The Ontario Bar Association’s Citizenship and Immigration Law Section met with the Canada Border Services Agency (CBSA) in May 2025 for the biannual liaison meeting. These discussions offer a rare opportunity to engage directly with CBSA’s enforcement leadership, clarify operational trends, and flag emerging practitioner concerns.
Detention and Enforcement Priorities
CBSA confirmed that immigration enforcement, detention infrastructure, and meeting increased removal targets are top priorities for the current fiscal year. With the agreement between CBSA and Ontario’s correctional system set to end in September 2025, detention space will be consolidated at the Rexdale Immigration Holding Centre and through alternatives to detention (ATDs). Counsel should expect infrastructure changes at the Rexdale facility, including new sanitized units designed to support individuals with behavioural risks.
Enforcement numbers remain significantly lower than pre-pandemic levels. CBSA is not currently anticipating a surge in refugee claims from the United States but confirmed that contingency plans are in place.
Dormant Files and Delayed Enforcement Referrals
Counsel raised concerns about enforcement files that sit dormant for years before being referred to the Immigration Division. CBSA acknowledged this delay, noting that cases involving minor inadmissibility grounds (e.g., misrepresentation) may be deprioritized in favour of detained or more serious matters.
However, counsel are encouraged to reach out directly to CBSA to request assignment of files. Officers can elevate cases when appropriate, especially when prolonged delay may prejudice the client or intersect with a pending application.
No AI in Enforcement Decision-Making
CBSA confirmed that artificial intelligence is not used in enforcement decisions. This includes triaging, detention, removal, or risk assessment decisions in the immigration context. This confirmation applies strictly to immigration enforcement and not to customs or commercial units.
PRRA Eligibility and Call-In Timing
A recurring concern was the timing of call-ins for individuals with pending H&C, PRRA, or spousal sponsorship applications. Practitioners have encountered short-notice interviews and decisions that do not appear to reflect updated eligibility information.
CBSA explained that screening of PRRA eligibility may take place weeks, or even months, before the scheduled call-in. If a client becomes eligible after this point, the system may not automatically update the file. Officers are expected to verify eligibility before proceeding, but the current lag in file review may result in call-ins being issued based on outdated information.
CBSA committed to improving consistency and requested that specific cases of concern be flagged directly.
TRPs and Removability
CBSA confirmed that individuals with valid Temporary Resident Permits (TRPs) should not be scheduled for removal unless the TRP is cancelled. If a client on a valid TRP is called in, counsel should raise the issue directly with CBSA. No systemic issue was identified, but officers were reminded to verify active TRPs before enforcement action.
Looking Ahead
This meeting delivered several clear takeaways for counsel. First, confirm PRRA eligibility immediately if your client receives a call-in. Second, report removal notices issued to clients with valid TRPs. Third, if a file has sat dormant for years, do not wait, ask CBSA to assign it.
These insights are only possible through consistent liaison work between OBA members and the agencies we interact with every day. If you are not yet part of the OBA Immigration Section, consider joining. Section membership provides early access to updates like this one, an opportunity to raise concerns through liaison, and a community of counsel working to keep immigration law responsive, transparent, and accountable.
If you have questions or topics to raise at future liaison meetings, please contact the OBA Citizenship and Immigration Law Section Executive.
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