Citizenship Oath on a Click: My Submission

My submission in response to Canada Gazette, Part I, Volume 157, Number 8: Regulations Amending the Citizenship Regulations (Oath of Citizenship)


The planned change risks weakening the meaningfulness of Canadian citizenship by allowing the oath to be administered by a “non-authorized person” and thus citizenship ceremonies to be reduced if not eliminated in number.

The notice is lacking in any serious analysis apart from some generalities around potential cost and time savings. 

Given that the proposal focuses on cost savings due to a reduced number of ceremonies, one would expect, at a minimum, estimates of the number of applicants who would avail themselves of “ceremonies on a click” and the consequent number of reduced ceremonies. 

There is no analysis on the impact on the sense of belonging and attachment that moving to “ceremonies on a click” will have on new Canadians, nor is their any consideration of the historical context or the will of Parliament. It appears that no public opinion research was conducted regarding this proposed change as none is mentioned in the notice. 

This proposal has been widely criticized in commentary by myself and Senator Omidvar, former Governor General Clarkson, former Immigration Minister Marchi among others. These public commentaries, and the comments they have generated, need to be included along with formal comments like this one.


While IRCC has correctly focussed on modernization of the process such as e-applications, e-tests and an on-line application tracker in order to facilitate the process for applicants, in other areas it has weakened the meaningfulness, integration and sense belonging of becoming a citizen. The move to virtual citizenship ceremonies, needed during the pandemic, has less power and significance than in-person ceremonies, as anyone who has attended both can attest.

The proposed change would further weaken the act of becoming a citizen by eliminating or at least reducing the need for citizenship ceremonies, an objective explicitly stated in the “benefits and costs” section.

It is also against the wishes of Parliament, expressed as early as the first reading of the original Citizenship Act on October 22, 1945, when the then Secretary of State, Paul Martin Sr. spoke of the importance of citizenship ceremonies, stating that the legislation would:

“by appropriate ceremonies, impress upon applicants the responsibilities and privileges of Canadian citizenship” (House of Commons Debates, October 25, 1945, p. 1337 and s.38, Citizenship Act, 1946.)

Mr. Martin went on to state that new Canadians must:

“be made to feel that they, like the rest of us, are Canadians, citizens of a great country, guardians of proud traditions and trustees of all that is best in life for generations of Canadians yet to be … [and] have a consciousness of a common purpose and common interest as Canadians; that all of us be able to say with pride and say with meaning: “I am a Canadian.”” (House of Commons Debates, October 25, 1945, p. 1337)

At second reading, Mr. Martin reiterated that where ceremonies were taking place for Canadian ‘naturalization’ (which occurred prior to 1947), these ceremonies “have made a deep impression upon every new Canadian who has obtained Canadian naturalization.” He added that is was the Government’s “determination under the statutory provisions of this bill to frame regulations that will make these ceremonies more than ordinary procedure, and one of a memorable character.” (House of Commons Debates, April 2, 1946, p. 505)

Mr. Martin understood the importance of a ceremony to welcome new Canadians into the Canadian family and our practice of public ceremonies has been emulated by other countries who emulate the benefits of what we have been doing. It would be a betrayal of those who preceded us to do away with citizenship ceremonies.


The section focusses on the oath and ceremony as meeting the formal legal requirement and is silent on the broader implications on welcoming and belonging that citizenship ceremonies provide. There is no mention of public opinion research on attitudes towards citizenship ceremonies. 

Internal research and evaluations are similarly not mentioned. The 2013 IRCC Evaluation of the Citizenship Awareness Program noted: 

“Although newcomers have various reasons for getting their Canadian citizenship, the evaluation found that practical reasons, such as getting passports, ranked below more intangible reasons linked to their social integration, highlighting a role that promotion can have in creating a sense of belonging and permanency for newcomers to further encourage uptake.”

The 2020 Evaluation of the Citizenship Program also indicated that the “evidence suggested that wanting to feel fully Canadian and to make Canada their permanent home are primary motivators,” along with the need to “implement a new approach for the knowledge requirement, which could include a revised study guide and additional tools.” 

Public commentary in the media and social media indicate significant attachment to public ceremonies, whether in-person or virtual.  Again, there is no reference to the original will of Parliament that ceremonies take place and that:

“Since the passage of the Citizenship Act in 1947, Canadian citizenship policy has embodied two distinct objectives: i) to encourage and facilitate naturalization by permanent residents; and ii) to enhance the meaning of citizenship as a unifying bond for Canadians.” (2013 Evaluation)


IRCC is essentially arguing that becoming a citizen in front of an authorized person along with other to be Canadians is not worth a few hours of their time? Seriously? 

The experience that I and others have while attending citizenship ceremonies is that the ceremony is a very significant moment in the immigration and citizenship journey for them, their families and friends. This more than compensates for a few more months of processing time.

Again, the lack of public opinion research on this proposed change is telling, as this is one of the few public moments in the immigration, integration and citizenship journey, and one of the few positive experiences with the process.

Regulatory analysis—Benefits and costs

The aim is clearly cost reduction through the holding of fewer citizenship ceremonies:

“Consequently, it is expected that participation in ceremonies would be lower than it is currently, and there would likely be fewer ceremonies overall. Therefore, the Government of Canada would save costs, as the proposal would likely reduce the number of ceremonies the Department would be required to arrange.”

Tellingly, there is no data on the recent average costs of holding citizenship ceremonies, both in-person and virtual. And there are no estimated numbers of the reduction of citizenship ceremonies that would be needed to cover the ongoing costs of $5 million over 10 years. This amount is negligible in relation to the overall budget of the Citizenship Program.

Similarly, there are no  estimates on the number of persons who would likely choose this option and the consequently reduced number of ceremonies. This information, and the underlying assumptions, should be stated in the notice (the government of the day did so with respect to the 2014-15 increase in citizenship fees).

But more than the financial benefits and costs, this change fundamentally diminishes the symbolic and celebratory aspects of citizenship by eliminating the most significant part of the process of becoming a citizen, being among others from around the world who are taking the next step in their immigration and integration journey.  As Paul Martin Sr. said in 1946, we need ceremonies and they must be these “more than ordinary procedure, and one of a memorable character.”

There is no discussion on this most fundamental aspect of this change, nor acknowledgement of how this shift will affect applicants and their sense of participation and belonging. Citizenship is not a drivers license or health card; it is the means of having a secure home, of have the right to vote and participate in decisions regarding the present and future of Canada. 

Trying to justify these changes on inclusion grounds, given processing and ceremony time savings, misses the most important and fundamental inclusion which is the ceremony itself, with all its rituals and symbolism and welcome it provides.

With no public opinion research or consultations cited in the notice, likely that none was carried out, yet we know from commentary to date that this change is highly controversial.

Implementation, compliance and enforcement, and service standards

Will IRCC report on the expected up to three months processing time separately? Unlikely, so we will never know whether these savings were realized.

Will IRCC publicly report on the number of persons self-administering the oath and those in ceremonies on an annual basis as part of the department’s annual departmental plan and results report? Given the weakness of IRCC’s current reporting on the citizenship, and given no commitment is made in the Gazette, unlikely. 


IRCC should abandon these proposals and maintain Canada’s proud tradition of meaningful public citizenship ceremonies.

However, should IRCC proceed in this ill-advised change, several commitments need to be made:

  1. IRCC needs to include breakdowns between the number of new Canadians self-administering the oath and those participating in public ceremonies in its annual departmental plans and result reports;
  2. IRCC needs to share publicly any internal targets in terms of ceremony reductions in order to assess the impact of the change; and,
  3. IRCC needs to commit to public opinion research on the experience of new Canadians who self-administer the oath and those who participate in ceremonies, an interim public report two-years after the change comes into effect (June 2025) and a further public report five-years later (June 2028)

Finally, as it was Parliament that originally directed formal ceremonies to take place, Parliament ought to review any actions by IRCC that undermine the will of Parliament.

Please consider providing your views to the Government through the Gazette process:

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