
Canada has officially overhauled the most controversial section of its Citizenship Act. On 21 November 2025 Governor-General Mary Simon granted royal assent to Bill C-3, legislation that abolishes the so-called first-generation limit (FGL) and extends citizenship to thousands of people who—until now—could not pass on Canadian nationality to children born or adopted abroad.
Background: The FGL was introduced in 2009 to curb the growth of overseas Canadian communities with tenuous ties to the country. Critics quickly pointed out that globalised work patterns, dual-career couples and international adoptions made a strict one-generation cap unworkable. A 2023 Ontario Superior Court ruling agreed, declaring parts of the Act unconstitutional and setting the stage for legislative reform.
What changes: • Automatic citizenship will be restored retroactively to those who “would have been Canadians but for” the FGL; • Going forward, Canadians born or adopted abroad may transmit citizenship to children born or adopted outside Canada, provided the parent shows a “substantial connection” (definitions will follow in regulations); • IRCC confirms that applicants who filed under the interim measure need not re-apply once the new rules take effect.
Business impact: Multinational employers headquartered in Canada gain a significant talent-retention tool. Global assignees no longer face a hard choice between accepting an overseas posting and ensuring their future children’s citizenship rights. Mobility teams should update policy manuals and assignment letters to reflect the forthcoming regulations and advise affected employees to gather birth/adoption and proof-of-status documents in anticipation of an application rush once the in-force date is announced.
Practical tips: • HR should flag employees posted abroad for more than one year; they are the most likely to benefit. • Foreign spouses of “Lost Canadians” may also become eligible for expedited permanent residence through the family-class stream. • Expect IRCC to release detailed guidance and an online self-assessment tool in early 2026; encourage staff to sign up for IRCC email alerts.
Background: The FGL was introduced in 2009 to curb the growth of overseas Canadian communities with tenuous ties to the country. Critics quickly pointed out that globalised work patterns, dual-career couples and international adoptions made a strict one-generation cap unworkable. A 2023 Ontario Superior Court ruling agreed, declaring parts of the Act unconstitutional and setting the stage for legislative reform.
What changes: • Automatic citizenship will be restored retroactively to those who “would have been Canadians but for” the FGL; • Going forward, Canadians born or adopted abroad may transmit citizenship to children born or adopted outside Canada, provided the parent shows a “substantial connection” (definitions will follow in regulations); • IRCC confirms that applicants who filed under the interim measure need not re-apply once the new rules take effect.
Business impact: Multinational employers headquartered in Canada gain a significant talent-retention tool. Global assignees no longer face a hard choice between accepting an overseas posting and ensuring their future children’s citizenship rights. Mobility teams should update policy manuals and assignment letters to reflect the forthcoming regulations and advise affected employees to gather birth/adoption and proof-of-status documents in anticipation of an application rush once the in-force date is announced.
Practical tips: • HR should flag employees posted abroad for more than one year; they are the most likely to benefit. • Foreign spouses of “Lost Canadians” may also become eligible for expedited permanent residence through the family-class stream. • Expect IRCC to release detailed guidance and an online self-assessment tool in early 2026; encourage staff to sign up for IRCC email alerts.







