17 Sep The IRB’s New AI Ban: What It Means for Your Case and the Standard BGI Holds Itself To

By Bree Global Immigration | Reading time: ~6 minutes

A New Line in Canadian Immigration Practice

Effective September 7, 2026, the Immigration and Refugee Board of Canada drew a clear line on the use of artificial intelligence in proceedings before it. The IRB’s Practice Notice prohibits the use of AI to generate or materially alter personal narratives, affidavits, and witness statements filed in any IRB proceeding. Where AI has played any role, in translation, transcription, or drafting support, a signed disclosure declaration is now mandatory. Case law cited before the Board must be human verified; an AI summary does not meet the standard.

This is not a guideline. It is a binding procedural requirement with direct consequences for applicants and their representatives alike.

Bree Global Immigration holds the RCIC-IRB designation, the specific credential that authorizes a regulated consultant to appear and represent clients before the Immigration and Refugee Board. This Practice Notice sits squarely within our practice area. Our clients deserve to understand what it means and how we are responding to it.

The IRB and When It Enters Your Immigration Journey

For most applicants pursuing Canadian permanent residence through Express Entry or a Provincial Nominee Program, the IRB will not be part of their journey. But for those with more complex circumstances, the Board is where some of the most consequential decisions in Canadian immigration are made.

The IRB operates four divisions:

• The Immigration Division (ID) conducts admissibility hearings for individuals found to be inadmissible on grounds of criminality, security, or misrepresentation.
  
  
• The Immigration Appeal Division (IAD) hears appeals of removal orders, refused family sponsorship applications, and residency obligation decisions. If a sponsorship application for a spouse or parent has been refused by IRCC, or if a permanent resident faces a residency obligation concern after extended time abroad, the IAD is where those decisions are challenged.
  
  
• The Refugee Protection Division (RPD) decides refugee protection claims made within Canada.
  
  
• The Refugee Appeal Division (RAD) handles appeal’s of RPD decisions.

For Gulf-based clients, the IAD is the division most frequently relevant, particularly for family sponsorship refusals and residency obligation matters affecting permanent residents who have spent significant time outside Canada. The ID becomes relevant where inadmissibility grounds are in question.

What the Practice Notice Requires

The IRB’s position is precise. Three requirements apply to all proceedings before the Board:

• Personal evidence must be human authored. Narratives, affidavits, and witness statements cannot be generated or materially altered by AI. The substance and voice of personal evidence must come from the person providing it. A document produced or substantially shaped by an AI system does not meet the IRB’s evidentiary standard, regardless of how it is presented.
  
  
• AI involvement must be disclosed. Where AI tools have been used in any capacity, including translation, transcription, or any form of drafting assistance, a signed disclosure declaration must accompany the submission. The declaration must identify the tool used and the nature of its involvement.
  
  
• Case law must be read, not summarized. AI-generated summaries of jurisprudence are not acceptable substitutes for human review. Any decision cited before the Board must be verified by a representative who has read and understood it.
  
  

The consequences of non-compliance are significant. A document that does not meet these requirements may be rejected outright. Beyond rejection, non-compliant submissions risk adverse credibility findings against the applicant, a finding that can be extraordinarily difficult to overcome and that may determine the outcome of the entire proceeding. In serious cases, non-compliance may be referred to the CICC or a provincial law society for regulatory action against the representative.

Why This Is Particularly Relevant for Gulf-Based Clients

Clients based in the UAE, Qatar, Bahrain, Saudi Arabia, and Oman often arrive at IRB proceedings with documents that originated in Arabic, Tagalog, Hindi, Urdu, or other languages. The use of AI translation tools in preparing these documents for Canadian proceedings is common, and under the new Practice Notice, any such use must be formally disclosed.

An affidavit translated with an AI tool, submitted without a disclosure declaration, creates a compliance risk that extends beyond the document itself. It creates a credibility risk for the applicant.

This is not a hypothetical concern. It is a direct and immediate compliance requirement for any file where Gulf-originated documents are being prepared for IRB proceedings.

Bree Global Immigration’s Response

We have updated our intake and drafting protocols across all IRB files to reflect the Practice Notice requirements effective immediately.

Every personal narrative, affidavit, and witness statement prepared under our representation is developed directly with the client, in their voice, verified by them, and reviewed by our consultants before submission. Where translation assistance has been involved in the preparation of any document, that involvement is identified and disclosure declarations are prepared in accordance with the Board’s requirements. All case law cited in our submissions is read and verified by the RCIC responsible for the file.

The integrity of our clients’ evidence is not a process we delegate. It is a responsibility we carry personally on every file.

What the RCIC-IRB Designation Means in Practice

Not every immigration consultant is authorized to represent clients before the Immigration and Refugee Board. The RCIC-IRB designation is the specific credential that grants that authorization, and it requires a separate qualifying examination beyond the standard RCIC license.

The Board has its own procedural rules, its own evidentiary standards, and now its own binding requirements on how technology may be used in preparing evidence. Representation by someone specifically qualified in IRB practice is not a detail, it is the appropriate standard of care for a proceeding where the outcome can change the course of your life in Canada.

Bree Global Immigration holds the RCIC-IRB designation. When we take on an IRB file, our clients are represented by someone who is authorized, qualified, and current.

If Your Case Involves the IRB

If any of the following apply to your situation, this Practice Notice is directly relevant to how your case must be handled:

• A refused family sponsorship you intend to appeal at the IAD
  
  
• An inadmissibility finding or admissibility hearing before the ID
  
  
• A residency obligation matter, particularly relevant for permanent residents who have spent extended periods in the Gulf
  
  
• Any pending or anticipated IRB proceeding where affidavits, personal narratives, or witness statements will form part of the evidence

In each of these situations, how your evidence is prepared and presented is not a procedural formality. It is the substance of your case.

The Standard Does Not Change. The Rules Just Caught Up.

Regulatory developments like this Practice Notice are a reminder that immigration is a profession with real accountability, and that the representative you choose carries direct consequences for the outcome of your file.

At Bree Global Immigration, staying current on regulatory change is not optional. It is the baseline.

If you have an active IRB matter, anticipate one, or have questions about how these requirements affect your file, speak with our RCIC-IRB designated consultant today.

Every immigration profile is different. Speak with a Regulated Canadian Immigration Consultant at Bree Global Immigration for guidance tailored specifically to your situation.