Bill C-12: What Canada’s New Immigration Reforms Mean for Applicants and Entrepreneurs

Overview

Immigration, Refugees and Citizenship Canada (IRCC) is preparing for a major overhaul of its immigration application system through Bill C-12, introduced on October 7, 2025. Replacing Bill C-2, this new legislation expands the Minister of Immigration’s authority to cancel or suspend entire categories of applications. Currently at its second reading, Bill C-12 is expected to have sweeping implications for applicants stuck in long processing queues and those navigating Canada’s complex immigration pathways.

Key Legislative Changes

Bill C-12 amends Part 1 of the Immigration and Refugee Protection Act (IRPA), empowering the Minister to terminate or pause processing where backlogs undermine program integrity or operational efficiency. Unlike earlier transitional provisions that allowed limited cancellations through budget bills, Bill C-12 creates standing authority for broad cancellations via regulations or Ministerial Instructions (MIs).

Supporters argue this reform will help IRCC manage resources and maintain fairness across immigration programs. Critics warn that granting such discretion risks undermining the transparency and predictability of the system, potentially erasing years of effort for thousands of legitimate applicants.

Impact on the Start-Up Visa Program

The Canada Start-Up Visa (SUV) Program is expected to face the most significant disruption. As of mid-2025, the backlog stands at roughly 42,200 pending applications, with many entrepreneurs waiting more than three years—some over a decade—for decisions.

Nearly 80 percent of designated business incubators currently fail to meet the Ministerial Instructions (MI72) issued on April 30, 2024. Despite this, new applications continue to be filed, especially from Southeast Asia, China, and Iran, often supported by non-compliant incubators.

Under Bill C-12, IRCC could cancel these applications in bulk, eliminating the backlog and realigning processing capacity with government targets. However, this would come at a steep cost for applicants who have invested time, money, and effort under previously valid rules.

Balancing Efficiency and Fairness

The bill’s intent is to modernize and streamline immigration processing, aligning application volumes with Canada’s controlled migration objectives. Yet, the human cost of mass cancellations is difficult to ignore. Thousands of entrepreneurs and families risk losing their place in line—and their opportunity to immigrate—through no fault of their own.

At the same time, the legislation maintains a path for certain SUV applicants to obtain early work permits and temporary residence for themselves and their families shortly after filing permanent residence applications. This nuance shows IRCC’s continued support for genuine innovators while tightening oversight of non-compliant entities.

Compliance Risks and Practical Advice

Refusal rates among designated business incubators have surged to 73 percent in 2025, largely due to MI72 non-compliance. Many pending applications filed under earlier rules no longer meet updated standards, putting them at high risk of refusal or cancellation once Bill C-12 takes effect.

Prospective applicants should proceed with caution:

• Confirm incubator compliance with MI72 before applying.

• Avoid organizations that fail to meet current eligibility standards.

• Seek legal advice before investing or submitting new Start-Up Visa applications.

Conclusion

Bill C-12 marks a turning point in Canada’s immigration landscape—one that prioritizes efficiency and control but raises serious concerns about fairness and applicant rights. As Parliament continues to debate the legislation, individuals and immigration professionals must stay informed and prepared for significant procedural changes ahead. Potential applicants should exercise caution. Especially engaging with designated incubators that do no meet Ministerial Instructions (MI72), avoiding do so entirely as it increases the likelihood of cancellation with this new legislation.

How can Ayodele Law help you bring your business to Canada?

Ayodele Law represents both employers and workers navigating work-permit pathways, we stay at the forefront of Canadian immigration policy changes — including the evolving implications of Bill C-12. We can assist in assessing eligibility for the Start-Up Visa Program and exploring alternative pathways for work permits, permanent residence, or investor immigration. If you have a pending or planned application affected by Bill C-12, contact our office today for a personalized consultation.

📞 Contact us today for a consultation and find out how we can help you bring your business to Canada.