benefits of the amendments are estimated for 10 periods of 12 months (2025–2034), starting when the Regulations come into force.

The total costs of the regulatory amendments are estimated at $1,536,451 present value (PV) over 10 years. These costs reflect both the transition costs and ongoing costs to the Government of Canada.

Transition costs to the Government of Canada would be incurred in the first period of analysis. These transition activities include updating program delivery instructions and manuals, updating application kits, updating training material, developing communication products, updating IRCC’s website to reflect the regulatory amendments and updating information technology (IT) systems, such as the Global Case Management System (GCMS) and client portal, to implement these changes. These costs are estimated at approximately $953,114 PV.

Ongoing costs to the Government reflect the additional costs of processing renunciation applications and issuing confirmation letters deeming a person to never have been a Canadian citizen, as well as ongoing communications support. Total ongoing costs to the Government are estimated at $583,337 PV over 10 years.

The Regulations will benefit clients by providing a streamlined (simplified) process in which clients could divest themselves of Canadian citizenship. The regulatory changes could result in less impact on clients, including financial impact, because there would be no cost associated with making a citizenship renunciation application.

Small business lens

Analysis under the small business lens concluded that the Regulations will not impact Canadian small businesses.

One-for-one rule

The one-for-one rule does not apply, as there is no incremental change in the administrative burden on business and no regulatory titles are repealed or introduced.

Regulatory cooperation and alignment

The Regulations are not related to a work plan or commitment under a formal regulatory cooperation forum.

Effects on the environment

In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA Directive), a preliminary scan concluded that a strategic environmental and economic assessment is not required.

Gender-based analysis plus

No impacts based on gender and other identity factors have been identified for the Regulations.

Implementation, compliance and enforcement, and service standards

Implementation requires updates to program delivery instructions and manuals, application kits, IT systems and web pages. These updates were implemented to correspond with Bill C-3 coming into force.

A high-profile proactive communications approach for the order in council is recommended. Messaging could be incorporated into communications products for the coming into force of Bill C-3, An Act to amend the Citizenship Act, which could include a news release, backgrounder, communications issue notes, social media and web sections.

Contact

Stephanie Jay-Tosh
Acting Senior Director
Legislative Policy
Citizenship Branch
Department of Citizenship and Immigration
180 Kent Street
Ottawa, Ontario
K1A 1L1
Email: IRCC.CITDGO-BDGCIT.IRCC@cic.gc.ca