Only three groups may charge you for advice or representation on a Canadian immigration application: lawyers (and Quebec notaries) in good standing with a law society, other law society members such as licensed paralegals, and members in good standing of the College of Immigration and Citizenship Consultants (CICC). That rule is in section 91 of the Immigration and Refugee Protection Act (IRPA). Anyone else who takes a fee for this work commits an offence, and the risk to your application falls on you, because you sign the forms.
This article explains who is authorized, how to check in a few minutes, what “ghost consultant” arrangements look like, and which advertising claims should make you walk away. It draws on the current text of IRPA, the Immigration and Refugee Protection Regulations and the Citizenship Act, and on a May 2026 LPEN ethics session on the CICC Code of Professional Conduct led by a regulated consultant.
Key Takeaways
- Under IRPA s. 91, only lawyers and Quebec notaries, other law society members (including paralegals), and CICC members in good standing may advise or represent for a fee. The Citizenship Act s. 21.1 has the same rule for citizenship files.
- Unauthorized paid representation is an offence punishable by a fine of up to $200,000 and up to two years in prison on indictment.
- Your application must name any paid representative or paid adviser, with their membership number. Hiding a “ghost” adviser is an inaccurate declaration.
- A licensed consultant’s advertising must show their registered name and the address of the CICC public register, and may not guarantee success or imply a link to government.
- Check the public register yourself before paying anything. It takes minutes.
Who is allowed to charge for immigration advice
Section 91(1) of IRPA says no person shall “knowingly, directly or indirectly, represent or advise a person for consideration”, or offer to do so, in connection with an application, proceeding or Express Entry expression of interest. “For consideration” means for payment or any other benefit.
Section 91(2) then lists who is exempt:
- Lawyers who are members in good standing of a provincial law society, and notaries in good standing with the Chambre des notaires du Québec.
- Other members in good standing of a law society, including paralegals. Provincial rules may limit what a paralegal can do, so check the scope in your province.
- Members in good standing of the CICC, the regulator of immigration and citizenship consultants since November 2021.
Two narrower exceptions exist. A law student may help under the supervision of a lawyer who is acting on the file (s. 91(3)). An entity operating under an agreement with the Government of Canada, such as a contracted visa application centre, may provide the services that agreement covers (s. 91(4)).
The rule is about payment. A relative or friend who helps you fill in a form for free is not breaking section 91. The moment money or another benefit changes hands, they are.
The penalties
Under s. 91(9), contravening section 91 is an offence punishable on indictment by a fine of up to $200,000, up to two years’ imprisonment, or both, and on summary conviction by up to $40,000, six months, or both. Section 21.1 of the Citizenship Act makes the same activity an offence for citizenship applications and uses the same list of authorized people.
How to verify a representative in five minutes
- Get the full legal name and the membership number. An authorized representative will give you both without hesitation. They have to put them on your forms anyway.
- Search the public register. For a lawyer or paralegal in Ontario, use the Law Society of Ontario’s Lawyer and Paralegal Directory; other provinces have their own law society directories. For a consultant, use the CICC’s online public register.
- Confirm the status is active and in good standing. Suspended, revoked or non-practising members are not authorized.
- Check the scope. The CICC issues different classes of licence. For example, the RISIA licence is designed for international student matters. The CICC Code requires a licensee to refuse work beyond the scope of their licence (s. 19(1)).
- Check that the person you are dealing with is the member. An agency with one licensed name on the website and unlicensed staff doing the advising is a common pattern. Ask who will actually prepare and sign off on your file.
What your application must disclose
The regulations make representation visible to Immigration, Refugees and Citizenship Canada (IRCC). Under section 10(2) of the Immigration and Refugee Protection Regulations, an application must include:
- the contact details of anyone representing you (para. (c.1));
- if that person is paid and is a lawyer, law society member or CICC member, the name of their regulatory body and their membership number (para. (c.2)); and
- the same details for anyone who advised you for payment, even if they are not your representative of record (para. (c.3)).
In practice, representation is recorded on the IMM 5476 Use of a Representative form, which is also what lets a representative link to your online application. Our guide to IRCC portals covers how that linking works.
Why “ghost consultants” put you at risk
A ghost consultant is someone who charges you to prepare or advise on your application but does not appear on it. Sometimes they are unlicensed. Sometimes they are licensed but prefer to stay off the file. Either way:
- The declaration you sign is inaccurate if a paid adviser is left out, because the regulations require their disclosure.
- Their mistakes become yours. IRPA s. 40(1)(a) makes a person inadmissible for “directly or indirectly misrepresenting or withholding material facts”. Blaming an undisclosed preparer does not remove the finding, and a misrepresentation finding carries a five-year bar. See our misrepresentation guide.
- You have no regulator to complain to. An unlicensed person owes you none of the professional duties described below.
Advertising red flags
The CICC Code of Professional Conduct, in force since June 10, 2022, sets marketing rules for licensed consultants. Lawyers have parallel rules under their law society’s code. Under s. 44 of the CICC Code, a consultant’s advertising must:
- display their name, as registered with the College, prominently at or near the beginning;
- in any written advertisement, include the internet address of the College’s public register of licensees; and
- be in the public interest and consistent with a high standard of professionalism.
It must not:
- make false, misleading or inaccurate representations;
- guarantee the success of an application, expression of interest or proceeding; or
- imply that the licensee has a relationship with the federal or a provincial government.
Client testimonials may be used only if actually given by a client, true and accurate, and approved in writing by that client (s. 45). The College’s name and logo may be used only by licensees in good standing (s. 46).
So, as a rule of thumb: an advertisement promising approval, claiming “inside” contacts at IRCC, showing a government-style crest, or giving no registered name or register link is a reason to stop and verify before going further.
What an authorized representative owes you
Knowing the standard helps you recognise when it is not being met. Under the CICC Code:
- Honest advice, even when unwelcome (s. 6). The LPEN session used the example of a former student whose post-graduation work permit was about to expire and who asked about a “dummy” work permit. The honest answer may be that the plan is not viable or not lawful.
- Competence, or a referral (ss. 19 and 20). A representative who lacks the competence for your matter must decline or, with your consent, bring in another authorized person, with the arrangement and fees disclosed in writing.
- Deadlines and communication (s. 22). They must meet deadlines, keep you informed in writing, tell you when something has been submitted or received for you, and give you copies on request.
If you are not getting copies of what was filed in your name, ask for them. You are entitled to see your own application. Our checklist for a first immigration consultation lists what to bring and what to ask.
If you already used an unauthorized or ineffective representative
- Get the full file. Request everything submitted in your name, including portal submissions and correspondence.
- Have it reviewed by an authorized representative for inaccuracies that may need to be corrected before IRCC finds them.
- Consider a complaint to the CICC or the relevant law society, depending on who acted.
- Know your options on a refusal. Where poor representation affected the outcome, the Federal Court has a specific test for prior counsel incompetence.
For a broader checklist on choosing counsel, see our guide to choosing an immigration lawyer.
Frequently Asked Questions
Can a travel agent or education agent charge me to prepare my visa application?
Not unless they are a lawyer, a law society member, or a CICC member in good standing, or they act under an agreement with the Government of Canada. Charging a fee for this advice without authorization is an offence under IRPA s. 91.
Is it legal for a friend or relative to help with my application?
Yes, if they are not paid or otherwise rewarded. Section 91 applies only to representation or advice “for consideration”. An unpaid helper who is your representative should still be named on the IMM 5476 form.
How do I check whether an immigration consultant is licensed?
Search the CICC’s online public register by name and confirm the licence is active. For a lawyer or paralegal in Ontario, search the Law Society of Ontario’s directory. Match the name and membership number to what appears on your forms.
Does a licensed representative guarantee approval?
No. The CICC Code prohibits consultants from guaranteeing the success of an application, and law societies impose similar limits on lawyers. A promise of approval is a warning sign.
What happens if I do not disclose a paid adviser on my application?
The regulations require it, so the declaration would be inaccurate. If the undisclosed adviser introduced false information, you remain responsible under IRPA s. 40, which can lead to a five-year inadmissibility.
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Disclaimer: This article is for general information only and is not legal advice. Immigration law and IRCC/ESDC policy change frequently, and every case turns on its own facts. Reading this article does not create a lawyer–client relationship. Obtain advice tailored to your situation before you act.
Talk to a Canadian immigration lawyer. BridgePoint Law advises individuals and businesses across Canada — and on Canada–US–China cross-border matters — on immigration applications, file reviews and representation problems. Book a consultation with our team in Toronto and Kingston. We work in English, Mandarin, and Cantonese.