Research and Evaluation
Evaluation of CIC’s
Visitor Visa Program
Evaluation Division
August 2012
Ci4-99/2012E
978-1-100-21569-3
Reference number: RR20120901
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Table of contents
Executive summary ......................................................................................................................................... ii
Evaluation of CIC’s Visitor Visa Program - Management response ................................................................. vii
1. Introduction ...................................................................................................................................... 1
1.1. Organization of the report................................................................................................................ 1
1.2. Program background ........................................................................................................................ 1
2. Methodology ..................................................................................................................................... 3
2.1. Evaluation scope ............................................................................................................................... 3
2.2. Approach .......................................................................................................................................... 3
2.3. Lines of evidence .............................................................................................................................. 3
2.3.1. Document review ----------------------------------------------------------------------------------------------------- 4
2.3.2. Key informant interviews ------------------------------------------------------------------------------------------- 4
2.3.3. Case studies ------------------------------------------------------------------------------------------------------------- 4
2.3.4. Administrative data analysis --------------------------------------------------------------------------------------- 5
2.3.5. Literature review ------------------------------------------------------------------------------------------------------ 5
2.4. Limitations and considerations ........................................................................................................ 6
3. Findings ............................................................................................................................................. 7
3.1. Relevance ......................................................................................................................................... 7
3.1.1. Continued need -------------------------------------------------------------------------------------------------------- 7
3.1.2. Alignment with GoC and CIC objectives and outcomes ----------------------------------------------------- 9
3.1.3. Alignment with roles and responsibilities --------------------------------------------------------------------- 10
3.2. Performance policy ...................................................................................................................... 11
3.2.1. Visa policy framework ---------------------------------------------------------------------------------------------- 11
3.2.2. Country monitoring -------------------------------------------------------------------------------------------------- 13
3.2.3. Partner consultations ----------------------------------------------------------------------------------------------- 15
3.2.4. Visa policy recommendations ------------------------------------------------------------------------------------- 16
3.3. Performance implementation ..................................................................................................... 18
3.3.1. Processing -------------------------------------------------------------------------------------------------------------- 19
3.3.2. Communications------------------------------------------------------------------------------------------------------ 25
3.4. Performance Achieving integrity and facilitation outcomes ....................................................... 26
3.4.1. Integrity of the immigration system ---------------------------------------------------------------------------- 26
3.4.2. Integrity of the asylum system ----------------------------------------------------------------------------------- 30
3.4.3. Facilitation of travel ------------------------------------------------------------------------------------------------- 33
3.4.4. Balancing facilitation with integrity ----------------------------------------------------------------------------- 38
3.4.5. Other impacts related to visa requirement changes ------------------------------------------------------- 39
3.5. Efficiency, economy and alternatives ............................................................................................. 41
3.5.1. Resource utilization -------------------------------------------------------------------------------------------------- 41
3.5.2. Alternatives ------------------------------------------------------------------------------------------------------------ 44
4. Conclusions and recommendations ................................................................................................. 50
Appendix A: Evaluation matrix .................................................................................................................. 53
Technical appendices are available upon request to Research_Re[email protected]
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Executive summary
Purpose of the evaluation
This report presents the findings of the evaluation of CIC‘s Visitor Visa Program. This evaluation
was completed to meet the requirements of the Directive on the Evaluation Function (TBS, 2009),
and the commitments made in CIC’s Performance Measurement and Evaluation Plan (PMEP)
relating to the visa imposition on Mexico. The purpose of this evaluation was to assess the Visitor
Visa Program in relation to:
Continued Program relevance;
Program performance; and
Resource utilization and alternatives.
The data collection for the evaluation was undertaken by CIC’s Research and Evaluation Branch
(R&E) between April 2011 and January 2012.
Visitor Visa Program background
Throughout the report the term “Visitor Visa Program” should be understood as comprising of the
following two components:
Policy component
Under the Immigration and Refugee Protection Act (IRPA), every foreign national travelling to Canada
must obtain a temporary resident visa (TRV) before arriving, except where an exception is granted
to citizens of selected countries under section 190
1
of the IRP Regulations. Any changes in visa
requirements are grounded in CIC’s visitor visa framework. Ongoing monitoring, country reviews
and consultations are carried out to inform visa policy recommendations (whether citizens from a
particular country require a visa or not).
Implementation component
A foreign national needs to apply for a TRV at a Canadian visa office abroad. If the application is
accepted, the TRV is issued to the applicant and they may travel to Canada, subject to the
determination of entry by the Canada Border Services Agency (CBSA) at a port of entry (POE).
CIC informs potential travellers about the requirements for a visa and processes the applications
once received.
Program objectives/outcomes
CIC’s Visitor Visa Program seeks to achieve a balance between facilitating legitimate travel while
protecting the integrity of the immigration and asylum system and, in the longer term, protecting
the health, safety and security of Canadians.
1
Section 190 of the IRP Regulations identifies which countries do not require a visa to enter Canada. In addition,
persons described in R39 and holders of Temporary Resident Permits (TRPs) are also exempted from the TRV
requirement; however, those exemptions are outside the scope of this evaluation.
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Methodology
The key areas of study are the following:
CIC’s country-level visa policy: focuses on the assessment of the policy framework and the
evidence gathered to support recommendations for visitor visa requirement changes;
Implementation of visa regulations: an examination of visa processing activities in missions
abroad and related communications activities; and
Mexico visa regulatory change: an examination of the design, implementation, and impact
(performance) of the Mexico visa regulation (as required by the regulatory PMEP).
The evaluation focused on the relevance and performance of the Visitor Visa Program, as well as an
examination of alternatives. Lines of evidence drawn upon for this evaluation included interviews,
document review, literature review and analysis of administrative data. Four case studies were
examined, with a separate report on the Mexico regulatory change.
Limitations
There were a number of limitations that should be considered in the context of this report. These
include the fact that the perspectives of affected country representatives and international partners
were not included in the evaluation; and that, at the time of data collection, CIC was introducing
several initiatives intended to streamline visa processing. Because they had not been in place for a
sufficient length of time, the evaluation was not able to assess their effectiveness. However, it is
important to note that these limitations have not significantly influenced the findings, conclusions
or recommendations made in the evaluation report.
Evaluation findings
The main findings associated with each of the evaluation questions are presented below.
Relevance
There is a continued strong need to facilitate and control the movement of temporary residents.
The visitor visa addresses this need and is used by Canada to leverage the benefits and decrease the
risks associated with the temporary movement of foreign nationals to and from Canada.
The objectives of the visa policy framework are consistent with Government-of-Canada (GoC) and
CIC priorities, objectives and outcomes. Under the revised CIC PAA, the alignment of the Visitor
Visa Program under Strategic Outcome 4 (Managed migration that promotes Canadian interests
and protects the health, safety, and security of Canadians) obscures the dual nature of the
Program’s objectives, which are intended to balance facilitation of travel and protection of the
integrity of the immigration and refugee system.
With its specific dual mandate, CIC is the most appropriate federal department to design and
implement Canada’s Visitor Visa Program even though there may be some overlap with the
protection and facilitation mandates of other federal departments.
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Performance
Policy
CIC’s policy framework and monitoring and country review processes are viewed as adequate. The
criteria and thresholds largely match international practices, although few countries use refugee
claim rates as an indicator to inform their visa changes. Some indicators of system integrity risks
(such as overstays) are not currently included in the process due to lack of data collection systems.
CIC engages appropriate partners and there is adequate collaboration to inform visa
recommendations; some OGDs feel that they are not engaged early enough in the process or that
their views have not always been reflected in the final decision.
Monitoring and evidence from country reviews are regularly used to support visa policy
recommendations and the regulatory process. However, evidence is ultimately weighed and other
internal and external factors play a part in the final decision to impose or lift a visa.
Implementation
CIC has been able to meet the processing demand for TRVs to date with some extension of time
required to process applications. While CIC has the capacity to address seasonal fluctuations,
addressing major regulatory changes requires additional resources. Recent streamlining initiatives
show some positive effects on processing activities; however, it is too early to assess their long-term
impact.
The timeliness and breadth of CIC’s communication strategies related to immigration are
reasonable and address a variety of potential client information needs. As materials supporting
decisions on changes to visa requirements are subject to Cabinet confidence, CIC faces
communication constraints related to the timing of information being released to partners,
stakeholders and to the public.
Achieving outcomes
The visitor visa is an effective tool that helps protect the integrity of CIC’s immigration and asylum
system through selecting low-risk countries for visa-free travel, and potentially acting as a deterrent
for non-bona fide travellers. Its role as a mechanism to prevent immigration violations is less
certain. The impact of the visitor visa on irregular migration is difficult to measure due to lack of
data on certain indicators (e.g. overstays).
CIC’s Visitor Visa Program facilitates the movement of bon fide travellers, as evidenced by the fact
that the TRV processing requirements are similar to those in other countries; by reaching CIC
targets for approval rates; and by introducing other facilitative approaches and tools.
CIC’s visitor visa policy, supported by other tools with similar objectives, is largely perceived to
have successfully achieved a balance between protecting the integrity of its immigration and asylum
system and the facilitation of bona-fide travel to Canada. In addition, the visa policy is flexible and
has the ability to allow CIC to react to contextual changes.
The removal of visa exemptions affects Canada’s bilateral relations with countries impacted by the
change. Furthermore, the introduction or removal of visitor visa requirements can impact CIC
partners’ operations and political mandates.
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There is a potential negative impact on the Canadian tourism industry when a visa exemption is
removed, as it is expected to result in a decrease in the number of travellers from the affected
country. Conversely, when a visa exemption is granted, it should have a positive impact on tourism.
The available evidence supports these assumptions, although data on the magnitude of the impact
are mixed.
Costs and alternatives
Although the evaluation framework did not include a detailed analysis of program costs, available
data suggests that there are several financial resource implications associated with TRVs.
Furthermore, according to internal financial data, the costs of processing a visa are higher than the
revenue generated from TRV fees.
There are several potential alternatives to CIC’s approach to TRVs. While they are unlikely to better
meet CIC’s facilitation and integrity objectives at the present time, some could be effectively used
to supplement existing frameworks, tools and indicator, thereby creating a more encompassing
system.
Relevance/alternatives
The visitor visa is a relevant tool as it addresses the need to manage the movement of temporary
residents. It remains widely used by peer countries. In the majority of cases, Canada’s visa
exemption list aligns with its peers. This creates an environment where Canada facilitates travel,
while preventing the entry of travellers that could pose risks to the integrity of the immigration and
asylum system and the safety and health of Canadians.
While potential alternatives to Canada’s visitor visa exist, such as an electronic travel authorization
(eTA) system, the visitor visa will remain the most effective tool to manage migration until other
tools are further investigated / implemented and their effectiveness is assessed.
Recommendation #1:
Canada should continue using the visitor visa as a tool to manage migration,
while at the same time investigate the feasibility of introducing supplementary tools to better meet its objectives
(protection and facilitation). In doing so, CIC should take into account the benefits, risks and resource needs
associated with implementing each option.
Performance
Policy
Monitoring and evidence from country reviews are regularly used to support visa policy
recommendations and the regulatory process. However, the visitor visa program, as currently
designed, focuses on CIC’s own objectives and is not taking a whole-of-government approach.
While the policy process seeks input of relevant other government departments, there is a need to
improve their involvement and participation in analysis and decision-making processes.
Recommendation #2:
CIC should assess, with its federal government partners, the strengths and
weaknesses of the current partner engagement strategy in visa policy development, to address their needs and
concerns and gauge the feasibility of broadening the considerations during the visa review process, towards an
increased whole-of-government approach.
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Processing
The evaluation presented recent CIC efforts to introduce or expand various facilitative
mechanisms; such as VACs, multiple entry visas, long-term visas, business express program, etc. to
ensure streamlining of processing of applications. Those initiatives have the purpose of creating
streamlined processes to make it easier for clients to visit Canada and reduce resource utilization at
CIC. As those are fairly new initiatives, this evaluation did not assess effectiveness of those
mechanisms at this point.
In addition, the evaluation reviewed the role of the VAC in supporting processing in Mexico,
identified some benefits but also the importance of undertaking performance and contract reviews
to ensure compliance. With expansion of the VAC network in the world, CIC is relying increasingly
on a variety of third-party organizations to support the TRV process. The expansion of VAC to a
global network is a new initiative and creates new opportunities and possible challenges.
Recommendation #3:
CIC should develop strategy and assessment tools to measure the impact of the
various facilitative mechanisms, in terms of their objectives and effectiveness in managing processing demands.
This should also include an assessment of the VAC network and its effectiveness in assisting the modernizing
of CIC operations.
Integrity of the immigration and asylum systems
The visitor visa is an effective tool that helps protect the integrity of CIC’s immigration and asylum
system by reducing irregular migration (primarily unfounded refugee claims), and potentially
playing a deterrence role. Measuring the overall impact of the visa on irregular migration is
challenging due to lack of data on certain indicators (i.e. overstays, illegally working in Canada, etc.).
Recommendation #4:
CIC should explore other, more effective methods of collecting data on irregular
migration, such as overstays, to better inform policy-makers about the success of the program in achieving its
immigration and asylum system integrity objectives.
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Evaluation of CIC’s Visitor Visa Program - Management response
Recommendations
Response
Action
Accountability
Completion
date
1. Canada should continue
using the visitor visa as a
tool to manage migration,
while at the same time
investigate the feasibility
of introducing
supplementary tools to
better meet its objectives
(protection and
facilitation). In doing so,
CIC should take into
account the benefits, risks
and resource needs
associated with
implementing each option.
CIC agrees with this finding.
As a result of this evaluation as well as initiatives under
development as part of the Canada-US Shared Vision for
Perimeter Security and Economic Competitiveness, CIC will
undertake a review of the visa policy framework to ensure it
continues to meet the objectives to manage migration to
Canada and it is positioned to support the introduction of
supplementary tools.
One such initiative, the Electronic Travel Authorization
(eTA), is under development to allow Canada to screen
visa-exempt travellers before travel to Canada. In the long
term, the introduction of the eTA, planned for 2015-16, will
enable CIC to explore new options to improve the balance
between protection and facilitation.
CIC will launch and complete the
review of the visa policy
framework.
Put in place the authorities and
tools required to support the
implementation of the eTA
programme
Admissibility
Admissibility
Q4 2012-13
Q4 2015-16
2. CIC should assess, with its
federal government
partners, the strengths and
weaknesses of the current
partner engagement
strategy in visa policy
development, to address
their needs and concerns
and gauge the feasibility of
broadening the
considerations during the
visa review process,
towards an increased
whole-of-government
approach.
CIC partially agrees with this finding.
Consultations with federal government departments are an
intrinsic part of the country monitoring and reviews as well as
the decision-making process on changes in visa requirements.
CIC will continue its engagement of its federal partners, and
encourages their participation, to identify the full range of
considerations and potential impacts related to changes in
visa requirements.
Ultimately, however, Canada’s visa policy and visa
requirements serve to manage migration to Canada. Thus,
while efforts are made within the review process to identify
impacts and considerations related to Government of Canada
priorities and interests, decision-making will continue to be
based within an approach that balances the facilitation of
travel with the need to protect the health, safety and
security of Canadians.
Continue to engage federal
government departments and
agencies on country reviews and
proposed changes to Canada’s
visa requirements.
As part of the Review of the visa
policy framework, in consultation
with its partners, CIC will review
its engagement practices and
strategies to ensure they are
relevant and sufficient to gather
and represent the considerations
and views of partners.
Admissibility
Admissibility
Ongoing
Q4 2012-13
- viii -
Recommendations
Response
Action
Accountability
Completion
date
3. CIC should develop strategy
and assessment tools to
measure the impact of the
various facilitative
mechanisms, in terms of
their objectives and
effectiveness in managing
processing demands. This
should also include an
assessment of the VAC
network and its
effectiveness in assisting
the modernizing of CIC
operations.
CIC agrees with this finding.
In preparation for the expansion of the global VAC network
beginning in Fall 2012 CIC is standardizing a governance
framework with a three-tiered reporting structure between
CIC and the Contractor. Regular reports will be required from
the Contractor which will be reviewed by CIC. A Performance
Measurement Plan consisting of contractor compliance,
quality assurance reviews and formal audits is also being
developed.
To better monitor the progress of modernization initiatives,
CIC has developed a Modernization Performance Management
Framework that provides a structured approach for
measuring and reporting on modernization outputs and
outcomes over the next three years. In order to respond to
increasing processing demands, CIC aims to maximize
effectiveness through modernization initiatives that will
increase centralization of intake and processing of
applications, increased network-wide flexibility of workload
distribution, improved risk management and program
integrity. In addition, CIC will gain efficiencies through
improvements to application submission options, including
e-applications for TR and implementation of paperless
processing using e-storage and e-payment.
The new global VAC contract will
include a standardized framework of
governance including a three-tiered
reporting structure including a
Performance Management Plan is
being developed and will be
implemented with the deployment
of each VAC as part of the global
network.
Monitor and Report Modernization
through:
Modernization Measurement Plan
Modernization Roadmap
Modernization Dashboard
Operations/
International
Region
Operations/
OPMB
Ongoing
Ongoing
4. CIC should explore other,
more effective methods of
collecting data on irregular
migration, such as
overstays, to better inform
policy-makers about the
success of the program in
achieving its immigration
and asylum system integrity
objectives.
CIC agrees with this finding.
While the Government of Canada does not yet systematically
collect data on overstays, it is expected that the Entry-Exit
Information System initiative, which is to be implemented
under the Canada-US Shared Vision for Perimeter Security
and Economic Competitiveness and led by the Canada Border
Services Agency (CBSA), will provide CIC with additional data
on irregular migration which will bolster CIC’s visa policy
framework and review process.
Undertake a review of data
requirements to support country
monitoring and visa policy
changes as part of the Review of
the Visa Policy framework.
Work in collaboration with the
CBSA to identify and leverage the
potential for new data and
information sources.
Admissibility
Admissibility
Q4 2012-13
Q4 2014-15
(and
ongoing)
1
1. Introduction
This report presents the findings of the evaluation of the CIC Visitor Visa Program. This
evaluation was completed to meet the requirements of the Directive on the Evaluation Function
(TBS, 2009), and the commitments made in CIC’s Performance Measurement and Evaluation Plan
(PMEP) relating to the visa imposition on Mexico. The purpose of this evaluation was to assess the
Visitor Visa Program in relation to:
Continued Program relevance;
Program performance; and
Resource utilization and alternatives.
It is important to note that a “Visitor Visa Program” does not exist in the Department as a
traditional program; rather, CIC’s Admissibility Branch is responsible for the development and
maintenance of Canada’s visa policy that governs whether or not citizens from a particular country
require a visa to enter Canada. This policy is operationalized through CIC’s International Region by
processing temporary resident visas abroad. These two components fall under the Program
Activity Architecture (PAA) element 4.2.2 Visitors, which is part of Strategic Outcome 4
Managed migration that promotes Canadian interests and protects the health, safety, and security of Canadians.
Therefore, for the purposes of simplification, throughout the report the term “Visitor Visa
Program” should be understood as referring to both of these components collectively.
1.1. Organization of the report
The report consists of four sections: Chapter 1 provides the background of the program; Chapter 2
describes the methodology used to conduct the evaluation; Chapter 3 presents the evaluation
findings and evidence; and Chapter 4 contains recommendations based on the findings and
conclusions of the evaluation.
1.2. Program background
Under the Immigration and Refugee Protection Act (IRPA), every foreign national travelling to Canada
must have a temporary resident visa (TRV) before arriving, except where an exception is granted to
citizens of selected countries under section 190
2
of the IRP Regulations.
A foreign national who wishes to come to Canada from a visa-required country needs to apply for
a TRV at a Canadian visa office abroad (CVOA). If the application is accepted, the TRV is issued to
the applicant in their travel document and they may travel to Canada, subject to the determination
of entry by the Canada Border Services Agency (CBSA) personnel at a port of entry (POE).
There are many potential benefits that result from the temporary migration of foreign visitors to
Canada, such as the development and growth of the tourism industry, increases to trade and
international understanding, and cultural exchanges. While Canada may benefit from international
travel, it may also be exposed to risks ranging from the potential spread of infectious diseases,
admission of persons who pose a safety or security risk, transnational crime, and human trafficking.
Canada assesses countries against several criteria and risk factors when deciding whether to lift or
impose a visa requirement. From 2002 to 2012, visa exemptions were extended to nine countries,
2
Section 190 of the IRP Regulations identifies which countries do not require a visa to enter Canada. In addition,
persons described in R39 and holders of Temporary Resident Permits (TRPs) are also exempted from the TRV
requirement; however, those exemptions are outside the scope of this evaluation.
2
while visa requirements were introduced for five countries. Citizens of 55 countries and territories
are currently visa-exempt for travel to Canada, while citizens of 142 countries and territories are
visa-required.
For the countries for which a visitor visa is required, the processing of visitor visa applications from
persons intending to travel to Canada is carried out by CIC in the missions abroad, in cooperation
with its federal partners. In total, there are 86 offices with CIC presence abroad in 72 countries;
currently 64 are processing visitor visa applications. In 2010, CIC processed applications from over
one million persons seeking temporary resident visas as tourists and business visitors to Canada,
and issued visitor visas, permits and extensions to around 865,000 persons.
Visitor Visa Program
The following sections describe the key activities and outcomes of the Visitor Visa Program (see
Technical appendices) stemming from the two components of the Program: policy and
implementation.
Visa Policy: The following activities take place to inform recommendations on the exemption or
re-imposition of a visa requirement:
Visa policy framework development: In 2005, CIC established a set of formal criteria to be
used to guide the development of visa policy recommendations; including indicators and
threshold values.
Country monitoring: This refers to the activities that gather evidence on country conditions,
to support ongoing risk analysis, as well as the development of recommendations.
Consultations/coordination: To support the development of visa requirement
recommendations, CIC conducts consultations with other federal government partners.
The above activities are designed to enable CIC to make recommendations that are evidence-based,
risk-based, and consultative (immediate outcome).
Implementation: The implementation component of the Visitor Visa Program has the following
key activities:
Processing: CIC officers assess applications, in cooperation with federal security and health
partners. If the application is accepted, the TRV is issued to the applicant as a secure
counterfoil document affixed to their passport and they may travel to Canada. It is important to
note that a TRV does not guarantee entry to Canada; entry is still subject to determination by
the Canada Border Services Agency (CBSA) personnel at the POE.
Communications: Regular communications are required in order to provide potential
applicants with timely information on application requirements, processing, timelines, etc. In
the case of changes to the visitor visa policy, these decisions must be communicated to the
affected stakeholders.
These activities should result in informing relevant stakeholders about visa requirements and
meeting the demand for visitor visas (immediate outcome).
At the intermediate level, both components of the CIC’s Visitor Visa Program seek to balance the
objectives of facilitating legitimate travel while protecting the integrity of the immigration and
asylum system and, in the longer term, protection of Canada’s interests and the health, safety and
security of Canadians.
3
2. Methodology
2.1. Evaluation scope
Data collection for this evaluation took place between April and December 2011, with the
evaluation covering April 2005 to March 2011. Some recent events are reflected in the report as
context for the purpose of capturing further developments in the visitor visa program. The key
areas of study are the following:
CIC’s country-level visa policy: focuses on the assessment of the policy framework and the
evidence gathered to support recommendations for visitor visa requirement changes;
Implementation of visa regulations: an examination of visa processing activities in missions
abroad and related communications activities; and
Mexico visa regulatory change: an examination of the design, implementation, and impact
(performance) of the Mexico visa regulation.
There are several issues directly or tangentially related to the visitor visa continuum that are beyond
the scope of this report and will be assessed within other evaluations. These issues include: health
and security screening and the in-Canada asylum system. While this evaluation does not
comprehensively examine these issues, they are described in the context of the visitor visa
continuum.
Prior to the completion of this report, in November 2011, the Office of the Auditor General
(OAG) released its Fall report, one chapter of which pertained to the issuance of visas. Although
there is some overlap between that report and this evaluation, the focus of the OAG audit was “to
determine whether CIC and CBSA have managed the risks associated with determining
admissibility under the Act’s provisions related to health, safety, and security before issuing visas to
foreign nationals,”
3
rather than the broader visa policy framework development and
implementation examined in the current study.
4
2.2. Approach
The evaluation focused on the relevance and performance of the Visitor Visa Program, as well as an
examination of alternatives (see Appendix A: Evaluation matrix).
The evaluation did not use an experimental design as it was not possible to create a control group.
Certain elements of a quasi-experimental design were applied when comparing the pre- and post-
situations of the case study countries, and when comparing the visa-required and non-required
countries.
2.3. Lines of evidence
Several lines of evidence were used for this evaluation, including both quantitative and qualitative
sources. Each evaluation question was assessed using at least two lines of evidence. Using multiple
3
Office of the Auditor General, 2011. “Fall Report of the Auditor General, Chapter 2: Issuing Visas”.
www.oag-bvg.gc.ca/internet/English/parl_oag_201111_02_e_35934.html
4
Note: Both CIC and CBSA have accepted the recommendations made by the Auditor General, and have provided
action plans for addressing the issues raised in that report.
4
lines of evidence allowed questions to be examined from several perspectives, providing greater
reliability and validity of the findings when these lines of evidence converged.
2.3.1. Document review
A document review was conducted to provide descriptive information on the two components of
the visitor visa program, as well as information to address evaluation questions relating to program
relevance and performance. Documents reviewed included legislation, policy documents, process
and procedure documents, operational manuals and bulletins.
2.3.2. Key informant interviews
Interviews with key informants were held to address all evaluation questions. Only one
comprehensive interview guide was developed, as many interviewees had been involved in different
components of the program, and could thus potentially respond to the full set of questions. The
evaluation aimed to obtain perspectives from both sides of the spectrum the facilitative and the
protective one. A total of 31 interviews were completed, as follows:
CIC managers and officers at NHQ (n=15)
CIC managers and officers at selected missions (n=7)
Representatives from other federal departments, focused on protective aspects, such as
partners participating in the policy working group and involved in screening activities (CBSA,
RCMP) (n=4)
Representatives of partners and stakeholders with facilitative mandates, such as DFAIT,
Industry Canada, and the Canadian Tourism Commission (n=5)
Interviews lasted between 45 minutes and two hours. Not all informants responded to all
questions; this was taken into account when analysing the data (Technical appendix). Where
qualitative evidence is presented, the following scale was used to report:
Interview data analysis scale
Findings reflect the views and opinions of 100% of the key informants in the group
Findings reflect the views and opinions of at least 75% but less than 100% of key informants in
the group
Findings reflect the views and opinions of at least 50% but less than 75% of key informants in the
group
Findings reflect the views and opinions of at least 25% but less than 50% of key informants in the
group
Findings reflect the views and opinions of at least two respondents but less than 25% of key
informants in the group
2.3.3. Case studies
Case studies provided a means of examining key visa requirement changes, as well as the
implementation of these decisions. Two of the case study countries had a visa exemption removed
and two had visa exemption granted in the period under review. The case study countries were as
follows:
Czech Republic (2009 visa exemption removed)
5
Mexico (2009 visa exemption removed)
Poland (2008 visa exemption granted)
Taiwan (2010 visa exemption granted)
These case studies included a review of planning documents and interviews with key informants
who had first-hand involvement with the development and/or implementation of these policy and
implementation activities, such as processing and communications, especially as related to the
Mexico case study. An assessment of administrative and operational data pertaining to the missions
serving these countries was also conducted. For the Mexico case study, a field visit was conducted
in September 2011 that included a site examination, as well as interviews with personnel located in
the Mexico City mission and Visa Application Centre (VAC). While information on all case study
countries is provided throughout the report, a separate report was developed for the Mexico case
study as required by the PMEP. It is included in the Technical appendix.
2.3.4. Administrative data analysis
CIC has several information systems (CAIPS, GCMS and FOSS) that provide administrative data
on the monitoring criteria and processing of visitor visa applications. The analysis of these data was
a key source of information for program performance. Data was also provided by program delivery
partners (e.g., the number and type of inadmissibility reports issued by CBSA) and other
government departments and agencies (e.g., StatsCan data on the number and origin of travellers to
Canada).
2.3.5. Literature review
Context review
A review of literature discussing temporary resident migration management was conducted by the
evaluation team to obtain perspectives and information regarding trends in the temporary
movement to support the assessment of relevance. The literature reviewed focused on the need for
border and entry control and for the facilitation of travel.
Alternatives study
As a means of obtaining an additional perspective on the relative merits of Canada’s approach to
the management of temporary resident admissions, an external academic expert was commissioned
to undertake a comparative study of the frameworks employed by Australia, the U.S., and the
European Union. Key issues examined through the study related to the rationale for these different
approaches, the contexts under which they were introduced, the strengths and weaknesses of these
approaches with respect to balancing travel facilitation and security safeguarding, the impacts, and
lessons learned to date. The report is provided in the Technical appendix, and includes a list of the
literature and documents reviewed.
6
2.4. Limitations and considerations
There were a number of limitations that should be considered in the context of this report.
However, it is important to note that these limitations have not significantly influenced the
findings, conclusions or recommendations in the evaluation.
Perspectives of affected country representatives: Given the sensitive nature of the visa
requirement decisions, representatives of affected countries were not approached for
comments. Their input could have been affected by the nature of the decision and it was
deemed not appropriate for the analysis. To mitigate this, attention was paid to information
about country reactions to visa requirement decisions coming from other sources (e.g., media,
Canadian representatives abroad, and policymakers).
Perspectives of international partners: Given the difficulty in reaching international
partners and the limited value of this perspective in informing the evaluation, interviews with
international partners were omitted, in favour of the analysis of alternatives used in other
countries. This allowed for a more in-depth and objective assessment of the effectiveness of
various alternatives.
Process streamlining initiative results: At the time of data collection, CIC was introducing
several initiatives intended to streamline visa processing (e.g.; Visa Application Centres,
multiple-entry visas, long-duration visas). Because they had not been in place for a sufficient
length of time, the evaluation was not able to assess their effectiveness.
7
3. Findings
3.1. Relevance
Using information from the document review, interviews, administrative data analysis, literature
review, and case studies, this section presents the key findings regarding the relevance of the Visitor
Visa Program.
3.1.1. Continued need
The objective of CIC’s Visitor Visa Program is to facilitate the movement of bona fide travellers
while protecting the integrity of Canada’s immigration and asylum system, and the health, safety,
and security of Canadians. The need to control and facilitate the temporary resident movement,
and the need for the visitor visa as an instrument are reviewed in this section.
Finding: There is a continued strong need to facilitate and control the movement of temporary
residents. The visitor visa addresses this need and is used by Canada to leverage the benefits and
decrease the risks associated with the temporary movement of foreign nationals to and from
Canada.
As noted in the literature, “global international migration has undergone a transformation in the
last decade and one of the main elements in this has been the substantial increase in non-permanent
… migration between nations.”
5
In Canada, the number of visa applications (persons) has
increased since 2007 (from 1,231,081 TRV applicants in 2007 to 1,367,831 in 2011, representing an
11% increase). Furthermore, according to the United Nations World Tourism Organization,
international tourist arrivals globally grew by over 4% in 2011 to 980 million, with growth expected
to continue, on track to reach one billion tourists in 2012.
6
This trend is linked to the development
of means of transportation, communication technologies, increased knowledge of other countries,
and the growth of social networks that extend beyond one’s own country/community.
The document and literature review and almost all interview respondents indicated a strong need
for Canada to continue to control the movement of temporary residents, including visitors, for
several reasons: need for managed access to Canada; protection of the health, safety and security of
Canadians; program integrity; and the facilitation of travel to leverage benefits.
Manage access/control movement
Historically, the ability to precisely define (and control) borders is one of the hallmarks of the
modern state.
7
Growing internationalization makes it harder to retain control over one’s borders
and the policies enacted therein.
8
In this vein, most interviewees confirmed that there is a need to
manage access to Canada in order to ensure an orderly flow and that those who enter Canada meet
the requirements of entry.
Globally, visitor visas are an internationally accepted and prevalent practice. Each country
determines who is allowed to enter and for how long. The EU’s Schengen Zone is the most
noteworthy visa-free zone; however, even in the EU, while there is borderless travel within the
5
Circular migration, keeping development rolling. Graeme Hugo, University of Adelaide, IOM. 2008.
6
media.unwto.org/en/press-release/2012-01-16/international-tourism-reach-one-billion-2012
7
Stanford Encyclopedia of Philosophy, 2010. “Sovereignty.” plato.stanford.edu/entries/sovereignty/
8
Hall, Stuart et al., eds, 1996. Modernity: An Introduction to Modern Societies. Maidenhead: Open University Press
8
zone, there are still visa requirements for countries to enter the external border of the EU. The
prevalence of visa requirements around the globe suggests that Canada’s visitor visa tool, with its
broad requirements and country exemptions, is aligned with those employed by other countries to
achieve similar objectives.
Some interviewees commented that the visa has been one of the few tools a country has to control
access. The majority of interviewees described the need for the visitor visa mechanism as relating to
the fact that it is more difficult to remove that individual if they do not abide by the terms and
conditions of entry than to pre-emptively deny them entry. Even the interviewees who stressed the
need to facilitate travel for economic purposes and other benefits affirmed the need for a
mechanism, such as a visitor visa, to control against the risks associated with over-generous
facilitation.
Protection of the health, safety and security of Canadians
The literature, documents and key informants frame the need to control the movement of
temporary residents as a mechanism to protect the health, safety and security of Canada. Events
such as Sept 11th, 2001, and major health disasters such as the SARS and the H1N1 pandemic,
have contributed to migration policies becoming more concerned with heightened security, and
global health issues. In particular, this need for control is similar to the rationale for controlling the
admission of those who seek to become permanent residents of Canada. In both cases, the benefits
of allowing people into the country (e.g., economic, intellectual, and cultural exchanges) need to be
weighed against the risks presented by those seeking to enter the country (e.g., threats to the health,
safety, and security of Canadian residents). The temporary resident visa aims to serve as an
admissibility and screening tool that helps to ensure the balance of these factors.
9
Furthermore, the
majority of interviewees noted that threats from drug and human trafficking, terrorism, as well as
potential criminal activities, result in a need to control who enters the country.
Program integrity
Internal CIC documents and many key informants clearly articulated a need to control temporary
migration due to potential risks to program integrity, the most commonly cited threat being
irregular migration. One of the key forms of irregular migration associated with temporary
residents are overstays: the risk that temporary residents will not leave the country by the date
specified by the border officer at the Port of Entry (POE) is a key concern. Additionally,
unfounded refugee claims made by temporary residents are viewed as a significant problem in
Canada, as they require resources that could be used for the processing of legitimate asylum
claimants. The admission of visitors without appropriate documentation also constitutes a risk in
terms of potential identity fraud. Similarly, people with prior criminal records and/or ties to
criminal organizations pose a risk of engaging in similar activities in Canada; controlling the
movement of temporary residents helps prevent inadmissible people from entering Canada, thus
contributing to the integrity of Canada’s immigration system. In order to assess the bona fides of
those seeking to enter Canada, officers in missions and Ports of Entry assess the backgrounds and
travel documents of those people passing through inspection points.
9
Citizenship and Immigration Canada, n.d. “Overview of Canada’s Visa Policy and Visa Review Process.” Internal
document.
9
Leveraging benefits
In literature, benefits of facilitated travel were identified as economic (e.g., growth in tourism and
trade), social (e.g., cultural exchanges and strengthened family linkages), political (e.g.,
improvements to diplomatic relations), or even as related to international security (e.g., increased
collaboration in terms of information sharing and ongoing cooperation).
Some interview respondents, particularly those who worked in fields related to international
relations, trade, or tourism, stressed the need to facilitate the movement of temporary residents in
order to access the benefits associated with international travel. These interviewees also saw the
need to facilitate travel as being linked with improving international relations.
3.1.2. Alignment with GoC and CIC objectives and outcomes
To assess alignment of the Visitor Visa Program with GoC and CIC objectives, its objectives were
compared with GoC Results for Canadians and the CIC’s strategic outcomes.
Finding: The objectives of the visa policy framework are consistent with GoC and CIC priorities,
objectives and outcomes. Under the revised CIC PAA, the alignment of the Visitor Visa Program
under Strategic Outcome 4 (Promotion of Canadian interests and protecting the health, safety and
security of Canada) obscures the dual nature of the Program’s objectives, which are intended to
balance facilitation of travel and protection of the integrity of the immigration and refugee
system.
Alignment with GoC objectives and outcomes
Overall, the visa policy program is largely aligned with all four of the Government of Canada’s
outcome areas as defined in the Results for Canadians framework: economic affairs, social affairs,
international affairs and government affairs. A review of the Program objectives facilitation and
protection - suggest that it supports the GoC objectives of economic and international affairs on
the facilitation side, and the social and government affairs on the protection side (i.e. re-imposing
visa requirements, security, health and criminality screening).
Alignment with CIC outcomes
The Visitor Visa Program is currently one of the elements under the departmental Strategic
Outcome 4 of Managed migration that promotes Canadian interests and protects the health, safety and security of
Canadians.
In the revised CIC PAA (Technical appendix), which took effect in the beginning of the 2010-11
fiscal year, the Visitor Visa Program is linked directly to Strategic Outcome 4 Promotion of Canadian
Interests and protecting the health, safety and security of Canada. This Strategic Outcome is not
well-described to enable assessment of the alignment between the Visitor Visa Program objectives
and this Strategic Outcome. In addition, the result 4.2 Migration Control and Security Management, to
which Visitor Visa Program contributes, states in its description that the TRV requirement is seen
as Canada’s primary means of controlling migration and allows for the screening of individuals for health, safety and
security risks before they begin travel to Canada. While the aim of the Visitor Visa Program is to balance the
twin objectives of facilitation and integrity, the focus of result 4.2 is mainly on protection, with
limited mention of facilitation.
10
The alignment of the visitor visa objectives with CIC’s program activity areas was more evident
under the previous PAA structure (2005-2010), where it was located during most of the period
under review, together with other temporary resident programs, under the previous Strategic
Outcome 1 Migration that significantly benefits Canada’s economic, social and cultural development, while
protecting the health, safety and security of Canadians. The dual objectives of the Visitor Visa Program were
directly aligned with the previous Strategic Outcome statement. Currently that link may not be as
clear, although the Program does include facilitative elements, such as granting a visa exemption on
a country, as well as the introduction of processing streamlining mechanisms.
Lastly, the majority of interviewees held that Canada’s visitor visa policy objectives are broadly
aligned with the Government of Canada and CIC’s objectives with respect to the facilitation of
travel and ensuring protection. Some interviewees stated that this alignment is a matter of degree:
that the objectives are aligned, but the magnitude of some of the potential consequences, such as
decreased tourism to as a result of a visa imposition, is unintended. A few interviewees held that
Canada is moving towards being able to achieve both objectives. Canada does not want to hinder
investment or other opportunities, but this could occur following changes to visitor visa
requirements.
3.1.3. Alignment with roles and responsibilities
This section reviewed the federal role vis-à-vis immigration as well as roles of federal departments
involved in the visitor visa policymaking.
Finding: With its specific dual mandate, CIC is the most appropriate federal department to design
and implement Canada’s Visitor Visa Program even though there may be some overlap with the
protection and facilitation mandates of other federal departments.
Federal and provincial roles and responsibilities
While immigration is a shared responsibility, defining immigration policies and processing
temporary resident applications falls within the federal sphere. The federal government has the
authority to make decisions regarding the admissibility of those who intend to enter Canada.
Immigration agreements with provinces place some responsibilities on the federal government to
consult with provincial governments when visitor visa applicants are coming to Canada for the
purpose of receiving medical care, and when the applicant could potentially be medically
inadmissible to Canada. Additionally, some federal-provincial collaboration occurs with regard to
the promotion of provinces to potential visitors. In terms of policy-making and regulatory changes,
provincial considerations are taken into account when assessing the impact of potential refugee
claims on social and health systems. As with most immigration programs, provinces may be
involved in applicant selection, however, admissibility screening remains a federal responsibility.
Federal departments’ roles and responsibilities
As defined in IRPA, the Minister of Citizenship and Immigration has the ultimate authority for the
establishment of visa requirements. However, other departments and agencies have mandates that
align to varying degrees with the Visitor Visa Program’s objectives of facilitating and securing
foreign travellers’ access to Canada.
A review of the mandates of CIC, Canada Border Services Agency (CBSA) and the Department of
Foreign Affairs and International Trade (DFAIT), and the opinions of most interviewees suggest
11
that the objectives of the Visitor Visa Program are most explicitly aligned with the mandate of CIC.
These objectives (facilitation and protection) are not as directly aligned with the mandates of
DFAIT or CBSA; DFAIT emphasis is on facilitation, while the CBSA focuses on the protection of
Canada and Canadians.
The majority of interviewees commented that the respective roles of these departments in support
of the Visitor Visa Program were generally clear and appropriate. They are involved in discussions
and consultations concerning country monitoring and country reviews, and are able to present their
particular perspectives and interests in the visa decision process. However, some interviewees
noted that the division of roles between CBSA and CIC may lack clarity, due to the fact that the two
organizations both administer the same Act. They perceive CIC as the facilitators and CBSA as the
enforcers, despite the fact that CIC also performs protection/security functions, and CBSA also
performs facilitation functions.
In terms of the implementation of the Visitor Visa Program, CIC’s role is aligned with its
responsibilities, as outlined in IRPA. Visa officers screen foreign nationals and issue Temporary
Resident Visas in compliance with IRPA and IRPR requirements. Other government departments
participate in policy development and processing of TRV applications and include: DFAIT, CBSA,
Royal Canadian Mounted Police (RCMP), and, if needed, the Canadian Security Intelligence Service
(CSIS). In addition, DFAIT also plays a role vis-à-vis the implementation of the visa program as it
provides information, services, and infrastructure to CIC’s immigration services overseas, and is
involved in communications with country representatives and trade partners as part of its role in
managing foreign relations.
10
While CIC is the main author of visitor visa decision communication
messages, DFAIT representatives are frequently the official spokespeople presenting these
decisions.
3.2. Performance Policy
CIC’s Admissibility Branch undertakes several activities when developing recommendations for
the Minister regarding whether or not Canada should grant or remove a visa requirement (a visa
policy decision). These activities include: the development and maintenance of a visa policy
framework, ongoing monitoring for all countries and in-depth reviews for selected countries. This
also involves bringing together multiple partners and stakeholders from within the Canadian
federal government, and may involve seeking information from the governments of affected
countries or other stakeholder groups. Through these processes, evidence is gathered in order to
assess whether a change in the visitor visa requirement is required, and to support any subsequent
decision. It should be noted that the final authority regarding changes to visa regulations rests with
the Governor in Council, on the recommendation of the Minister of Citizenship, Immigration and
Multiculturalism.
This section presents findings regarding the performance of the visitor visa policy component, and
discusses the activities and achievements of the related immediate outcome.
3.2.1. Visa policy framework
CIC established its visa policy framework in 2005, which includes a set of main categories, criteria
and thresholds. The evaluation assessed the criteria, indicators, and thresholds that were developed
to support the country monitoring and review processes and development of recommendations.
10
Citizenship and Immigration Canada, 2010. “Performance Measurement and Evaluation Plan: Regulations
Amending the Immigration And Refugee Protection Regulations (Mexico).” Internal document.
12
Finding: CIC’s policy framework and monitoring and country review processes are viewed as
adequate. The criteria and thresholds largely match international practices, although only select
countries use refugee claim rates as an indicator to inform their visa changes. Some indicators of
system integrity risks (such as overstays) are not currently included in the process due to lack of
data collection systems.
Appropriateness of visa policy framework design
Before 2005, CIC did not have a formalized visa policy framework. CIC established its country
monitoring criteria (visa policy framework), indicators and thresholds, to provide an objective
framework for the assessment of country risks, and to support the development of evidence-based
recommendations.
The framework includes more than forty criteria grouped into seven categories: socio-economic
indicators, immigration issues, travel documents, border management, safety and security issues,
human rights, and bilateral cooperation on removals (Technical appendix). There are nine
indicators known as threshold criteria, which are monitored on an ongoing basis. Three criteria are
quantitative in nature, and are instrumental in determining whether further investigation of the
country through the country review process is warranted. The quantitative threshold criteria consist
of the following: TRV refusal rates; immigration violations;
11
and the number of refugee claims
made in Canada by foreign nationals. Other indicators with thresholds that are not quantitative but
have defined parameters, include: passport security; passport production; the treatment of lost and
stolen passports; national security; bilateral cooperation on removals; and bilateral cooperation on
immigration integrity and law enforcement.
Information for these indicators is drawn from a number of sources, including statistical reports,
open source reports and media articles, and information provided by other departments and
agencies, such as CBSA, DFAIT and the IRB. Once there is an indication that the country meets or
exceeds the stated thresholds, it triggers internal discussion in the Admissibility Branch and at the
senior management level; this may result in a full assessment through the country review process.
This is an in-depth investigation of areas of concern or opportunities for a potential change in the
country’s visa requirement. The criteria and thresholds contribute to the assessment of risks
associated with specific countries, and thus guide the decision to recommend granting or removing
a visa exemption for nationals of those countries.
The media review indicated that at the time of introduction of the framework, the affected country
representatives appreciated the existence of the framework as it provided them with a set of
objective criteria and an understanding of where they need to make changes to increase the
potential of visa removal for their countries. Most of the interviewees agreed that the indicators and
thresholds are appropriate and very comprehensive. The framework provides a good tool to assess
various countries using the same criteria and thus allows for a consistent, comparable, and holistic
assessment.
While some interviewees commented that the framework is too extensive, others mentioned a
number of additional indicators that could be useful in the monitoring framework. For example:
11
This threshold refers to all documented cases of non-compliance with requirements of the Immigration and Refugee
Protection Act. This incorporates all reports of non-compliance prepared under Section 44 of the IRPA. It also takes
into account all instances in which foreign nationals are determined to be inadmissible to Canada at a port of entry and
allowed to voluntarily return to their country of origin.
13
measuring overstays, working illegally, or rates of permanent resident applications filed within
Canada after being admitted as visitor, could be effective indicators of irregular migration.
Currently, these indicators are not collected due to the absence of control systems for tracking
purposes.
Some interviewees noted that CIC’s current targets and thresholds do not measure all push and pull
factors that affect the temporary movement to Canada, such as the features of the Canadian asylum
system which were frequently mentioned as the most generous in the world. In addition, the visa
policy framework does not include a detailed assessment of internal Canadian concerns, such as the
potential effect of a visa requirement change on the volume of trade, or implications for the
Canadian economy, cultural, or social context. Those are assessed, to some degree, as part of the
consultative decision-making process in cooperation with Canadian partners.
Consistency with international practices
A comparison of the Five Country Conference members
12
and the EU suggests that Canada’s
framework is very comprehensive, and includes almost all criteria used by other countries. Some
differences include: Canada and Australia are the only countries reviewed that use asylum claims
directly as an indicator. While some other countries assess economic, cultural, and
social/reputational impacts related to potential visa imposition in their review process, Canada
takes these impacts into account through consultation with partners and the regulatory process.
3.2.2. Country monitoring
The established framework is used to conduct ongoing country monitoring and guides the country
review process for selected cases. To assess appropriateness of country monitoring, the evaluation
looked at ongoing monitoring and country review process.
Appropriateness of ongoing monitoring
The ongoing monitoring conducted by the Admissibility Branch examines the key indicators
through which country risks are measured. This monitoring is facilitated by a variety of
administrative data that are collected from CIC databases and other government department
(OGD) systems. Monitoring data are collected and updated regularly, which allows for the rapid
assessment of emergent issues for specific countries with respect to the quantitative thresholds.
CIC’s Admissibility Branch maintains a database that tracks the status of quantitative threshold
indicator information. Other monitoring activities include the regular review of domestic and
international media articles, and input from security or international partners. CBSA maintains and
provides data on immigration violation rates that is shared with CIC. Statistics Canada tourism
volumes are also used to compare data collected internally to the total number of travellers from a
given country. Collectively, this data is used to inform the need for further investigation through
the country review process.
Overall, many interviewees felt that CIC’s ongoing monitoring was adequate. While CIC regularly
receives data from its security partners, interviewees noted that, as a result of the separation of
CBSA and CIC in 2003, CIC must rely on partners for a great deal of information. The
effectiveness of this information-sharing relies on working relationships that are built between
partners. Some interviewees note that, at times, good information-sharing exists between partners,
but it might not always be as proactive as it could be.
12
Canada, Australia, New Zealand, the United States, and the United Kingdom.
14
Appropriateness of country review
Country reviews can be carried out for a number of reasons. Some of these reasons include:
When either the grant or removal of a visitor visa exemption is under consideration;
A change in the thresholds as identified through ongoing monitoring, including changes in
patterns of immigration violations or inCanada asylum refugee claim rates;
An identified change in country conditions, including changes in organized crime, a country’s
security situation, or national security concerns;
An identified change in document security, integrity or misuse of documents;
A request from a foreign government received via the Department of Foreign Affairs and
International Trade (DFAIT) or another department.
Country review reports are developed to support recommendations and the development of
regulations. There is no established schedule for country reviews. Unlike the process in the U.S.,
which is embedded in legislation and requires a country review of visa-exempt countries every two
years, Canada’s visa review schedules are based on ongoing monitoring and employ a flexible,
risk-based country review schedule. In interviews, most of the stakeholders mentioned that this
approach is more adaptable, focused, and efficient than the U.S. process.
A country review consists of an assessment of all or a majority of indicators under the seven
criteria. A document review is carried out using information obtained from various sources, as per
the ongoing country monitoring process described above. When considering granting a visa
exemption, a technical visit to a country under consideration may be undertaken; however, this is
not typically conducted in advance of removing a visa exemption. Technical Visit Delegations are
working groups sent to specific countries to conduct technical visits. These delegations, which seek
to resolve specific information gaps and issues of concern, bring together, on the Canadian side,
those equipped to ask probing questions and assess local conditions and, on the host country side,
those officials who can answer questions and address issues. Canadian delegation members are
typically drawn from groups within CIC, anti-counterfeiting officers from within the RCMP,
members of Public Safety Canada, and representatives from Canada’s relevant embassies,
consulates, and/or high commissions. These visits are performed to confirm existing information
and/or to close information gaps, and would include, for example, visiting passport production
centres to validate the security of passport production and distribution. These visits were perceived
by some interviewees as helpful in creating contacts with government representatives of the
affected countries, and providing an opportunity to not only gather data but explain the criteria and
the rationale for the potential change.
A review of the country reports for each case study country revealed that quantitative indicator
information was available in all of the cases, while qualitative indicator information was limited. It
was not clear whether this lack of qualitative indicator data suggests that a judgement was made
regarding the usefulness/quality of the data, or whether there was an inability to collect desired
information.
Some interview respondents noted that CIC always looks at the same issues consistently for all
countries, which was viewed as positive. They noted that evidence is not always weighed equally in
the country review process (i.e., some indicators are more significant in certain countries); a feature
that allows for more flexibility and is inherent in the review framework.
15
3.2.3. Partner consultations
While CIC is the federal government department responsible for developing visitor visa policy,
consultations with internal, external and international partners take place to support the
recommendations. This section examines to what extent those consultations are adequate.
Finding: CIC engages appropriate partners and there is adequate collaboration to inform visa
recommendations; some OGDs feel that they are not engaged early enough in the process or that
their views have not always been reflected in the final decision.
Mechanisms for partner engagement
Internally, within CIC two main branches are involved:
Admissibility Branch has overall responsibility for visitor visa policy development, including
consultations with partners;
International Region is responsible for processing visitor visa applications and is consulted
on visa-related policy issues.
Other internal CIC units play a supporting role in terms of consultations, and the provision of
information or advice. Other external partners involved in policymaking include DFAIT, the
Department of Public Safety (PS), the CBSA, RCMP, and CSIS, and may, when relevant, included
others such as Agriculture and Agri-Food Canada (AAFC), the Department of Justice Canada
(DoJ), Industry Canada (IC), and Transport Canada (TC). International stakeholders participate in
the discussions on the development of visa policies, or are interested in decisions on changes in visa
requirements.
The work of CIC in reviewing country conditions and generating recommendations regarding visa
requirements is facilitated by several working groups. The domestic working groups involve
relevant branches within CIC and OGDs mentioned above. Some examples of Canada’s
international engagement include the Canada-United States Visa Policy Working Group (VPWG),
which hold regular consultations, exchange information, and share best practices with regard to
visa, admissibility, and screening policies; and the Canada-Czech Expert Working Group, which
was set up to discuss visa issues and conditions following the decision to remove the visa
exemption for the Czech Republic in 2009.
Effectiveness of partner engagement
Analysis of the engagement mechanisms and the range of stakeholders involved indicates that
appropriate partners are included in consultations that support the development of visa policy and
recommendations. Stakeholders included in this process represent both sides of the visa
continuum; those that focus on the facilitation of travel and those that focus on the
security/protection of Canadians. The majority of interviewees (both CIC and OGDs) felt that the
mechanisms through which CIC engages and collaborates with program partners and stakeholders
to inform visa recommendations are generally sufficient. It is important to note that many OGD
interviewees commented that the majority of engagement has been ad hoc (they are involved only
when a visa policy recommendation is moving forward or when information is needed) and that
they are not engaged as early in the process as they would like. The reason for this lack of early
engagement, as reported by some CIC interviewees, is the difficulty in managing the engagement
process within the short timeframes that accompany visa recommendations, and the level of
16
sensitivity surrounding proposals. Because visa policy decisions are secret and are developed closely
with partners, CIC only brings key internal stakeholders in at the start and eventually expands
consultations outwards.
Many OGD interviewees stated that while they are engaged in the discussions to inform visa
recommendations, they felt that their stance was often not reflected in the final decision. There is a
lot of consultation, but the perception was that there is a need for further integration a
whole-of-government approach. It was perceived that the role of OGDs in an integrated visa
policy remains an idea, not a reality. Interviewees at CIC commented that, while partners may feel
they are not sufficiently included, from a departmental perspective, their input is sought as needed.
3.2.4. Visa policy recommendations
The immediate outcome of the visa policy development, monitoring and consultations result in
recommendations that are to be evidence-based, risks based and consultative. This section
examines the extent to which this is achieved.
As a result of the country review process and consultations with stakeholders, as described in the
previous section, a recommendation may be made to the Minister of Citizenship, Immigration and
Multiculturalism, who would make the final decision. This recommendation would be to:
Maintain the status quo;
Remove the visa exemption for nationals from that country; or
Grant a visa exemption.
There may also be further recommendations on the conditions imposed or actions taken, to better
balance the desire to facilitate the entry of bona fide travellers to Canada with the need to ensure the
health, safety, and security of Canadians. These could include:
Continued monitoring of a country’s conditions;
Implementing a public awareness campaign regarding the reviewed country;
Assigning a CBSA Liaison Officer to the country; and/or
Granting a visa exemption to particular nationals that possess specific types of travel
documents.
13
Overall, the process of developing recommendations and changing regulations can be lengthy for a
number of reasons: the conditions are monitored to assess longer-term trends, each individual
change must be accompanied by appropriate regulatory documents, and there exists a necessity to
manage relations with the affected country.
13
Government of Canada, 2008. Canada Gazette, vol. 142, no. 26 December 24, 2008. “Regulations Amending the
Immigration and Refugee Protection Regulations (Visa exemption requirements for Lithuania and Poland).”
gazette.gc.ca/rp-pr/p2/2008/2008-12-24/html/sor-dors308-eng.html
17
Finding: Monitoring and evidence from country reviews are regularly used to support visa policy
recommendations and the regulatory process. However, evidence is ultimately weighed and other
internal and external factors play a part in the final decision to impose or lift a visa.
Evidence-based, risk-based and consultative recommendations
A review of documents for the four case study countries indicates that recommendations appeared
to be informed by the evidence collected through monitoring and country review processes. Many
interviewees also confirmed that information collected from country review and monitoring
processes is used to support visa requirement recommendations.
While the evidence is always taken into account, the information/evidence is ultimately weighed
and a holistic assessment is used, rather than focusing on one factor that may be not in line with
thresholds. The use of evidence is particularly noticeable in cases of removing the visa exemptions,
with Mexico and Czech Republic having significantly surpassed key risk thresholds. In case of
Poland, the decision was to grant an exemption, even though the country surpassed at least one of
the thresholds (10% refusal rate) and there were concerns related to passport security. The passport
risks were subsequently addressed with the additional e-passport requirement regulation.
Some interviewees held that, in some cases, evidence from monitoring and country reviews may be
used to support country-level visa requirement changes that had already been considered as a result
of other pressures/political considerations. Even in those cases, country reviews were conducted
and evidence was gathered to support the decision by providing a risk assessment.
Many interviewees suggested that other factors come to bear on the final decision to remove a visa
exemption or grant a visa exemption by the Cabinet and the decision to change a visa requirement
is also strongly informed by GOC interests and priorities. The final decision is seen as a question of
the right balance and the right timing. In the cases of Taiwan and Mexico, evidence in support of
the visa exemption and the removal of the visa exemption existed for several years before the actual
change was made. In the case of Hungary, where asylum claims rates have surpassed the threshold
for several years, the recommendation to re-impose a visa is not being addressed. This suggests that
the decision to grant an exemption or re-impose a visa is carefully considered within a context of
other national and international factors.
Regulatory processes
After the recommendation is approved by the Minister, a regulatory change to section 190 of the
IRPR is required. This must be accompanied by a Regulatory Impact Assessment Statement (RIAS)
prepared by the Regulatory Affairs Unit at CIC. The RIAS explains the background and the
rationale for a decision, as well as the alternatives, provides a cost and benefit analysis, details the
consultative process that informed the decision, describes the compliance and enforcement
required, and explains what the impacts of the decision could be, and the risks and benefits of the
regulatory change. The evaluation examined RIASs prepared for each case study to assess the use
of evidence to support the regulatory change. An analysis of RIASs for the four case study
countries confirm that the information contained within the RIASs was largely informed by the
evidence gathered though monitoring and country reviews.
One of the weaknesses of RIAS documents is the cost-benefit analysis section. While the section
addresses additional impacts to Canada, such as the impact on the Canadian economy, social
assistance costs, or costs that will be incurred by other federal departments, most of the analysis is
18
fairly qualitative and does not provide a quantitative assessment of these impacts (Technical
appendix). While there may be challenges in assessing the cost/value of some of the elements, such
as deterrence of irregular migration, other elements, such as aggregated cost to the asylum claim
processing, or the loss to economy may be easier to assess using quantitative estimates. The
intention of the cost-benefit analysis as per the Canadian Cost-Benefit Analysis Guide for
Regulatory Proposals (TBS, 2007) is to quantify both the costs and benefits of the regulatory
change, the current method, which focuses largely on qualitative descriptors, reduces the strength
of the evidence.
3.3. Performance Implementation
The responsibility for processing visitor visas lies with CIC’s Operations Sector, which is divided
into domestic and overseas operations. Overseas operations fall under the responsibility of the
International Region and its network of visa offices abroad. Processing of visitor visas takes place at
Canadian visa offices overseas;
14
only visitor visa extensions are processed in Canada. Visa offices
are usually located within a Canadian mission (e.g., embassies, high commissions).
Administrative services are shared with DFAIT under the terms of a Memorandum of
Understanding, whereby CIC transfers resources to DFAIT to secure accommodation and some
administrative support. Some visa offices offer a full range of processing, while others offer limited
processing services (for example only permanent or temporary resident applications). The office
may cover one or more countries. In large countries like China, India and the U.S., the volume of
applications is such that there is more than one office to serve each country. Applications from
clients must be directed to the office in their country of permanent residence or in a country to
which they were lawfully admitted.
CIC processing of TRVs is guided by the Operations Manual (OP 11). According to the Manual,
temporary resident applications will be given as much priority as possible within the restraints imposed by other
processing priorities at the visa office. All applications are reviewed and decided on a case-by-case basis.
The applicant is required to satisfy the visa officer that their visit to Canada is temporary, they will
not overstay their approved time in Canada, they hold a passport or travel document, have
sufficient financial means to support their stay in Canada, are in good health, do not have a criminal
record, and that they are not a security risk to Canadians.
Each application for a visitor visa is processed abroad, but each person is also examined, to various
degrees, at the port of entry by the border officer. The foreign nationals must satisfy the border
officer that they have both the ability and the willingness to leave Canada at the end of the period
for which they are authorized to remain in Canada and that they will not engage in activities that are
not authorized by the visitor visa i.e., work, study, or apply for permanent residency from within
Canada.
14
There are three categories of visa offices or missions abroad: regional program centres (RPCs), full-service centres,
and satellites and specialized offices. RPCs and full-service centres both deliver the full range of immigration services
for the countries they serve, but RPCs also oversee satellite offices. The full range of immigration services includes the
processing of permanent and temporary resident applications as well as other immigration applications, such as
requests for travel documents or temporary resident permits. Satellites and specialized program offices do not deliver
the full range of immigration services.
19
3.3.1. Processing
To facilitate the flow of temporary residents, visa offices need to meet the demand for TRVs. The
following section describes the performance of the Program as it relates to the processing of visitor
visas. This includes a description of trends in demand, visitor visa processing trends and ability to
align capacity with fluctuations in demand and visa policy changes.
Finding: CIC has been able to meet the processing demand for TRVs to date with some extension of
time required to process applications. While CIC has the capacity to address seasonal fluctuations,
addressing major regulatory changes requires additional resources. Recent streamlining initiatives
show some positive effects on processing activities; however, it is too early to assess their
long-term impact.
Demand for temporary resident visas
The following section demonstrates that the overall number of TRV applications has increased
since 2006, although these increases are more apparent in certain regions, and that travel patterns
fluctuate seasonally. As a result of this demand and fluctuations, the impetus is placed on CIC to
find ways to meet this demand by taking into account travel patterns and leverage the benefits
(economic, social, etc.) associated with temporary travel to Canada.
Demand for TRVs can fluctuate in response to changes in economic conditions, regional and
seasonal travel patterns, and changes to visa requirements. The number of applications for
temporary resident visas remained fairly stable from 2006 to 2010, with a slight dip in 2008 and
2009, presumably as a result of the economic recession (see Figure 3-1). In 2010, there was an
increase in the number of visa applications (by approximately 130,000 applications) compared to
the previous year. Fifty percent of this increase was the result of the removal of the visa exemption
on nationals of Mexico in mid-2009.
Additionally, an analysis of the data shows that, in general, there are different trends in the demand
for TRV applications per region over the years under review. As shown in Figure 3-1, the number
of applications received in the Americas Region recently surpassed the number from Asia and
Pacific. While applications received by European offices decreased, there was a slight increase in
applications received from African and Middle Eastern countries.
Figure 3-1: Applications received by region (2006-1010)
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
2006
2007
2008
2009
2010
Asia & Pacific
Americas
Europe
Africa and Middle East
Source: OPS Statistics, CIC
20
While the overall number of applications remains relatively stable, the rate of change in the number
of applications received for particular missions has been quite high.
In addition to changes by region and by mission, travel patterns fluctuate seasonally with a higher
number of travellers in the summer months. This pattern is consistent across all regions (see Figure
3-2).
Figure 3-2: Application patterns within a year
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
Oct/
2010
Nov/
2010
Dec/
2010
Jan/
2011
Feb/
2011
Mar/
2011
Apr/
2011
May/
2011
Jun/
2011
Jul/
2011
Aug/
2011
Sep/
2011
Africa and Middle East
Asia & Pacific
Europe
Americas
Source: OPS Statistics, CIC
Ability to meet TRV demand
In order to assess CIC’s ability to meet the demand for TRV applications, the evaluation examined
TRV processing statistics and CIC resource capacity.
Processing rates: As shown in Figure 3-3, which compares the number of applications processed to
the number of applications received, a large majority of applications are processed to completion;
however, there has been a slight decline in processing rates in 2009 and 2010; 98% of files were
processed in 2007 compared to 95% in 2010. The percentage of unprocessed applications relates
mostly to the fact that applications received at the end of the year may only be processed in the
following year.
Figure 3-3: Applications received and processed, by year
0
200,000
400,000
600,000
800,000
1,000,000
2006
2007
2008
2009
2010
Applications received
Applications processed
Source: OPS Statistics, CIC
21
Processing times: In order to meet the demand in applications and provide good service to
clients, TRVs should be processed in a timely manner. From 2006 to 2010 processing times (for
80% of cases) have increased from 7 to 14 days, overall, and in almost all regions (see Table 3-1).
An analysis of processing times for the 65 offices that existed between 2006 and 2010 shows that:
Processing times increased in almost 50% of the offices, decreased in 14%, and remained the
same in 38%;
The highest increases in processing times were in Islamabad (from 14 days to 56), Tehran (from
28 to 42 days), Abidjan (from 7 to 21 days);
The largest decreases in processing times were in Warsaw (from 7 days to same-day processing
due to the granting of the visa exemption), Guatemala (from 14 to 7 day processing), Harare
(from 42 days to same-day processing), and Chandigarh (from 28 to 14 days);
In 2006 there were 15 (22%) offices that processed applications within one day; this number
decreased to 9 (14%) in 2008, where it remained for the rest of the period under review.
Processing times are influenced by the number of applications received, the level of effort to
process visa applications in certain areas and whether additional health or security screening is
undertaken. Some interviewees suggested that one of the reasons for longer processing times
relates to the time it takes for CIC’s partners to perform security and health checks.
Table 3-1: Trends in temporary resident visa processing, 2006-2010 (averages)
Region
Application
received
Approved Refused
Total/
Total
finalized
Approval
rate
TRVs
issued
80% of cases
finalized
within X Days
Asia & Pacific
300,340 233,575 63,272 296,847 79% 233,575
Steady, at 7 days
Africa and Middle East
104,609 69,435 30,628 100,063 70% 69,435
Increased, from
14 to 21 days
Europe
110,127 90,346 17,492 107,838 84% 90,346
Increased, from
7 to 14 days
Americas
282,286 235,365 41,038 276,404 85% 235,365
Increased, from
7 to 14 days
Total points of
service
803,605 629,683 152,437 782,120 80% 629,683
Increased, from
7 to 14 days
Source: OPS-Statistics, CIC
An overall examination of the two indicators mentioned above (processing rates and time) suggests
that CIC is meeting the demand in TRV applications. As previously noted, some trends in TRV
processing indicate that CIC’s performance has declined slightly over the last five years (i.e.
increased processing times, decreased processing rates). Some interviewees suggested that while
CIC manages to meet the demand, at some point CIC will not be able to cope with processing more
TRVs without increasing resources or compromising security/program integrity, due to
insufficient human resources issues.
Capacity to process TRVs
In total, the number of visa offices that process applications has remained fairly constant (68 offices
in 2006 and 65 in 2010)
15
. Visa offices generally consist of an Immigration Program Manager (IPM),
one to two Deputy IPM/Operations Managers, and several Canada-Based Officers (CBOs). There
15
After office closures in 2012, the number of offices is currently 56.
22
are also Locally Engaged Program Officers (LEPs), Locally Engaged Staff (LESs) and local
administrative staff. Circa 2011, there were approximately 340 CBOs and 1,320 locally-engaged
staff working for the immigration program abroad (including those performing CIC and CBSA
related tasks). There are significant variations in terms of how many countries and people each of
the visa offices include. For instance, the mission in Singapore is responsible for a territory that
covers 600 million people in 10 countries and is staffed with eight CBOs and 28 LESs. The biggest
mission, in New Delhi, has 150 staff, including 28 CBOs.
To assess CIC’s capacity to process TRV applications, the evaluation examined the level of
operational support provided by CIC; whether CIC has the HR capacity to adjust to meet visitor
visa demand fluctuation.
Operational support: Materials are available to inform staff about operational procedures, policy
changes, and any other form of change occurring in the IR network. Ongoing support is provided
by NHQ and bulletins are published throughout the network to ensure that staff are aware of any
changes. Recent initiatives include the Wiki page for international staff, which includes a section on
questions and best practices. Recent audits (2008, 2009, 2010, 2011) of visa programs in nine
missions suggest that the decisions are made by the appropriate level of staff and that staff followed
the required procedures.
Overall ability to adjust TRV workload: The first concern mentioned by CIC interviewees was
workload pressures related to TRV processing. In particular, because visa processing units are
staffed based on permanent resident applications processing levels, TRVs are treated as a lesser
priority. The focus is to ensure that the processing of permanent resident applications allows CIC
to meet the stated permanent immigration targets. There are no targets associated with TRVs. Due
to the fact that staffing is done through an interdepartmental committee for overseas staff, creating
one position in the field takes about one year. This results in a lack of flexibility or responsiveness as
it is a cumbersome process to reassign permanent staff to missions and even more difficult to add
a position. Instead, resources are shifted between permanent and temporary processing and other
strategies are used to address workload challenges. In internal CIC reports for 2010, difficulty with
processing due to increased demand was mentioned by managers of almost all missions.
Ability to meet TRV demands due to annual/seasonal fluctuations: The majority of
interviewees commented that while there are some challenges, overall, CIC has the ability to meet
visa processing demands due to annual/seasonal fluctuations. In general, January to September is
considered temporary season; students are also included in this group because they have to get their
visas in the spring in order to attend school. When the demand for temporary resident visas
increases in the spring and summer, mission resources are shifted from processing PR applications
to TRVs. In general, many missions focus on processing permanent resident applications in the low
season (winter, early spring).
Ability to meet TRV demand due to changes to visa regulations: Respondents were divided
when asked whether CIC has the ability to meet visa processing demands due to changes in visa
regulations. Many interviewwws noted that the sufficiency in resources to meet the new demand
relating to a visa imposition depends on the country on which it was imposed (size, yearly number
of travellers to Canada, etc.). While the majority believe that Mexico received sufficient resources,
this is not always the case. An examination of the Mexico and Czech Republic case studies show
that while there were some initial challenges, sufficient resources were provided to address the
demand.
23
Mexico: Prior to the removal of the visa exemption, there was one immigration program
manager, two visa officers, a migration anti-fraud officer and some locally engaged staff
working in the immigration section of the mission in Mexico. During this period, the majority
of processing work related to permanent resident applications, study and work permits.
According to interviewees, after the removal of the visa exemption, the office increased its
number of staff to approximately 70 people almost overnight. In the year since the imposition,
there were more than 100 temporary duty (TD) officers that operated in the Mexico office; the
cycle of officers coming to Mexico was between one to three months each, from the date the
visa exemption was removed until about September 2010. Because the majority of processing
officers sent from Canada for the first year were TD officers, some interviewees said that the
high turnover made it more difficult to manage. After the first year, the office became more
stable with a steady team of people, receiving officers who will likely remain in the office for 2-3
years, who can understand Spanish, and who had the time to understand the socio-economic
situation in Mexico and apply this to their work. As illustrated in Figure 3-4, below, the mission
in Mexico processed almost all applications received within the first two years of the visa
change.
Figure 3-4: Mexico: applications received vs. applications processed
0
10,000
20,000
30,000
40,000
50,000
60,000
70,000
2009
2010
Applications received
Total processed
Source: OPS Statistics, CIC
Czech Republic: In the case of the Czech Republic, processing was delegated to CIC’s Vienna,
Austria office. Recognizing that it would be a significant change for Czech nationals to have to
apply for a visa in another country, various avenues were created to submit applications.
However, in order to be more responsive to concerns raised by Czech nationals, CIC
introduced a two-person office in Prague (1 CBO and 1 LES). While the Vienna office could
have handled Czech applications, the Prague office was necessary to improve client service and
Canada’s reputation. In 2010, the mission in Czech Republic processed 99.3% of all the
applications received.
16
16
2009 data for the Czech nationals was not available, as applications were processed by the Vienna mission (data is
available by mission rather than nationality).
24
Main mitigation strategies to address capacity challenges
As previously noted, there are challenges in managing TRV resources because missions are funded
based on their permanent workload and because TRV demand fluctuates. Therefore, CIC employs
a number of different strategies to mitigate capacity challenges, such as Temporary Duty (TD)
arrangements, and introducing streamlining processes; such as VACs, and multiple entry and
longer term visas.
Temporary Duty: CIC relies on TD officers to mitigate capacity challenges in missions due to
annual/seasonal demand, visa requirement changes and other factors. TD officers are staff with
several years’ experience working at CIC, who receive theoretical and practical training on
processing immigration applications. These individuals are assigned to process applications to
relieve officers during the busy season, or to replace those on leave. While the TD officer is
intended to assist with processing, this practice has other positive effects, such allowing the TD
officer, who may have a substantive position in the policy sector, to bring back to their branch their
experience learned working in an operational environment. This should help inform future policy
work. Over the last few years, the overall number of TD assignments (for TR, PR, etc.) has
increased from 133 in 2007 to 341 in 2010 and number of work weeks from 723 to 1740 with a
minimum of 30% of those allocated to processing temporary applications.
Streamlining processes
Visa Application Centre (VAC): VACs are independent service providers and international
organizations that are operated on a user-pay basis by third-party service providers, and that charge
user fees (at levels set by the service provided and agreed by CIC) to assist clients with the visa
application process. Canada is currently served by 60 VACs in 41 countries. VACs have two main
objectives: to facilitate in-person assistance for clients and to support the ability of CIC to meet the
demand for TRVs. This section focuses on the use of VACs to support demand/capacity
challenges within missions (the facilitation objective will be discussed in the section on facilitation).
In its support role to CIC, VACs are intended to improve missions’ processing capacity by
providing administrative support services to applicants. VAC staff are strictly prohibited from
providing evaluative advice or consultancy and play no role in the decision-making process. In
Beijing and Mexico, VACs have the ability to scan applications with 2D barcodes, which is
uploaded to the system in Ottawa, validated, and provided to mission through GCMS to facilitate
processing of applications. While definitive, quantitative information on their success was not
available for the evaluation, based on the interviews from the mission in Mexico, the VAC has had
a positive impact on addressing demand and capacity challenges. In particular, staff at the Mexico
mission mentioned that VAC contributes to the completeness of application packages, which
reduces the rejection rate for incomplete/incorrect forms. This provides staff with time to
concentrate on assessing complete applications. While staff positively assessed the impact of the
VAC on operations, an internal review of the Mexico VAC files for July/August 2010, in which
1,000 applications were reviewed, indicated that the applications received from VAC in Mexico had
a 78% error rate, and 43% of these applications were incomplete. However, corrective measures
were taken by mission staff to provide feedback to VACs on the most frequent mistakes and
subsequently the error rates has significantly reduced. This underlines the importance of regular
feedback and communication between the visa offices and VACs. .
25
Other Changes: There are other mechanisms being introduced that are intended to improved
CIC’s processing capacity and efficiency. Examples include: long-term and multiple-entry visas,
which aims to decrease the number of transactions with clients; e-applications (2D barcodes); and
the introduction of a new system to collect data on applications, Global Case Management System
(GCMS), which includes features such as uploadable information and group processing. While the
missions expressed some concerns that GCMS added processing time, particularly during the file
creation process, during the Mexico site visit interviewees commented positively about the initial
impacts of these mechanisms, however, the longer term impact will have to be assessed when more
information is available.
3.3.2. Communications
There are three main communication activities related to visitor visas: communicating application
requirements to potential TRV clients, communications related to changes in visa regulations, and
communications related to sensitive TRV cases. As it was not possible to locate temporary visitor
applicants (due to privacy and cost issues), the evaluation could not gather their direct assessment
of the impact of communication activities; therefore, this section relies on qualitative assessment of
the breadth and depth of communication efforts.
Finding: The timeliness and breadth of CIC’s communication strategies related to immigration are
reasonable and address a variety of potential client’ information needs. As materials supporting
decisions on changes to visa requirements are subject to Cabinet confidence, CIC faces
communication constraints related to the timing of information being released to partners,
stakeholders and to the public.
Communication: visitor visa application requirements
To assess regular communications, the evaluation conducted interviews, a document review, and a
review of the information available on-line to assess the comprehensiveness and breadth of the
information provided. The evaluation found that information regarding temporary resident visas is
readily available online and the CIC website appears comprehensive and provides information that
may be helpful to those who have access to the internet. In particular, CIC’s website provides
information for potential clients on current visa requirements, as well as any changes introduced.
17
This information includes links to application forms and guides, TRV exemptions, processing
times, and means of extending one’s stay in Canada. Additional information is contained on
mission specific websites, including information on temporary travel requirements. Missions
provide information in English and French but also sometimes in local languages. These websites
have a common look and feel and the information provided is almost identical. One issue noted in
some interviews was that some complaints were received from clients in Mexico about TRV forms
only being available in English and French, which made them difficult for clients to complete.
Communicating changes regarding visitor visas regulations
Information about proposed regulatory changes to visa requirements is made available through the
Canada Gazette. Key stakeholder groups within Canada, such as provincial and territorial ministries
of immigration, as well as the Canadian Council for Refugees, are subsequently provided notice of
17
See, for example, www.cic.gc.ca/english/visit/index.asp and
www.canadainternational.gc.ca/mexico-mexique/visas/index.aspx?lang=eng&menu_id=5. Note that mission
websites are provided by the Department of Foreign Affairs and International Trade.
26
these changes by a departmental spokesperson. Communications are also undertaken for the
benefit of the Canadian public both the general public and those who may have business or family
ties to the affected country. These communications include an explanation of the rationale for the
decision. In addition to these governmental channels, news of visa requirement changes is often
disseminated through Canadian media, whose reporting of the changes may include reference to
prepared communications materials and/or comments from departmental spokespeople. The level
of public notification with respect to visa requirement changes is lower than for other forms of
regulatory change, as the visa policy process itself is sensitive owing to the national and
international information involved.
Timing of visa requirement change communication
Due to the sensitive nature of decisions to remove a visa exemption, they are communicated at the
last possible moment to prevent a surge in travel (and, potentially, in-Canada asylum claims) by
citizens of affected countries. Communication materials are prepared well in advance of the
announcement. Because visa requirement changes come into effect very shortly after their public
announcement, these requirements must be communicated swiftly to reduce the risk of traveller
confusion abroad. Nevertheless, according to some interviewees, because of the short notice of
these types of changes, travellers who are travelling the day of, or shortly after, the announcement
can face difficulties getting their visas in time for the travel. It should be mentioned that CIC usually
allows a grace period of a few days for these circumstances.
A review of documents and interviews pertaining to the Mexico and Taiwan visa decisions show
that there is an approach to consult with affected international stakeholders with respect to visa
decisions. In the Mexico case study, the ambassador and staff at the Canadian mission were highly
involved, not only in informing their counterparts about the decision, but also in providing the
rationale for such a decision. In the case of Mexico, while CIC put some public notices in the
papers, it also benefited from existing media interest in the issue. The public appeared to be fairly
well-informed about the need to apply for visa as evidenced by large line-ups in front of the
embassy the day the announcement was made. Many interviewees from the mission and NHQ felt
that the Mexico visa change was effectively communicated. Some mission staff commented that the
large number of Mexican citizens applying for a visa immediately after the imposition was an
indication that they were aware of the new requirement.
3.4. Performance Achieving integrity and facilitation outcomes
Using data from interviews, administrative systems and case studies, the evaluation examined the
extent to which CIC’s Visa Policy Program contributed to the achievement of the intermediate
outcome of the visa program: protection of the integrity of Canada’s immigration and asylum
systems and facilitation of travel for bona-fide travellers as well as balancing both.
3.4.1. Integrity of the immigration system
The evaluation examined the following aspects of integrity:
Integrity of the immigration system: At the outcome level, the impact of the visa program on
protecting the integrity of the immigration system was assessed by looking at the effectiveness of
the Program in deterring non-bona fide travellers from applying, preventing irregular migration,
and preventing immigration violations.
27
Integrity of the asylum and refugee system: The impact of the Visa Program on the integrity of
the asylum and refugee system was assessed by examining the effect of the visa on asylum claim
rates, especially those presumed to be unfounded, and the costs/savings associated with processing
such claims.
Finding: The visitor visa is an effective tool that helps protect the integrity of CIC’s immigration
and asylum system through selecting low-risk countries for visa-free travel, and potentially being a
deterrent for non-bona fide travellers. Its role as a mechanism to address immigration violations is
less certain. The impact of the visitor visa on irregular migration is difficult to measure due to lack
of data on certain indicators (e.g., overstays)
Deterrence effect
The existence of a visa plays a role in preventing people who may not meet eligibility/admissibility
criteria from applying. Interviewees noted that the existence or re-imposition of a visa requirement
on a country is a deterrent for non-bona fide travellers. They noted that a visa requirement in theory
should have a self-selection or deterrence effect on ineligible/inadmissible travellers to Canada.
This is supported by evidence in the case study countries (e.g., Czech Republic and Mexico). While
it is difficult to generalize and quantify this effect across all visa-required countries, travel patterns
after removing the visa exemptions suggests that there is a link between visa requirements and
deterrence of non-bona fide travel. For example, in the Czech Republic, visa refusal rates were very
low when a visa was required; in 2010, the TRV refusal rate for Czech Republic nationals was
around 1%. This may suggest that potential applicants self-assess their likelihood of obtaining a visa
to come to Canada.
Irregular migration
Once visitors obtain a visa and gain entry into Canada, they must comply with the terms and
conditions of their stay: they should not engage in unauthorized activities, such as work and/or
study; they should leave the country as stated; and they should not use their temporary entry to
pursue permanent residency. Any temporary visitor who pursues other activities is in direct conflict
with conditions of admission, which undermines the integrity of the immigration program.
Due to the weaknesses of the data collection system, it is not possible to assess the number of
people who remain in Canada longer than authorized (overstays), those who engage in illegal work
while under temporary visitor status, or those that apply for permanent residence while in the
country. While CIC considers these indicators relevant to measure irregular migration as described
in its PAA, Canada and many other peer countries do not have exit control systems, so it is difficult
to know how many people remain in the country when their period of authorized stay ends. In
2008, the Auditor General report estimated that there were 63,000 people with enforceable
removal orders in Canada; however, since there is no information on who has left the country, the
number of illegal migrants may be higher. The report stated that Canada does not monitor the exit of
travellers from the country, and therefore (..) does not know whether individuals have left the country as required in their
temporary permit.
18
18
Auditor General Report, Chapter 5 Citizenship and Immigration Canada Control and Enforcement.
www.oag-bvg.gc.ca/internet/English/parl_oag_200304_05_e_12911.html
28
Immigration violations
Immigration violations are documented infractions of Canadian immigration laws, such as
interceptions of individuals en route to Canada, of inadmissible individuals identified at a Canadian
port of entry and those identified in Canada. In this section, immigration violation rates, for both
visa-required and visa exempt countries, are compared in order to determine whether the visa has
been successful at protecting the integrity of Canada’s immigration system. Inadmissible travellers
attempt to enter Canada on an ongoing and regular basis, which presents a risk to the integrity of
Canada’s immigration system. The risks are that travellers may repeat previous unlawful
behaviours, or that admitting those with criminal records will tarnish Canada’s international
reputation by suggesting that it is a country that provides a haven for serious criminals. Another risk
is that people with health risks will either directly impact the health of Canadians (e.g. through the
spread of tuberculosis) or will constitute a drain on public health services (e.g. through treatment
for chronic illnesses or conditions).
Table 3-2 and Table 3-3 show that the number of immigration violations remains fairly comparable
between visa exempt (EXM) and visa-required (REQ) countries, with the exception of intercepts
(improperly documented people en route to Canada). However, comparing the rates of
immigration violations from visa exempt and visa-required countries must take into account that
the majority of international travel to Canada comes from visa exempt countries (between 95% to
97% of annual travel volumes depending on the year see Number of Travellers statistics in Table
3-2). Therefore, while the number of violations is comparable, immigration violation rates are
much lower for visa exempt countries. As noted in Table 3-2, the rate of immigration violations
from visa exempt countries is 14 to 20 times lower than visa-required countries depending on the
year. This suggests that visa exempt countries were appropriately selected for visa-free travel as they
do not pose the same level of risk in term of immigration violations.
These numbers also indicate that a visa requirement does not completely eliminate immigration
violations, which would presumably be higher if a visa exemption had been granted. Data from the
Czech Republic and Mexico case studies support this presumption. The highest rates of
immigration violations for the Czech Republic occurred in the years following the granting of the
visa exemption (from 2007 to 2009) primarily as a result of the high number of asylum claims. The
immigration violation rate then diminished following the removal of the visa exemption in 2009.
For both the Czech Republic and Mexico, the years following the removal of the visa exemption
align with a drop in the immigration violation rate, therefore suggesting that visas are effective in
reducing immigration violation rates. In terms of the impact of granting visa exemptions, there was
no noticeable increase or decrease in immigration violation rates is the cases of Taiwan and Poland.
Therefore, there was no impact on the integrity of the immigration system. While the data shows
that both visa exempt and visa-required countries are sources of immigration violations, the
removal of the visa exemption helped control the immigration violation rate in the case of Mexico
and the Czech Republic. However, it is difficult to determine the degree to which immigration
violations would change (increase) without visa requirements for current visa-required countries.
29
Table 3-2: Violation rates for visa-exempt and visa-required countries
2006 2007 2008 2009 2010
Number of Travellers
EXM
32,290,184 29,229,676 26,206,439 23,417,882 23,382,569
REQ 1,035,009 1,076,740 1,092,824 1,210,447 1,388,505
Grand Total
33,325,193 30,306,416 27,299,263 24,628,329 24,771,074
Intercepts
EXM
272 693 530 1,038 1,011
REQ
4,076 3,670 3,347 3,746 4,765
A44 Inadmissibilities
EXM
17,005 19,198 21,862 11,560 10,655
REQ 15,488 17,681 20,828 29,128 17,115
A42 Inadmissibilities
EXM
52,916 48,837 50,443 31,938 41,270
REQ
19,812 19,420 23,519 24,365 22,641
Total Immigration Violations
EXM 70,193 68,728 72,835 44,536 52,936
REQ 39,376 40,771 47,694 57,239 44,521
Total 109,569 109,499 120,529 101,775 97,457
Rates of Immigration violations
EXM
0.22% 0.24% 0.28% 0.23% 0.23%
REQ 3.80% 3.79% 4.36% 4.73% 3.21%
Grand Total 0.33% 0.36% 0.44% 0.46% 0.39%
Ratio (REQ to EXP) 17.50 16.10 15.70 20.19 14.16
Legend: ECM - Vixa exempt countries; REQ - Visa-required countries
Source: CBSA administrative data
Number of Immigration Violations
Note: The above are annual immigration violation rates. In addition to visitors, it includes immigration violations related to students
and temporary workers. These rates relate to cases identified en route to Canada (intercepts) and those that are identified at the
port of entry or inland (A44 and R42
19
). These rates do not include inadmissible cases identified in missions abroad.
It is important to note that the majority of visitors to Canada do not pose much of a threat to
Canadians. There are; however, individuals who may pose more direct risks to the Canadian public,
such as those with previous criminal histories. Interviewees suggested that those with links to
organized crime or human trafficking are of particular concern, as the individuals involved may
continue unlawful activities within Canada. A comparison of the type of immigration violations
between visa exempt and visa-required countries (see Table 3-2 and Table 3-3) shows that:
Visa-exempt countries are not a major source of security or human right violations (related to
section A34-35 of IRPA).
The number of criminality-related inadmissibility cases (related to section 36 of IRPA) among
visa-exempt countries is higher than visa-required countries, suggesting that a visa requirement
may be effective in decreasing the number of criminality cases.
19
A44 inadmissibility cases are those relating to sections 34-42 of IRPA (See Table 4 for detailed categories. R42
inadmissibility cases are those relating to determination if a foreign national could become a temporary or a permanent
resident or make a claim for refugee protection; direct a person to leave Canada or to return to the United States; allow
the withdrawal of an application to enter Canada or refuse the entry to a person who does not satisfy the requirements
of the Act; authorize a person to enter Canada for further examination or an admissibility hearing.
30
The top country among non-visa-required countries with immigration violations is the United
States which accounts for about 75% of the total immigration violation rate. However, given
the volume of travellers from the U.S., the proportion of immigration violations from that
country remains very low at 0.2%.
In Mexico, the number of immigration violations decreased significantly, from 9,000 in 2006 to
3,500 in 2010, after the visa re-imposition. This may suggest that the re-imposition had an
effect on either deterring or screening out inadmissible applicants/applications.
Table 3-3: Number of inadmissibility reports per year, by visa status and IRPA
section
Visa Status / Inadmissibility Type 2006 2007 2008 2009 2010
34 - Security grounds
- 3 6 1 1
35 - Human Rights Violations
1 - 2 3 1
36(1) - Criminality - Serious 3,540 3,135 3,115 2,420 2,199
36(2) - Criminality - Lesser
4,331 3,636 3,293 2,604 2,252
37 - Organized Crime
23 25 43 36 29
38 - Health
12 7 11 12 12
39 - Financial
61 49 55 46 45
40 - Misrepresentation
103 120 96 74 96
41 - Non-compliance
8,760 12,057 15,135 6,296 5,949
42 - Inadmis. family member
174 166 106 68 71
TRV-exempt (total) 17,005 19,198 21,862 11,560 10,655
34 - Security grounds
23 22 21 30 74
35 - Human Rights Violations
13 19 19 20 13
36(1) - Criminality - Serious
480 477 517 706 569
36(2) - Criminality - Lesser
494 507 536 602 482
37 - Organized Crime 24 29 35 78 85
38 - Health
10 20 14 14 15
39 - Financial
17 16 13 16 10
40 - Misrepresentation
240 167 142 186 254
41 - Non-compliance
14,159 16,387 19,484 27,405 15,523
42 - Inadmis. family member 28 37 47 71 90
TRV-required (total) 15,488 17,681 20,828 29,128 17,115
Source: FOSS data – port of entry and inland enforcement inadmissibility reports.
Even though the number of inadmissible cases for visa-required countries is not large, the
following questions remain: does this represent an acceptable level of risk? Should these cases have
been identified abroad through health and security screening (even though some of the violations
will have occurred in Canada)?
3.4.2. Integrity of the asylum system
Canada’s existing asylum system faces an ever-increasing number of new claims every year, with
claims taking years to process. The perceived generous nature of Canada’s asylum system may
encourage submissions of unfounded asylum claims, which serves to reduce Canada’s ability to
help those who truly need protection. The analysis below includes an assessment of the impact of
the visa on asylum claim rates as well as an analysis of claims made by the case study countries
under discussion. The impact of the visa program on the integrity of the asylum system was
assessed by examining the effect of the visa on asylum claim rates and the costs/savings associated
with processing unfounded claims
31
Asylum claim rates
CIC uses asylum claim rates as one of the quantitative thresholds to inform changes in visa
requirements and defines it as one of the indicators pertaining to Managed Migration outcome
results in the PAA/PMF document. Figure 3-5 shows that the proportion of asylum claims, from
both visa-required and visa-exempt countries, have shifted over time. Even though the majority of
claims have consistently been from visa-required countries, from 2006 to 2008 there was nearly a
20% increase in the proportion of asylum claims from visa exempt countries. This increase was
mostly due to increasing numbers of asylum claims from Mexico. In 2009 and 2010, this trend was
reversed due to the removal of the visa exemption granted to nationals of the Czech Republic and
Mexico, which were major sources of asylum claims. Furthermore, Figure 3-5 shows that there has
been an overall increase in the total number of asylum claims from 2006 to 2009, followed by a
large decrease in 2010, mainly resulting from the removal of the visa exemption for nationals of
Mexico. It is evident that CIC monitors and makes changes to the visa exemption list when
necessary; and when possible removing from this list countries that are becoming major sources of
asylum claims.
Figure 3-5: Total number of asylum claims made, by visa requirement
13,341
15,343
16,312
26,369
16,650
6,047
7,624
12,218
6,883
6,521
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
2006
2007
2008
2009
2010
Visa required
Visa not required
Source: OPS Statistics, CIC
CIC’s administrative data confirms that the removal of the visa exemption for nationals of Mexico
was very effective at reducing the number of asylum claims. Figure 3-6 shows the increase in
Mexican asylum claims from 2001 to 2008 (from 1,730 to 9,462 claims) and the significant decrease
since the removal of the visa exemption in July 2009 (from 7,570 claims in 2009 to 1,199 claims in
2010). This represents a substantial decrease (87%) in asylum claims from 2008 to 2010.
32
Figure 3-6: Total number of asylum claims made, by Mexican nationals in Canada
1,730
2,090
2,597
2,810
3,455
4,921
7,228
9,462
7,570
1,199
416
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
10,000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
(Jan-
Sep)
Source: OPS Statistics, CIC
Table 3-4, below, presents the proportion of asylum claims made (per year) by each case study
country (2005 to 2010). The cells highlighted in red indicate the years in which each country was
visa-exempt. The data indicates that the introduction of TRV requirements was effective in
reducing the proportion of asylum claims made in Canada by nationals from the two case study
countries.
20
In particular:
Czech Republic: The granting of a visa exemption in 2007 was followed by an increase in the
asylum claim rate. The removal of the visa exemption in 2009 resulted in a significant decrease
in the proportion of asylum claims made in Canada coming from Czech nationals, from 6.58%
to 0.18%.
Mexico: The removal of the visa exemption in 2009 was very effective in reducing the asylum
claim rate. In 2009, 23% of the asylum claims made in Canada were from Mexican nationals,
which decreased to 4.7% in 2010 following the removal of the visa exemption. It is expected
that the asylum claim rate will further diminish as many of the asylum claims that occurred after
July 2009 (date of the removal of the visa exemption) could have been made by Mexican
nationals present in Canada before the imposition.
Table 3-4: Asylum claim rate proportion from case study countries, 2005-2010
Country / Year 2005 2006 2007 2008 2009 2010
Mexico
17.23% 21.32% 24.85% 25.48% 22.56% 4.73%
Czech Republic
0.06% 0.00% 0.39% 2.32% 6.58% 0.18%
Poland 0.21% 0.20% 0.13% 0.26% 0.31% 0.28%
Taiwan
0.02% 0.02% 0.01% 0.03% 0.02% 0.03%
Source: OPS-Stats
To compare the rates of asylum claims made by citizens from the case study countries and those
from other countries in the world, asylum claim rates made in Canada and in other countries are
included in the Technical appendices. The data shows that in-Canada asylum claim rates were
20
While monitored, asylum claims for Poland and Taiwan are not a concern.
33
consistently higher for the two case study countries when a visa was not required (In 2009, 95% of
asylum claims from Czech nationals made globally and 80% of those made by Mexican nationals,
were made in Canada).
Outcomes of asylum claims
CIC’s mandate includes affording protection to people in need of protection. Therefore, reducing
the asylum claim rates alone is not sufficient to assess the effectiveness of the Visitor Visa Program
in protecting the integrity of the asylum system. The evaluation examined the legitimacy of the
claims using asylum claim outcomes (rates of approval/refusal as adjudicated by the Immigration
and Refugee Board (IRB), and withdrawal/abandonment by claimants).
Overall, from 2000 to 2010, the asylum claim approval rate for all countries was around 43% (see
Table 3-5). Over the period examined, Table 3-5 shows that asylum claim outcomes for all case
study countries differed from this average. The proportion of negative decisions diverged the most
in the case of the Czech Republic, with a rate half that of the 10-year overall average. In all other
case study countries, the proportion of negative outcomes was greater than the average. The case
study countries also displayed higher rates of abandoned or withdrawn asylum claims than the
international average. Unfortunately, data are not systematically collected on the reasons for the
abandonment or withdrawal of asylum claims.
Table 3-5: Asylum claim outcomes, case study countries, 2000-2010 (summary)
Country
Finalizations Positive Negative Abandoned
Withdrawn
/Other
Positive Negative
Abandoned/
Withdrawn
All countries
312,307 134,923 124,172 22,661 30,549 43% 40% 17%
Czech Republic
2,355 311 451 81 1,512 13% 19% 68%
Mexico
36,878 5,925 20,328 2,678 7,947 16% 55% 29%
Poland 1,654 520 747 268 119 31% 45% 23%
Taiw an
65 8 33 8 16 12% 51% 37%
Source: OPS Stats
Percent
Number
2000-2010
While it is not possible to make a definitive assessment of the legitimacy of the claims, the high rates
of abandoned claims plus the different pattern of negative decisions suggests that many may be
unfounded. If this is the case, then the imposition of a visa in these cases does contribute to
protecting the integrity of the asylum system.
3.4.3. Facilitation of travel
The following section assesses the achievement of the Visitor Visa Program’s facilitation objective.
To assess this objective, the evaluation examined the extent to which the visa application process
facilitates travel, in comparison to other countries, and the impact of visa requirement changes on
travel patterns. This section also presents some mechanisms and tools that aim to facilitate travel to
Canada for bona fide visitors.
34
Finding: CIC’s Visitor Visa Program facilitates the movement of bona fide travellers, as evidenced
by the fact that the TRV processing requirements are similar to those in other countries; by
reaching CIC targets for approval rates; and by introducing other facilitative approaches and tools.
Processing requirements
The visitor visa process and processing requirements can be a travel barrier if the process is not
timely and the requirements are more extensive than those used by other countries. Canada has
faced criticism from stakeholders, such as the Canadian Tourism Commission (CTC), regarding the
extensive information requirements. In 2010, CIC conducted an internally-led comparison study of
the TRV application processes and requirements between Canada and other countries competing
for international tourists. Information was gathered and analysed for the American, British, French
and Australian visitor visa programs in certain key locations comparing processes and requirements
for nationals of China, India and Brazil. The study showed that Canada collected more information
than the other countries reviewed (see Table 3-6). It has the highest number of fields to be
completed by applicants. Also, some information requested varies between different Canadian visa
offices. For example, Details of Past Work Experience and Details of Travel History were not
systematically requested by visa officers in all missions. On the other hand, Canada asked a similar
number of security questions as other countries and requests a similar number of supporting
documents.
Table 3-6: Comparison of Canadian and other countries visitor visa application
requirements
US UK France Australia Visa Canada
Number of required forms to be filled
1 1 1 or 2 1 or 2 2 or 3
Number of pages to fill on the main
application form
Not clear* 10 3 8 4
Number of fields to fill on all required
forms
100 98 49 to 84 95 to 137 101 to 146
Details of Education Required Not required Not required Not required Required
Details of Past Work Experience Required Not required Not required Not required Required*
Details of Travel History Required Required Not required Not required To Canada only*
Family Composition Information Required Required Not required Varies Required
Number of Security Questions
12 6 0 9 5
Number of additional required
documents
6 to 8 16 15 to 23 13 to 19 7 to 17
Source: CIC Internal Review . * updated information
Note: The information in the table presented on the Australia visa excludes eTA related processes
The study showed that Canada offers more options to submit an application, and the vast majority
of applications are processed on paper without an interview. The absence of interviews for
Canadian applicants could explain the need for a higher number of supporting documents than, for
instance, the U.S., where all applicants are interviewed. Fees requested by Canada to process a
single-entry TRV application are the lowest of all comparison countries. Moreover, Canada offers
comparable processing times in the locations reviewed (see Table 3-7).
35
Table 3-7: Comparison of application processing
US UK France
Australia Visa
Canada
Application Submission Process Online* VAC
In person +
VAC
In person + VAC +
mail +Online*
In person + VAC +
mail + online*
Interview 100% If needed If needed If needed If needed
Biometrics Yes Yes Yes No No
Fee (excluding VAC fees) $140 CAD $115 CAD $80 CAD $104 CAD
$75 CAD (single
entry visa)
Processing time in working days 14 to 93 days 1 to 10 days 5 to 10 days 5 to 15 days 1 to 21 days **
Source: CIC Internal Review . * updated information. ** 80% of cases.
CIC International region has reviewed all mission requirements, such as forms and supporting
documents requested, with a view to having a more consistent approach for supporting documents
throughout the network. CIC’s TRV streamlining exercise in 2011-12 has largely eliminated visa
office differences on forms and reduced the number of questions asked. Since January 2011,
applications are only accessible online and must be completed online to ensure that the 2D barcode
is created for each application. Applications are no longer mailed to clients, nor are they available
for pick up in the missions. It is not known what implications this may have on client perceptions
of the ease of access to application and on the number of applications received.
Approval rates
TRV approval rates show the extent to which visa officers approve or reject TRV applications,
which could be considered an indicator of facilitation. CIC administrative data indicates that the
majority of TRV applications, between 79% and 81%, are approved across all regions for the years
under review. By-mission approval rates vary, with a minority having approval rates below 50% (six
missions having approval rates below 50% in 2006-2008 and two offices in 2010). Between 17 and
20 offices (depending on the year) have approval rates of over 90%. Overall, during the last five
years, CIC has consistently met the established approval rate target of 80% for visitors.
Facilitative approaches
To meet its facilitation objective, CIC employs different approaches to facilitate the movement of
bona fide travellers from visa-required countries. Several facilitative approaches are described
below. The effectiveness of these approaches is difficult to measure due to their relative infancy;
however, some early positive results were observed.
Visa Application Centres (VACs): One of the travel facilitation mechanisms that aim to increase
convenience for the client in the visa application experience is the establishment of VACs. VACs
assist clients with the visa application process by providing computers for self-service, providing
one-on-one application completion service, providing photo and photocopy services, checking
applications for completion, sending completed applications to the missions via courier; scheduling
interviews between applicants and immigration staff at the mission; and receiving sealed visa
decisions for distribution to clients. VAC staff also provide services such as answering questions
for clients, providing a tracking system so clients can monitor the progress of their application, and
operating Call Centres and websites to facilitate the application process for clients.
Their services are based on cost-recovery established by the service provider (as approved by CIC)
and their services are optional. The establishment of VACs may yield one or more benefits, which
include:
36
Easier access The ability of VACs to provide more places of service and additional hours of
operations was noted by several interviewees. This allows clients more opportunity to access a
point of service, therefore potentially reducing the time, effort and cost associated with travel
required to submit an application. Canada currently has 60 VACs in 41 countries, almost
doubling the points of access available through missions only. By 2014, CIC wants to expand
the VAC network to 150 points of services. In an audit of the Mexico VAC performed by CIC
in July/August 2010, a large majority of the respondents found the VAC location (86%) and the
hours of operation (93%) to be convenient.
Personal contact The ability to obtain in-person help with completing and verifying an
application is one advantage of the more client-focused environment that VACs can create.
Some interview respondents included among the advantages of the VAC the ability to deliver
face-to-face service and to deliver services in local languages.
Although VACs provide a number of facilitation benefits, a number of concerns were raised during
the evaluation. These include:
Increased cost of obtaining a visa - While use of VACs is not mandatory, if a client chooses
to use the services of a VAC, the VAC fees are an additional cost. However, this may be offset
by the savings on travel, should such travel to the mission be required to submit the
applications in person or courier cost to submit the application.
Use of VACs - In Mexico, over 90% of applications are submitted through VACs, which
indicates it is a popular service; however, a review of some mission websites suggests that it may
not be clear to the client if the use of VACs is optional. Therefore it is not clear if VACs are
popular because of the service they provide or because clients are not sure if they are required
to use their services.
Applicant privacy While CIC and clients may be interested in VACs as a travel facilitation
mechanism, some concerns related to client privacy have been raised. During its operations,
VACs gather, temporarily, a great deal of client information even though the information that
the VAC can collect are limited and the applications and documents are sent daily to the visa
office and are not kept at the VAC. Although service agreements stipulate privacy-related
mitigation strategies, not all had been implemented as visible in the review of the Mexico VAC
(e.g., VACs use of Google’s email service to contact CIC). As a result of the review, privacy
protection processes were strengthened. Privacy and information security concerns were raised
by a few interviewees. A Privacy Impact Assessment and a Threat and Risk Assessment were
conducted and the risks were defined as being of medium concern by the Canadian Privacy
Commissioner. Most of the suggestions for improvement were incorporated in the agreements.
This speaks to the importance of undertaking performance and contract reviews to ensure
compliance. This will be an integral component of the global contract. In the future, some
VACs will also be charged with the collection of biometric information, which, while
convenient for clients, may increase privacy-related risks. This is currently being reviewed by
the Office of the Privacy Commissioner though a Privacy Impact Assessment.
Business Facilitation: Another facilitation measure targets business travellers. Facilitation
measures for business travellers have been developed in selected missions abroad and were in use
for several years in India and China, and introduced in Mexico following the removal of the visa
exemption. CIC is now in the process of applying these approaches more widely and, in 2011,
introduced broader guidance for such measures. These mechanisms aim to make the process more
37
efficient for low-risk cases, while maintaining integrity and improving customer service. Such
initiatives include the Business Express Program (BEP), which offers rapid visa processing and
simplifies application procedures for employees of pre-qualified businesses and/or priority
processing of business visitor applications. In addition, some missions conduct outreach activities
with local business people and business associations in collaboration with the DFAIT Trade
Commissioner Service in order to answer their questions, review existing procedures, and present
an overview of visa processing for business visitors.
Visa-fee-exempt entry for special events: To facilitate the travel of persons participating in
special events held in Canada, CIC introduced, on a case-by-case basis, an exemption from the visa
fee. Recent participants to a women’s conference on empowerment, a commonwealth conference,
and a conference on maternal and child health, have benefitted from this initiative.
Transit without Visa (TWOV):
21
Another mechanism that facilitates the travel through Canada
for foreign nationals of some countries is the exemption from a TRV requirement while travelling
through Canadian airports, allowing them to transit through Canada without having to first obtain
a Canadian temporary resident visa.
Multiple-entry/Long-duration visas: CIC has increasingly moved towards the issuance of
long-term multiple-entry visas. The maximum validity period of a multiple-entry visa can be given
for the validity of the passport (generally less one month), which may be up to 10 years. This
reduces the need for the clients to return to visa offices every time they need to travel, thereby
facilitating travel to Canada for visitors from visa-required countries.
Impact on travel patterns
To assess the effect of visa requirements on travel patterns, the evaluation examined the impact of
the recent visa changes for the case study countries under review. Table 3-8 presents information
on the annual number of travellers to Canada from each case study country. This information is
presented separately by status of visa requirement (visa-exempt/ -required), and reports the yearly
number of travellers when each visa condition applied. For the case study countries under review,
as illustrated, the removal of the visa exemption had a noticeable impact on the number of
travellers coming to Canada. Specifically, the number of Mexican travellers to Canada dropped
considerably since the removal of the visa exemption in 2009, although it is not clear to what extent
larger global events (such as the financial crisis and ensuing recession) played a role in the
magnitude of this decrease. In the case of the Czech Republic, the table also shows a noticeable
decrease in the number of travellers since the removal of the visa exemption.
The impact of granting a visa exemption is less pronounced; however, the data show some increase
in travel after granting a visa exemption. For example, the number of travellers from Poland and
the Czech Republic increased greatly in the years in which nationals of these countries could travel
to Canada without first obtaining a visa. While it is clear that visa requirement changes have an
impact on travel patterns, it is difficult to assess the extent to which bona fide travellers are affected.
In particular, when a visa exemption is granted, it is difficult to determine whether the increase in
travel to Canada is the result of non-bona fide travellers (unfounded asylum seekers, those who
would otherwise be found inadmissible); similarly, the same can be attributed to decreases in travel
due to the removal of a visa exemption (ineligible/inadmissible people are screened out or are
deterred from applying). However, the magnitude of this is difficult to estimate, especially in
21
cicintranet/CICExplore/english/guides/bulletins/2011/297-eng.aspx
38
conjunction with the many other factors that either hinder or encourage travel to Canada (i.e.,
economic conditions, geographic location, ease of application process, etc.).
Table 3-8: Number of travellers under different visa requirement conditions, case
study countries
Country
2003 2004 2005 2006 2007 2008 2009 2010
Czech Republic (Visa Req.)
10,226 11,118 11,570 11,791 11,144 -- 8,108 12,003
Czech Republic (Visa Non-req.)
-- -- -- -- 1,536 15,917 8,339 --
Total Czech Republic
10,226 11,118 11,570 11,791 12,680 15,917 16,447 12,003
Poland (Visa Req.)
20,445 23,007 22,767 25,634 24,012 2,054 -- --
Poland (Visa Non-req.)
-- -- -- -- -- 32,728 -- --
Poland (e-passport req.)
-- -- -- -- -- -- 28,592 29,565
Total Poland
20,445 23,007 22,767 25,634 24,012 34,782 28,592 29,565
Mexico (Visa Req.)
-- -- -- -- -- -- 74,316 123,763
Mexico (Visa Non-req.)
144,061 177,269 194,344 213,945 250,633 270,828 97,690
Total Mexico
144,061 177,269 194,344 213,945 250,633 270,828 172,006 123,763
Taiwan (Visa Req.)
69,273 108,611 100,635 94,917 82,524 63,455 51,608
Taiwan (Visa Non-req.)
-- -- -- -- -- -- -- 54,445
Total Taiwan
69,273 108,611 100,635 94,917 82,524 63,455 51,608 54,445
Source: Statistics Canada
Note: The Mexico, Czech Republic and Poland decisions took place mid-year, therefore some travel data shows both visa regimes
Also see Technical appendices for graphical representation of the table data.
Many interviewees confirmed that when a visa exemption is removed, there is a negative impact on
the travel of bona fide visitors to Canada. A visa requirement can be an irritant and have a
psychological effect on bona fide travel to Canada, suggesting that in certain cultures and countries
not granting a visa exemption could be a sign of Canada being a ‘closed’ country, thus deterring
travel by its citizens.
Some interviewees noted that while there is an initial negative impact on travel when visa
exemption is removed, their perception is that this impact is only short-term. Because visas are
common across the world and the fees are competitive in Canada, travellers become accustomed to
the requirement and travel patterns should return to pre-imposition levels.
3.4.4. Balancing facilitation with integrity
To assess the balance between the facilitation and system integrity objectives, the evaluation
focused on the perceptions of key informants. Respondents were asked to comment on whether
CIC’s visitor visa policy was successful in meeting its overall objective: balancing the protection of
the integrity of Canada’s immigration and asylum system with the facilitation of temporary resident
travel.
Finding: CIC’s visitor visa policy, supported by other tools with similar objectives, is largely
perceived to have successfully achieved a balance between protecting the integrity of its
immigration and asylum system and the facilitation of bona-fide travel to Canada. In addition, the
visa policy is dynamic and has the ability to allow CIC to react to contextual changes.
The majority of respondents felt that CIC’s visa policy has achieved a balance between the
facilitation and protection objectives. A few commented that the balance has been achieved to a
large degree with a slight emphasis on protection, as evidenced by the recent visa imposition
39
decisions. Only a minority of interviewees considered the policy to be more facilitative than the
context requires, and suggested that visa policy may be influenced by stakeholders interested in
promoting economic benefits to Canada.
Respondents who felt that CIC has achieved the necessary balance, frequently cited some of the
new tools and program as important components of this balance.
Many interviewees commented that while visa policy is a crude, blanket approach intended to
protect Canadians, there are other tools, policies and programs that CIC and OGDs offer that help
achieve/refine this balance. As previously noted, initiatives that help facilitate travel include:
programs that facilitate travel for business people, workers, and certain groups travelling with tour
companies; and Visa Application Centres (VACs). Other initiatives, such as biometrics, attempt to
increase security and protect Canadian borders.
Overall, interviewees suggested that the balance between security and facilitation shifts depending
on the political climate or international events (e.g., September 11, 2001) and visa policy decisions
should have the ability to address those emerging risks and opportunities. Most respondents agreed
the visa policy is dynamic and has the ability to allow CIC to react to contextual changes.
3.4.5. Other impacts related to visa requirement changes
A number of additional impact of visa changes identified during the evaluation on bilateral
relations, partners, and the tourism industry are examined in this section.
Finding: The removal of visa exemptions affects Canada’s bilateral relations with countries
impacted by the change. Furthermore, the introduction or removal of visitor visa requirements can
impact CIC partners’ operations and political mandates.
Impact on bilateral relations with other countries
Many interviewees acknowledged the fact that Canada’s visa policy may have an impact on bilateral
relations. However, this impact is very difficult to anticipate because it depends on many external
factors, such as how the impacted country interprets the change. Many interviewees stated that the
visa change processes, including the country visit, aim to address in advance any potential bilateral
or multilateral issues with the impacted countries.
Nevertheless, two of the recent cases may have had a negative effect on bilateral relations. The
removal of the visa exemption for nationals of the Czech Republic affected Canada’s bilateral
relations with that country in three ways: the Czech government retaliated by imposing a visa
requirement on Canadians travelling to the Czech Republic on diplomatic and official passports; it
recalled its Ambassador to Canada; and it continues to warn that the visa requirement may affect
the Czech Republic’s position on bilateral or multilateral initiatives (such as the Canada-EU
Comprehensive Economic and Trade Agreement). The Czech Republic case is also a key source of
strain between Canada and the European Union due to the fact that Canada does not adhere to the
European Union’s policy of reciprocity. This may also prove an irritant with Romania and Bulgaria,
both EU states still requiring Canadian TRVs who may use the trade negotiations and ratification
issues as possible leverage in discussions on the continuation of the Canadian visa requirement.
In the case of Mexico, interviewees noted that the removal of the visa exemption created negative
feelings towards Canada. During many bilateral or trilateral meetings with Mexican government
40
representatives, the topic of the visa requirement was broached. In addition, the Government of
Mexico introduced a visa for Canadian diplomatic personnel.
Impact on OGD partners
The majority of interviewees indicated that some of CIC’s immigration and enforcement partners
(i.e., CBSA, DFAIT, RCMP, IRB, P/Ts) are impacted by CIC’s visitor visa policy and associated
visa changes. The magnitude of this impact depends on the role of the department and may depend
on what country is affected by the decision. The following notes several impacts on certain
partners:
CBSA: Interviewees noted that CBSA’s ability to meet its protection mandate may be affected,
especially when a visa exemption is granted and results in an increased number of asylum claims
at the border and eventual need to remove unsuccessful claimants or visitors that overstay.
Conversely, visa re-imposition supports the CBSA mandate to large degree as it reduces those
activities related to large numbers of asylum claims at the border from a particular country.
DFAIT: Many interviewees suggested that DFAIT is affected in its ability to meet its
facilitation mandate when a visa exemption is removed because it receives many complaints
from business and government officials. DFAIT’s role in promoting trade is also affected by a
change in visa requirements, as well as by its role as a government representative in the
international arena. This is visible in the impact on dealings with the European Union with
regards to the change in visa requirements for nationals of the Czech Republic.
RCMP: A few interviewees noted that the RCMP is likely to have some possible resource
implications if more criminality screenings are required.
IRB: To the extent that changing a visa requirement has an impact on the number of refugee
claims, it will also have an impact on the workload of the IRB; either increasing in refugee
claims as a result of a visa lifting or decrease in case visa exemption is removed.
P/Ts: Provinces are affected by the number of asylum claimants in terms of the costs
associated with the provision of social services. On the other hand, provincial tourism is also
affected with the potential decline in travellers from certain countries (e.g.; Mexican tourists to
British Columbia ski resorts).
Finding: There is a potential negative impact on the Canadian tourism industry when a visa
exemption is removed, as it is expected to result in a decrease in the number of travellers from the
affected country. Conversely, when a visa exemption is granted, it should have a positive impact
on tourism. The available evidence supports these assumptions, although data on the magnitude of
the impact is mixed.
Impact on Canadian tourism industry
As noted previously, re-imposing a visa requirement on a country has an impact on travel patterns
to Canada. The expectation is that the removal of a visa exemption will decrease the number of
travellers to Canada, thereby decreasing tourism revenue, and the reverse is expected when a visa
exemption is granted. Some key informants believe that there was an impact on the Canadian
tourism industry due to the potential decrease in travellers from countries following the recent
changes to visa requirements. However, they also believed that any potential impact can only be
considered on a case-by-case basis. Partners who represent the tourism industry identified the
41
potential risks, which include decreased revenues and employment. An analysis of the potential
impact of the Mexico visa requirement on the Canadian tourism industry, provided by Statistics
Canada, suggests that for the first two years since the change in visa requirements, the Canadian
tourism industry potentially lost approximately $340 million dollars in tourism revenue.
22
This must
be compared with the cost of the processing of unfounded refugee claims for the two countries (as
presented later in the Section on Efficiency and Economy). Analysis of the Taiwan tourism data
from the Canadian Tourism Commission shows that the gain in the Taiwanese tourists brought an
additional $5 million into the Canadian economy (vis-à-vis $33 million predicted in the RIAS). The
information on Poland, another case study country where a visa exemption was introduced, shows
some increase in travel but the impact cannot be estimated due to lack of data.
3.5. Efficiency, economy and alternatives
A review of costs associated with the Visitor Visa Program, potential alternatives and
supplementary approaches, as well as a literature review of tools used by peer countries is contained
within the following section.
3.5.1. Resource utilization
This section briefly reviews Program cost, cost per visa as well as resource saving associated with
introduction of visa.
Finding: Although the evaluation framework did not include a detailed analysis of program costs,
available data suggests that there are several financial resource implications associated with TRVs.
Furthermore, according to internal financial data, the costs of processing a visa are higher than the
revenue generated from TRV fees.
CIC Program cost
The total costs associated with the CIC Visitor Visa Program (processing, policy and management,
and corporate support services) are presented in Table 3-9. Using data from CIC’s Cost
Management Model (CMM)
23
, these costs were estimated at $68M in 2007/08 and $87.5M in
2009/10. A part of the cost of the Program is CIC’s corporate services, allocated as a percentage of
the overall CIC expenditures across all CIC programs. With growth in the overall CIC budget the
cost appears to grow significantly between the two years. A review of the direct visa processing cost
associated with CIC, LES and CBSA integration officers in the missions shows that around
$23-24M (33% of the total for 2007/08 and 27% of the total for 2009/10) was allocated to
processing visas overseas (including screening, processing applications, conducting anti-fraud
activities, and providing outreach to the public). This amount has not changed significantly
between the two years for which data is available.
22
www.statcan.gc.ca/tables-tableaux/sum-som/l01/cst01/arts38a-eng.htm
23
CMM combines visa processing efforts estimates from CIC units and the TRV volumetrics obtained from
operational systems to establish the total costs related to the processing of Visitor Visas. Visitor Visas processing costs
shown in the table above include operational processing, program management and policy and corporate services.
CMM allocates the costs of program management and policy and corporate services based on weighted costs
percentage attributed to the TRV program.
42
Table 3-9: TRP program cost
2007-08 2009-10
CIC Visitor Visas Processing CIC
$10,253,749 $10,553,399
CBSA - Integration Officers
$416,227 $634,348
Locally Engaged Staff
$11,881,769 $13,182,410
$22,551,746 $24,370,157
Program and Policy Support
$22,649,653 $31,239,956
Corporate Support $22,868,037 $31,925,107
Total Program Costs* $68,069,435 $87,535,219
Source: CIC Cost Management Model - 2007-08 and 2009-10 Strategic outcomes cubes.
Partial Costs for CIC Visitor Visa processing
Cost per visa
The resources presented above represent CIC costs associated with processing TRVs, including
CIC, LES and Integrity Officers from CBSA whose salaries are covered by CIC. Table 3-10 (below)
uses the latest available TRV cost calculations from CIC’s Finance Branch, which includes costs
borne by other government departments (DFAIT, Department of Justice, additional CBSA
functions, RCMP, etc.). It shows that the revenues and costs associated with processing temporary
resident visas for visitors remained fairly stable over the years (2001/02-2007/08). Table 3-10 also
shows that the revenues and costs associated with processing temporary resident visas for visitors
were lower than the revenues and costs associated with processing temporary workers and
students. The table also indicates that full cost recovery of TRV processing was not achieved. This
means that, for the period under review, the cost of producing a visa was higher than the revenue
generated through processing fees. Furthermore, the literature review suggests that all reviewed
countries have had difficulty fully recovering the cost of processing visitor visas through fees.
While raising application fees to ensure cost recovery may be an option, it may also result in
diminishing tourism and trade.
Table 3-10: Total cost of TR processing
Revenue Cost
2001-2002
$125.00 $148.85
2002-2003
$125.00 $182.16
2004-2005
$125.00 $216.35
2006-2007
$125.00 $185.46
2007-2008
$125.00 $195.97
2001-2002
$150.00 $205.23
2002-2003
$150.00 $221.15
2004-2005
$150.00 $284.39
2006-2007
$150.00 $186.26
2007-2008
$150.00 $215.59
2001-2002
$92.75 $147.38
2002-2003
$92.01 $150.51
2004-2005
$94.62 $134.52
2006-2007
$94.54 $137.01
2007-2008
$95.18 $151.19
$150
$223
$186
$125
Category
Source: Cost Management Model and information provided by Other Government Departments (ODG). Information
from RCMP is missing for some years.
Average Fee Revenue
per Aplication
Average Cost per
Application
5-Year Costing Average
Fiscal Year
Visitors
Temporary
Workers
International
Students
$94
$144
43
TRV processing activities
CIC estimates the level of effort involved in processing applications. However, due to the structure
of the system, which relies on extrapolation based on volume, it is difficult to precisely define how
the time allocated to processing TRVs is actually spent on the various activities, such as criminality
screening. While volume-based estimates are available, CIC has no precise information to assess
the actual resource allocation to the particular task. In addition, given the lack of targets for each
activity, it is not possible to make any judgement on the appropriateness of resource allocation to
tasks, especially those related to processes related to security screening (anti-fraud, criminality
screening, etc.).
Financial resources
There are financial resource implications when a visa requirement change is made. When a visa
exemption is removed, CIC may need to open a visa office in the affected country or close an office
when a visa exemption is granted. Interviewees commented that CIC foregoes revenue (to the
Consolidated Revenue Fund) when it grants a visa exemption, which may pose a significant
resource pressure for CIC when granting visa exemptions, yet this is not a consideration in
providing the recommendations. Furthermore, resources are allocated to support visa changes on
case-by-case basis. When a visa exemption is removed, CIC and its partners must seek resources to
support the implementation of the change. In some cases, they must find the resources within their
existing allocations; in the case of significant change, such as Mexico, resources may be allocated
through separate funding request.
Asylum claim costs
The cost of asylum claims is significant in both federal and provincial governments. The federal
costs are incurred through operational processing and the provision of interim federal health
benefits to asylum claimants and their families in Canada. The provincial costs are incurred through
the provision of legal aid, social assistance, and education. Under the current in Canada asylum
system, the total cost per claimant is estimated by CIC at:
$16,142 for positive claimants ($5,992 federal and $10,151 provincial)
$48,285 for negative claimants ($16,593 federal and $31,693 provincial) based on estimated
time of 50 months for negative claims.
The costs associated with processing the number of negative and abandoned claims from Mexico
in 2009 was estimated
24
at $304M and $68M for Czech Republic. In 2010, given the decrease in the
number of claims received, these cost were estimated at $44M for Mexico and $1.2M for the Czech
Republic, representing a net savings of $326M. Not taking into account other potential costs of
removing the visa exemption granted to nationals of Mexico or the Czech Republic (e.g., loss of
tourism), both the federal government and the provinces benefitted from the savings associated
with a decrease in the number of unfounded refugee claims in Canada.
24
The cost of processing positive cases is not included in these estimates. The cost was calculated using the average
number of years claimants remain in the country while their claim is in process. The cost associated with
abandoned/withdrawn claims was calculated using half of the cost for negative cases.
44
3.5.2. Alternatives
When assessing the alternatives to the Visitor Visa Program the evaluation focused on 3 different
perspectives:
Alternative to the evidence-based approach represented by the visa policy framework;
Alternatives to visitor visa as a tool;
Alternatives to addressing similar objectives protecting integrity of the immigration and
asylum system.
Finding: There are several potential alternatives to CIC’s approach to TRVs. While they are unlikely
to better meet CIC’s facilitation and integrity objectives at the present time, some could be
effectively used to supplement existing frameworks, tools and indicators, thereby creating a more
encompassing system.
Alternatives to the visa policy framework
There are two main policymaking alternatives that could be used rather than the evidence-based
decision making approach currently employed by Canada: the reciprocity approach and the
perimeter approach. In addition, instead of using a policy framework, decisions could be rooted in
legislation.
Reciprocity: Reciprocity is a principle that governs visa policymaking and in which two countries
exchange the privileges of visa-free travel with one another. Basing policymaking on reciprocity
could reduce the current level of data collection and evidence gathering, as a decision would rely on
bilateral agreements
As an example, Canada is under some pressure from the EU to extend visa-free travel to its
member countries in a reciprocal approach. When new member countries are admitted to the EU
(more specifically, to the Schengen area), they extend visa-free travel to Canadians; in exchange, the
EU would like to see visa-free travel in Canada for the new members. While Canada has lifted visa
requirements for citizens of Estonia, Poland, Hungary, Czech Republic (subsequently
reintroduced) and Lithuania, it was done based on the current process, not on reciprocity.
Currently, Canada has a variety of arrangements with various Schengen area countries as some still
require a TRV to travel to Canada and some travel visa-free. In 2011, citizens of Hungary, who do
not need a visa, represented the highest source of asylum claims made in Canada (Technical
Appendix).
Therefore, while the reciprocity approach could contribute to achieving the facilitation objective
and would be beneficial to bilateral relationships, it could have negative implications on the
integrity of the immigration and asylum systems. Canada is considered one of the most risk-free
countries in the world, and the use of reciprocity for countries that grant Canada visa-free travel
may expose Canada to unnecessary risks.
Perimeter: A second potential approach to defining a country’s visitor visa policy is to align the
policy of several countries to create a perimeter, governed by similar rules of entry for all countries
within the area. The goal of such an approach is to create a common security area, while at the same
time, facilitating free mobility between members. The Schengen Area in Europe is the most
recognized example of such an approach. This approach is effective in facilitating movement
between member countries and providing all countries within the perimeter area with an integrated
45
approach to achieve joint security objectives. On the other hand, the perimeter approach requires
member countries to give up some degree of independent control over decisions regarding its
borders. Access to a country has been one of the most guarded rights associated with state
sovereignty; the movement toward integration of members may be a challenge and may be resisted
by the citizens of the member countries. Among Canadians, 75% are in favour of shared
intelligence gathering between Canada and the United States, and 23% strongly support this idea.
However, over two-thirds (68%) of these same respondents believe that Canada will cede too much
power to the United States over decisions related to immigration, privacy and security.
25
Challenges
in developing such an approach include: creating common systems, processes, and information
sharing agreements; the high reliance on IT; and the exchange of information between various
jurisdictions and systems is a concern, in terms of use of personal information and privacy issues.
On December 7, 2011, Canada and the US announced an Action Plan on Perimeter Security and Economic
Competitiveness focusing on multiple joint border-related initiatives to achieve a vision built upon a
perimeter approach to security and economic competitiveness.
26
Many of the challenges will be
addressed in cooperation agreements, such as an information-sharing agreement, through the
introduction of enhanced screening systems (discussed in next section) and through
interoperability of IT systems and databases. While the Action Plan aims to align some processes, it
does not call for the alignment of visa exempt countries. Thus, the current evidence-based
approach will still inform any future Canadian visa policy decisions.
Legislated approach: The US uses a legislative approach for introducing countries to their Visa
Waiver Program, under which each country admitted must be reviewed on a two-year schedule.
This approach, while providing structure and formality, was perceived by interviewees as less
flexible than the current needs-based approach. It would require additional resources and was not
viewed as contributing to the integrity of the visa policy nor would it improve facilitation of travel.
All three of the above policy approaches could potentially be used by Canada; however, the review
of their strengths and constraints suggest that none would replace the evidence-based approach
currently used to achieve a balance between facilitation and integrity objectives. Therefore, the
evidence-based approach currently employed by Canada appears to be the best way for Canada to
meet the stated objectives in a flexible and effective manner.
Alternative to the TRV tool
In terms of the TRV itself, the main method for granting permission to enter being used currently
by several of Canada’s peer countries is the electronic travel authorization tool.
Electronic travel authorization programs (including the Australian eTA/eVisitor and US
ESTA approaches): An electronic travel authorization requires a potential traveller to complete
an electronic online application form. The information is processed through an automatic risk
screening system which determines whether the individual can travel (positive assessment), or
requires an in-person assessment (negative). These programs have been introduced by peer
countries such as Australia and the U.S., but have not yet been implemented by Canada.
27
In these
25
Potential Elements of Perimeter Security Deal Garners Strong Support and Canadians have Reservations about
Aspects of Perimeter Security Deal. www.cic.gc.ca/english/resources/research/scan/march2011/index.asp
26
actionplan.gc.ca/eng/feature.asp?pageId=337
27
Discussion regarding the development of a Canadian Electronic Travel Authorization (eTA) program is currently
underway. In the Action Plan on Perimeter Security and Economic Competitiveness, Canada committed to implementing an
enhanced approach to identifying and interdicting inadmissible persons at the perimeter, including establishing an eTA
46
countries, the travel authorization is used as ‘limited’ screening tool for low-risk countries which
either have the legal status of a visa (as in the case of Australia), or is used to affirm eligibility to
travel under visa-exempt status (as in the case of the U.S.). In principle, the electronic travel
authorization tool addresses dual objectives: facilitation of travel, by enabling residents of certain
countries to go through a less demanding process of obtaining a travel authorization; and
protection, by enabling the screening of all travelers to some degree.
Strengths:
Efficiency and program integrity Some anecdotal evidence from the literature review
suggests that the introduction of an electronic system reduced the workload in visa offices in
Australia, as some of applicants are now processed through electronic means. This enables
officers to process visitor visa applications from clients who are required to complete a
traditional visa application more quickly and/or devote more attention to complex
applications. Evidence also suggests that processing at the POE is more efficient as a greater
number of applicants would be ‘known’ at the time of entry as their data will be available
through an electronic record, and could therefore be processed more quickly upon entry.
Ease of application process Some evidence from the literature review suggests that these
programs contribute to the facilitation of travel as the client benefits from ability to do the
process on-line.
Less of a bilateral irritant Evidence suggests that this requirement resulted in a lower level
of criticism from affected countries in Europe compared to the introduction of a visa
requirement. The eTA could be used to complement granting visa exemptions in situations
where some potential risks may exist, yet facilitation would be beneficial for other reasons. As
the Australian experience shows, introduction of such an approach was received favourably by
countries granted an exemption from the traditional visa process.
Increased coverage - In the Canadian context, an electronic travel authorization could
address potential screening gaps that exist for visa exempt countries, specifically, individuals
from these countries that pose a risk to Canada. This has the benefit of preventing some
inadmissible travellers from arriving in Canada, where detention, removal costs and social costs
could be incurred. The literature review was not able to determine whether the Australia ETA
has been successful in actually reducing these risks.
Challenges:
Information privacy concerns Evidence from the literature review suggests that there is
not a full understanding or discussion (with exception of the EU) of the privacy issues with the
move to electronic system of visa provision; however, issues such as identity theft and function
expansion have been raised as concerns. It was also mentioned that this may increase with the
collection of biometric information in the future.
Quality of decision The decision generated by the electronic system will only be as strong as
the data entered in the systems, especially as it relates to information collected and provided by
other countries. Furthermore, reliance on electronic decision-making, as opposed to
face-to-face and paper assessment, reduces the human aspect of decision-making (e.g.;
system, to improve screening of all visa-exempt foreign nationals. This initiative will mirror measures taken in the US
through its Electronic System for Travel Authorization system.
47
suspicions about an applications intentions and demeanour based on contact with the file or in
person). In addition, in the Canadian context, the decision to grant a visitor visa is delegated to
Minister and its representatives and, at this point, does not include an electronic means of
decision rendering.
Reliance on IT systems With shift to electronic service provision, IT security and
interoperability have become continuing and grown concern due to the complexity/cost of
implementation (reliance on costly external experts/consultants) and the continued need for
information sharing across jurisdictions.
Additional requirement If the eTA is introduced on countries that are currently visa
exempt, it may be perceived as an imposition on travellers. This was not the case in Australia,
which has a universal visa requirement. In such cases, the eTA appears to be more of a
facilitation mechanism. However if the eTA is introduced for countries that are currently visa
exempt, the eTA operates as an additional screening mechanism rather than facilitation tool.
Overall, given the limited information to date on the effectiveness of the eTA, it is unclear whether
its introduction in Canada would improve travel for those countries that are currently visa-free,
although it would provide an additional screening mechanism for those countries. It could also
facilitate travel from some lower-risk countries that currently require a visa if it was used as an
alternative. Evidence from the Australian and US program has shown that these programs are an
effective tool for identifying some inadmissible travellers and those using lost/stolen/fraudulent
travel documents. As the introduction of an eTA system is not expected to take place over the next
2-3 years, in the near future, the traditional visitor visa will remain the primary tool for managed
migration for the immediate future.
Alternatives to protecting the integrity of the immigration system
The Visitor Visa Program is intended to protect the integrity of the immigration system. In
interviews biometrics and exit controls were the most frequently mentioned alternatives to
achieving this objective.
Biometrics: The use of biometrics is seen by many countries as a complementary tool for
management of the temporary movement of migrants. It has dual objectives: the facilitation of
travel for bona fide travellers by enabling them to be screened faster at the POEs and increased
precision in identifying those that may pose a risk to Canada. There are, however, implications
in terms of: client privacy, especially if biometrics collection is done by commercial service
providers such as VACs; IT reliance; system interoperability; and the quality of data associated
with its implementation.
28
Exit Controls: Some interviewees noted that implementing an exit control system would be
one way of measuring how effective Canada is managing temporary travel. Exit controls would
enable Canada to create a record of when a temporary resident leaves Canada, which would
provide more up-to-date information on irregular migration trends (overstays, etc.). Exit
controls could be an effective measurement/monitoring tool and provide information on
overstays as a good indicator of non-compliance. In the Action Plan on Perimeter Security and
Economic Competitiveness, Canada and the United States committed to developing a system, by
28
With the passage of the Protecting Canada’s Immigration System Act on June 29, 2012, the Government of Canada will be
able to require biometric information from certain applicants starting in 2013 as part of the visitor visa, study, and work
permit application process. However, given the costs, biometrics will only be implemented for select countries.
48
June 30, 2014, to exchange biographical information on the entry of travellers, at the common
land border, including citizens, permanent residents and third-country nationals, such that a
record of entry into one country could be considered as a record of an exit from the other.
Canada also committed to developing a system to establish exit for air travel, similar to that in
the United States, under which airlines will be required to submit their passenger manifest
information on outbound international flights.
Alternatives to protecting the integrity of the asylum system
The Visitor Visa Program has as an objective to protect the integrity of the asylum system. The
following examines alternatives in achieving this objective:
Safe Third Country Agreement: Safe Third Country agreements require people making
asylum claims to do so in the first safe country they arrive to. This option would reduce the
number of asylum claims for those who are transiting through other countries but would not
address the number of claimants coming directly from their country of origin; therefore, it
would be only partially effective in lowering number of asylum claims made in Canada.
Reform of Canada’s asylum system: As stated by the Auditor General of Canada in its 2003
report, delays in rendering final decisions on asylum claims can leave the system open to abuse.
Long processing times encourage potential unfounded asylum claimants to make claims
knowing that they will be able to live and work in Canada for many years. To address this
weakness, the Government has initiated a broad reform of Canada’s asylum system aiming to
shortening the time it takes to process claims.
29
If the claims are processed more quickly, the
potential for abuse should diminish. However, as the full implementation of reforms to the
asylum system is yet to be completed, its potential effectiveness in improving the integrity of
the asylum system is not yet known. With time, however, it is presumed that this reform will
address some of the issues related to the integrity of the system.
Safe Country of Origin: One of the strategies under the reform of Canada’s asylum system
that could also be considered independently is the designation of certain countries as “Safe
Country of Origin”. Nationals from those countries would be able to make asylum claims, but
they would be processed in an expedited manner. As it has not yet been fully implemented, it is
difficult to determine how effective this approach would be in improving the integrity of the
asylum system.
While all the above approaches could be effective in addressing asylum system integrity, their
effectiveness cannot currently be measured, given the changes underway in the asylum system.
A review of all the above mechanisms suggest that while alternatives to policymaking,
implementation and protecting system integrity exist, the visitor visa remains the most effective
tool to manage migration at the current time and for the near future. The evidence-based approach
provides for targeted and flexible changes, and while the ETA is considered the most likely
potential alternative for many years to come it will complement the visitor visa approach. In
addition, in terms of approaches to address system integrity, all of these could, theoretically, play a
role in addressing system integrity; they will all take time to be fully implemented. Implementing an
29
Bill C-11, the Balanced Refugee Reform Act, which received Royal Assent on June 29, 2010, and Bill C-31, the Protecting
Canada’s Immigration System Act, which received Royal Assent on June 29, 2012, were introduced to protect and improve
Canada’s immigration system. Among several measures are changes to accelerate the processing of asylum claims and
the introduction of Designated Countries of Origin.
49
exit control system would be one way of improving and measuring how effective Canada manages
its temporary travel. Currently, most countries have a mix of migration control tools that include
visas, eTA tool as a visa alternative for selected lower-risk countries and general country-level
exemptions. As the literature review points out, the immediate future is likely to involve a hybrid
system rooted in country-level exemptions (determined at the national or, in the European case, regional level)
complemented by selective exemption from full applications approaches. Decisions to adopt one or more of
these tools are predicated upon an assessment of their risks and benefits by each country.
50
4. Conclusions and recommendations
Relevance/alternatives
The visitor visa is a relevant tool as it addresses the need to manage the movement of temporary
residents. It remains widely used by peer countries and, in the majority of cases, Canada’s visa
exemption list aligns with its peers. This creates an environment where Canada facilitates travel,
while preventing the entry of travellers that could pose risks to the integrity of the immigration and
asylum system, and the safety and health of Canadians.
While potential alternatives to Canada’s visitor visa exist, such as an electronic travel authorization
(eTA) system, the visitor visa will remain the most effective tool to manage migration until other
tools are further investigated / implemented and their effectiveness is assessed.
Recommendation #1:
Canada should continue using the visitor visa as a tool to manage migration,
while at the same time, investigate the feasibility of introducing supplementary tools to better meet its objectives
(protection and facilitation). In doing so, CIC should take into account the benefits, risks and resource needs
associated with implementing each option.
Performance
Policy
Monitoring and evidence from country reviews are used, as required, to support visa policy
recommendations and the regulatory process. However, the visitor visa program, as currently
designed, focuses on CIC’s own objectives and does not take a whole-of-government approach.
While the policy process seeks input of relevant other government departments, there is a need to
improve their involvement and participation in analysis and decision-making processes.
Recommendation #2:
CIC should assess, with its federal government partners, the strengths and
weaknesses of the current partner engagement strategy in visa policy development, to address their needs and
concerns and gauge the feasibility of broadening the considerations during the visa review process, towards an
increased whole-of-government approach.
Processing
The evaluation presented recent CIC efforts to introduce or expand various facilitative
mechanisms, such as VACs, multiple entry visas, long-term visas, and the business express
program, in order to streamline the processing of applications. Those initiatives have the purpose
of creating streamlined processes to make it easier for clients to visit Canada and reduce resource
utilization at CIC. As these are fairly new initiatives, the evaluation did not assess their effectiveness
at this time.
In addition, the evaluation reviewed the role of the VAC in supporting processing in Mexico,
identified some benefits but also the importance of undertaking performance and contract reviews
to ensure compliance. With expansion of the VAC network in the world, CIC is relying increasingly
on a variety of third-party organizations to support the TRV process. The expansion of VAC to a
global network is a new initiative and creates new opportunities and possible challenges.
51
With continued expansion of the VAC network, CIC is increasingly relying on a variety of
third-party organizations to support the TRV process. The expansion of VAC to a global network
is a new initiative and creates new opportunities and possible challenges.
Recommendation #3:
CIC should develop strategy and assessment tools to measure the impact of the
various facilitative mechanisms, in terms of their objectives and effectiveness in managing processing demands.
This should also include an assessment of the VAC network and its effectiveness in assisting the modernizing
of CIC operations.
Integrity of the immigration and asylum systems
The visitor visa is an effective tool that helps protect the integrity of CIC’s immigration and asylum
system by reducing irregular migration (primarily unfounded refugee claims), and potentially
playing a deterrence role. Measuring the overall impact of the visa on irregular migration is
challenging due to lack of data on certain indicators (i.e. overstays, illegally working in Canada, etc.).
Recommendation #4:
CIC should explore other, more effective methods of collecting data on irregular
migration, such as overstays, to better inform policy-makers about the success of the program in achieving its
immigration and asylum system integrity objectives.
53
Appendix A: Evaluation matrix
Evaluation Issues
Indicator
Methodology
Relevance
1. Is there a continued need for
temporary resident (visitor)
visas and related
regulations
30
?
Key stakeholders identify continued need for visa policy framework
Alignment with international trends governing visa policy frameworks
Evidence of need to control temporary resident movement (e.g. program integrity,
health, safety and security, etc.)
Interviews
Document Review
Administrative data
Review of selected countries’
visa policies
Case Studies
2. Are the objectives of the visa
policy framework consistent
with GoC and CIC priorities
and objectives?
Alignment/consistency of visa policy framework with GoC objectives with respect to
migration and security
Alignment/consistency of visa policy framework objectives/outcomes with GoC/CIC
priorities (IRPA, Strategic outcomes (SO4), Program Outcome (4.2))
Document Review
Interviews (CIC)
3. Is there an appropriate
division of roles and
responsibilities in making
visitor visa
recommendations/
regulations?
Appropriateness of the roles and responsibilities of CIC program partners and OGD
stakeholders
Perceived and self-reported level of CIC program partner and OGD stakeholder
understanding with respect to roles, responsibilities and objectives
Document Review
Interviews (CIC, OGDs)
Performance
Policy
4. To what extent do ongoing
country monitoring processes
capture relevant and timely
data to support
recommendations?
Evidence and appropriateness of monitoring criteria (targets, thresholds, etc.)
Variety, type and frequency of data collected
Appropriateness of processes for country reviews (timeliness, use of established
thresholds and targets)
Document Review
Administrative data
Interviews (CIC, OGDs, WG
members)
30
Temporary Resident Visa regulations includes country- and document-based exemptions found in Sections 190(1), 190(2) and 190(2.1) of the Immigration and Refugee
Protection Regulations
54
Evaluation Issues
Indicator
Methodology
Degree to which country reviews are planned vs. ad hoc
Evidence of adoption of new methodology, tools, and approaches used in country reviews
based on experience/lessons learned
Interviews with field staff (as
appropriate)
Case Studies Mexico (2009) and
Czech Republic (2007 & 2009),
Taiwan (2010), Poland (2008)
5. Are CIC program partners and
stakeholders engaged and
collaborating to inform visa
recommendations?
Evidence of mechanisms to engage CIC program partners and stakeholders
(informal/formal communications, working groups, MOUs, etc.)
CIC program partners and stakeholders’ perceptions regarding the appropriateness,
timeliness, usefulness, and quality of engagement mechanisms
Degree to which engagement with CIC program partners and stakeholders is consultative
and reciprocal
Document Review
Interviews (CIC, OGDs)
Interviews with Working
Group members
6. Is evidence from ongoing
monitoring and country
reviews used to support
country-level visa
recommendations?
Degree to which country review findings are used to inform recommendations and
regulations
Number of recommendations on lifting/imposing visa requirements made with/without
country review process
Number of recommendations on lifting visa requirements made with/without technical
visit
CIC program partners and OGD stakeholders’ perception regarding the degree to which
visa recommendations are based on evidence
Document Review (RIASs,
PMEPs, IRPA Regulations,
Canada Gazette)
Interviews (CIC, OGDs)
Case Studies Mexico (2009) and
Czech Republic (2007 & 2009),
Taiwan (2010), Poland (2008)
Implementation
7. Are the information needs of
external stakeholders being
met?
Number of communication materials published (press releases, etc.) and outreach
activities conducted
Information sharing processes, timelines, schedules
Stakeholders’ perceptions about the quality/timeliness/ /clarity of communication on
changes in regulations
Document Review (Media)
Interviews (Embassies,
International Partners)
Case Studies Mexico (2009) and
Czech Republic (2007 & 2009),
Taiwan (2010), Poland (2008)
8. Do CIC visa offices
abroad/processing centers
have the capacity to meet the
Perception of staff on the ability to meet demand (due to changes in regulations,
annual/seasonal fluctuations, health and safety concerns, between temporary streams),
by mission and VAC
Document Review
Interviews/Survey (CIC IR)
55
Evaluation Issues
Indicator
Methodology
processing demand,
especially in response to
changes in visa regulations?
Adjustment in number of FTEs to meet demand (due to changes in regulations,
annual/seasonal fluctuations), by mission and VAC
Field management and staff perceptions of whether proper supports are put in place to
support efficient processing of visitor visas (e.g. training, guides, applications, etc.)
Trends in case load by FTE, by mission and VAC (number of applications per person)
Trend in number and percentage of visitor applications received, processed and issued,
by mission and VAC
Trend in inventory, by mission and VAC
Trend in number of decisions rendered overseas (positive, negative, withdrawn), by
mission and VAC
Trend in number and percentage of visitor applications forwarded to CBSA, by mission
and VAC
Trend in processing times (annual and seasonal), by mission and VAC
CIC (IR) staff perceptions of the impact of visa lifting/imposing on the processing of
applications in the Temporary Resident stream (visitors, workers and/or students)
Administrative data review
(HR information)
Case Studies Mexico (2009) and
Czech Republic (2007 & 2009),
Taiwan (2010), Poland (2008)
Outcomes achievement
9. To what extent does CIC’s visa
policy
framework/implementation
contribute to the integrity of
Canada’s immigration and
asylum system?
Perception of CIC senior management on the impact of visa policy framework on the
integrity of the system
Perception of CIC program partners and stakeholders regarding the deterrence effect of
the visa requirement on irregular migration
Degree to which immigration partners (CBSA, DFAIT, RCMP, IRB, P/Ts, etc.) are impacted
by visa regulations
Number and % of TRV applications refused (by reason of refusal )
Trend in number of immigration violations
31
and immigration violation rate (%)
committed by visitors from visa-exempt and visa-required countries
Number of asylum claims from visa-exempt and visa-required countries and the
proportion (%) relative to all asylum claims made in Canada, and evolution of trend
Extent of visa fraud and/or misuse (use of fraudulent documents)
Document Review
Interviews (CIC, OGDs, P/Ts
International Partners)
Administrative data review
Case Studies Mexico (2009) and
Czech Republic (2007 & 2009),
Taiwan (2010), Poland (2008)
31
Immigration violations include all documented infractions to Canadian immigration laws, inadmissible individuals at a Canadian port of entry (including for health,
safety and security reasons) and interceptions of individuals en route to Canada.
56
Evaluation Issues
Indicator
Methodology
Degree to which costs of irregular migration (with focus on selected case study countries)
impact Canada’s immigration and asylum systems
10. To what extent does CIC’s visa
policy framework/
implementation contribute to
the facilitation of travel for
bona fide travellers?
Number of single-entry and multiple-entry TRVs issued for visitors, students and workers
(from selected visa-required case study countries) and % of demand
Trends in number of people admitted to Canada as visitors over the last 5 years (for
selected case study countries before and after the change in regulations)
Stakeholders’ perceptions of impact of visa liftings/impositions on bona fide travel to
Canada
Change in number of travelers from visa-required and visa-exempt countries
Visa acceptance rates
Number of temporary visitor documents issued at Ports of Entry for citizens from
visa-exempt countries
Evidence of innovative approaches to deal with visitor visa pressures (e.g., VAC, Business
Express, International Experience Canada, Transit Without Visa Program, Long Term
Multiple Entry Visas, etc.)
Document Review
Interviews (CIC, ODGs,
International Partners)
Administrative data review
Case Studies Mexico (2009) and
Czech Republic (2007 & 2009),
Taiwan (2010), Poland (2008)
11. Have there been any other
impacts associated with
visitor visa regulations?
Evidence of outcomes not accounted for in original plan and design (positive or negative)
Impact on tourism industry (positive and negative)
Impact of visa regulatory changes on Canada and relevant countries’ bilateral relations
and commercial exchanges
Document review
Interviews (CIC, OGDs)
Case Studies Mexico (2009) and
Czech Republic (2007 & 2009),
Taiwan (2010), Poland (2008)
12. Are there alternative
approaches to CIC’s visa
policy framework that could
meet the objectives more
efficiently and effectively
(facilitating travel and
protecting borders)?
Comparison of Canada’s visa policy framework with other visa policy tools/regimes/
approaches/content (in Canada and internationally). The following examples may be
included in this comparison:
Reciprocity
Individual-based decisions: Australia’s eVisitor, US ESTA
Document or status based-exemptions
Note: The scope of the comparison will be further defined with program staff at the time
of the evaluation.
International Comparison:
Document Review
Interviews