IRCC Paper Application Exemptions: Who Still Qualifies?

Who Can Apply on Paper? IRCC Clarifies Exceptions to the In-Canada Online Application Rule for Temporary Residents

Most temporary residents in Canada must now apply for extensions, work permits, or study permits electronically. However, the Immigration, Refugees and Citizenship Canada (IRCC) recently reaffirmed that some categories of applicants are exempt from this mandatory online submission rule and may continue to file by paper under specific circumstances.

This clarification, outlined in IRCC’s operational guidance, ensures that individuals who face technical or personal barriers to online filing can still maintain lawful status and access immigration services while in Canada.

Background: The Electronic Filing Requirement

Since 2019, the Immigration and Refugee Protection Regulations (IRPR) have required most applications made from within Canada to be submitted electronically through a secure IRCC online account.

This applies to applications for:

  • Work permit extensions or renewals,
  • Study permit extensions,
  • Restoration of temporary status, and
  • Applications made under youth mobility programs.

Failure to use the electronic system may result in a rejected application — unless the individual qualifies for one of the officially recognized exemptions.

Who Is Exempt from the Online Application Rule?

IRCC recognizes several situations where applicants may apply by paper instead of online. These include:

1. Exceptional Circumstances Beyond the Applicant’s Control

Applicants can use paper forms if events beyond their control prevent online filing — such as:

  • Inadequate internet or technical infrastructure in their area,
  • Political instability or natural disasters disrupting access, or
  • Other conditions that make electronic systems unreliable.

2. Applicants with Disabilities

Individuals who, due to a disability, cannot complete an online application may submit their materials on paper.

Officers are instructed not to demand proof of disability as long as the paper submission is complete and consistent with the application type.

3. System Limitations and IRCC Portal Restrictions

Some categories of applications cannot yet be processed through IRCC’s online systems. These include:

  • Bridging Open Work Permit applicants under category A75, who have received acknowledgment of receipt for a permanent residence file,
  • Quebec physicians (C10) and International Experience Canada (C21) participants extending or changing employers,
  • Post-Graduation Work Permit holders (C43) who did not receive the full authorized period, and
  • Refugee claimants or individuals under unenforceable removal orders (S61/S62) applying to maintain or restore their work authorization.

Certain temporary residents — such as family members of work or study permit holders, or visitors using refugee or stateless travel documents — may also qualify to submit on paper.

How to Apply on Paper (When Eligible)

If you fall under one of the exempt categories:

  1. Complete the appropriate paper application forms (for example, IMM 5710 for work permits).
  2. Include all supporting documentation and required fees.
  3. Mail the full package to the IRCC address specified in the application guide.

IRCC officers will review these paper applications under the same criteria as electronic submissions, provided the exemption is valid.

Guidance for Temporary Residents

The shift toward full electronic filing has simplified many immigration processes — but it can create challenges for applicants without stable online access or those in special categories.

At Visaserve, our Canadian immigration team assists clients with:

  • Determining whether they qualify for a paper-based exemption,
  • Preparing compliant application packages, and
  • Submitting timely renewals or extensions to maintain valid status in Canada.

FAQ – In-Canada Application Exceptions

Q1: Can anyone choose to apply on paper instead of online?
No. Only those who qualify under IRCC’s specific exemptions (disability, system restriction, or exceptional circumstances) may do so.

Q2: Do paper applications take longer to process?
Yes, processing times for paper submissions are often longer because they require manual intake and scanning by IRCC.

Q3: What if I’m unsure whether I qualify for an exemption?
Consult an immigration lawyer or review IRCC’s latest operational updates before submitting. Filing incorrectly could delay your application or cause it to be returned.

Contact Information

If you or your family members have any questions about how immigration and nationality laws in the Canada  may affect you, or if you want to access additional information about immigration and nationality laws You can reach us by emailing info@visaserve.ca or by calling us at  +1 905-203-2266  .We also invite you to visit our website at www.visaserve.ca/contact for more information.