The record-keeping obligation, in the regulation’s own words
A Regulated Canadian Immigration Consultant is a licensee of the College of Immigration and Citizenship Consultants. Their conduct is governed by the College of Immigration and Citizenship Consultants Code of Professional Conduct Regulations (SOR/2022-128). The record-keeping duty is set out in section 37:
“A licensee must maintain a reliable system of office administration in relation to the immigration or citizenship consulting services that they provide and keep and preserve records in accordance with the by-laws made under the Act.”
Two phrases in that sentence carry the weight a file review turns on: “a reliable system of office administration” and “keep and preserve records.” A review is not satisfied by the outcome of the file alone; it examines whether there is a durable, orderly record that shows what was done, when, and by whom. The obligation attaches to the system, not just the individual document.
What the record is expected to contain
The same regulation is specific about several kinds of record a licensee must keep. It requires a written service agreement, and it requires the licensee to retain a copy of it:
“The licensee must keep a copy of the signed service agreement for their records and provide a copy to the client.”
It also ties record-keeping to communication with the client. A licensee must keep the client informed, in writing, about the status of the case — including a record of what was submitted or received on the client’s behalf:
“The licensee must provide timely information to the client in writing concerning the status of their case, including by (a) notifying the client when a document or information has been submitted or received on the client’s behalf; and (b) on request, providing a copy of the documents that were submitted or received.”
Read together, sections 22, 24 and 37 describe a file that a reviewer can reconstruct: the agreement that scoped the work, the documents that moved in and out, the status the client was told about, and a preserved record of it all. When a complaint or a review asks “what happened on this file, and when”, the answer is expected to live in that record rather than in memory.
Why the record protects the licensee, not just the client
The application itself sets a high bar for completeness and accuracy. Under the Immigration and Refugee Protection Regulations, subsection 10(1) requires that an application be made in writing, signed, and include all required information:
“an application under these Regulations shall (a) be made in writing using the form, if any, provided by the Department”, “(b) be signed by the applicant”, and “(c) include all information and documents required by these Regulations, as well as any other evidence required by the Act.”
Separately, subsection 10(2) requires the application to include a declaration that the information provided is complete and accurate:
“The application shall, unless otherwise provided by these Regulations, … (d) include a declaration that the information provided is complete and accurate.”
When a decision is questioned after the fact — a request for more information, an allegation that something was misstated, or a client who disputes what they were told — the record of the services provided is what establishes what actually occurred. A file that can show, with dates and an actor attached to each step, when a document was received, when analysis was run, when the client was updated, and when the package was assembled, is a file whose licensee can answer the review’s questions from the record. A file that cannot is left reconstructing events from memory. That is the practical difference a complete activity record makes: it is the licensee’s own account of the work, preserved as the work happened.
The kind of record-keeping a file review looks for
A reviewer is not looking for a narrative essay. It is looking for an orderly, attributable trail: each material step on the file, with a timestamp and an indication of who took it. The regulation calls this “a reliable system of office administration” and requires the licensee to “keep and preserve” it. The gap most firms have is not the absence of the work — it is that the work leaves no durable trace beyond the final documents, so months later there is no way to show the sequence.
The mechanism Navisa uses to help maintain it
Navisa records case activity as a structured, actor-attributed event on the file. Every material step writes an entry to a case activity record: a fixed activity type, a human-readable title, a timestamp, and an actor — whether the step was taken by the system, by a consultant, or by the client. The set of activity types is not free text; it is a defined list, so the record is consistent from file to file. The events currently captured include, among others:
- a case being created, and client intake being completed;
- a document being uploaded to the file;
- eligibility, consistency and compliance analysis completing (or failing);
- a reference-letter or NOC match being reviewed or reconciled;
- a form or letter of explanation being approved;
- the evidence package being built;
- a status change, a retainer being signed or paid, and a senior-counsel review completing;
- post-submission events — an IRCC letter being detected and confirmed, a client update being sent, a PFL response being approved, and the outcome being logged;
- changes to who is responsible for the file — the case owner changing, and collaborators being added or removed.
Each of those is written with its actor attached, so the record shows not only that a step happened but who was accountable for it. Because the events accumulate as the work is done, the file carries its own chronology rather than depending on someone reconstructing it later. This is the kind of trail a file review looks for: a preserved, attributable record of the services provided.
To be precise about what this is and is not: it is record-keeping readiness. Navisa maintains the activity record; the licensee remains responsible for their obligations under the Code of Professional Conduct, including the service agreement, the written client updates, and the preservation of records in accordance with the College’s by-laws. Navisa does not file or submit anything on its own — a consultant reviews and approves the work — and it does not replace the judgment of a licensed immigration professional. The record is there to support the professional, not to stand in for them.
Read the rules for yourself
The full Code of Professional Conduct Regulations, including every section quoted above, is published on the Government of Canada’s consolidated regulations site. We link the full-text version so the sections around record-keeping can be read in context rather than in isolation.