Record
5.19(1) FFD erccepcress Semone conse
From:
Sent: [requester]
To: Immigration Representatives / Représentants immigration (IRCC) <[requester email]>; Immigration Representatives / Représentants immigration (IRCC)
<[IRCC Immigration Representatives mailbox]>
Subject: [requester]
CAUTION: This email originated from outside the Government of [requester] not click on links or open attachments
unless you recognize the sender and know the content is safe.
ATTENTION: Ce courrie! provient de I'extérieur du gouvernement du [requester] cliquez pas sur les liens et n‘ouvrez pas
les pieces jointes sauf si vous reconnaissez 'expéditeur et sachez que le contenu est sir.
Dear [requester] mailbox,
My Party ID is and my RCIC number is
lam seeking clarification regarding the IRCC requirements for submitting Use of Representative forms via
webforms, particularly regarding the necessity of wet ink signatures. The current instructions available online
(hitos:/Ammw.canada,ca/en/immigration-refugees-citizenship/services/application/application-forms-
quides/imm5476.him)) are confusing, non-specific, and appear to contain grammatical errors, and incomplete
sentences.
Previously, |have successfully utilized digitally signed representative forms, which offer enhanced security,
efficiency, and environmental advantages over wet ink signatures. Recently, however, | received several
responses requiring a wet ink signature without clearly explaining why this is necessary.
Security:
Wet ink signatures pose substantial security risks as they are easily replicated or misused, potentially exposing
representatives to identity fraud. This is an issue Ive already experienced professionally. Digital signatures
provide significantly greater security, incorporating authentication measures, secure PDFs, and domain-linked
verification with two-factor authentication.
Accessibility and Environmental Impact:
Mandating wet ink signatures requires unnecessary printing and scanning, resulting in wasted resources,
increased costs, and inefficiency. This requirement seems contradictory to IRCC’s broader promotion of
encouraging digital submission and environmental responsibilty
Inconsistency and Unclear Guidance:
The instructions provided on the IRCC website lack clarity and consistency. The delineation of when digital
signatures are accepted (e.g., application submissions via portals) and when wet ink signatures are mandated it
appears in some cases (¢.g., webform submissions) is ambiguous and unexplained.
Given these concerns, and the possibility that ambiguous and inexplicable procedural hurdles may prevent clear
and effective communication with IRCC officers, especially when time of the essence which could prejudice
applicants, could you please clarify:
1. 1. Where | can find explicit and definitive guidance regarding circumstances in which wet ink signatures are
strictly necessary?
02262
2, 2. Whether an Access to Information request would provide insight into the rationale behind this policy?
3, 3. IRCC accommodates applicants who cannot submit electronically by allowing mail submissions;
similarly, can accommodations be made for applicants and representatives who prioritize digital
submissions, maintaining paper-free offices? Specifically, is there room to consistently accept digital
signatures, considering their proven advantages in security, convenience, and sustainability and
acceptability on some submissions but not on other types of submissions?
Thank you very much for addressing these concerns. | appreciate your clarification and guidance.
[NAME REDACTED]
[requester]