Adoption — substantial-connection limit (s.5.1(4), post-C-3)

CA-ADP-02 is the first-generation substantial-connection LIMIT on the direct citizenship grant for adopted persons, introduced by Bill C-3 (S.C. 2025, c. 5, s.4(1)) and operative for adoptions on or after 2025-12-15. It is the adoption parallel to the descent first-generation limit (CA-DSC-02): the direct s.5.1 grant (route CA-ADP-01) is UNAVAILABLE where the adoptive parent who is a Canadian citizen was themselves a citizen by descent or otherwise born/naturalized abroad AND no adoptive-parent citizen was physically present in Canada for at least 1,095 days before the adoption (Citizenship Act s.5.1(4)). The route is therefore principally a GATING / disqualification rule rather than an independent grant pathway: where the 1,095-day connection is not met and no exception applies, the family cannot use the direct citizenship grant and must instead pursue the immigration/sponsorship (PR-then-grant) route. A Crown-service carve-out at s.5.1(5) disapplies the limit where the relevant parent or grandparent served abroad with the Canadian Armed Forces, the federal public administration, or a provincial public service. As of 2026-06-01 C-3 is IN FORCE (Order in Council SI/2025-129), so s.5.1(4) is live law, not pending.

Where the direct grant remains available (the limit does not apply or an exception is met), the s.5.1 application uses the citizenship-grant fee schedule: an adopted MINOR (under 18) pays CAD 100.00 (minor-grant processing fee, no Right of Citizenship Fee), and an adopted person processed as an adult pays the adult total of CAD 653.00 (CAD 530.00 processing plus the CAD 123.00 Right of Citizenship Fee, the RCF having risen to CAD 123.00 effective 2026-03-31), per the IRCC fee list (date-modified 2026-04-30). Where the s.5.1(4) limit BARS the direct grant and the family must use the immigration/sponsorship route, the applicable fees are the permanent-residence family-reunification fees, which increased 2026-04-30 — for example the sponsorship fee to CAD 90.00, the sponsored principal applicant to CAD 570.00, and the Right of Permanent Residence Fee (RPRF) to CAD 600.00 — generally a higher fee burden than the direct grant, in addition to a mandatory medical exam. There is no investment-based or expedited-purchase pathway and no fee that buys around the substantial-connection requirement. Fees index periodically under the Service Fees Act, so each figure should be reconfirmed against the live IRCC fee list at the time of application.

The operative provision is Citizenship Act, R.S.C. 1985, c. C-29, s.5.1(4), as REPLACED by An Act to amend the Citizenship Act (2025), S.C. 2025, c. 5, s.4(1). Section 5.1(4) bars a grant under s.5.1(1), (2) or (3) for a person adopted on or after the day on which S.C. 2025, c. 5 came into force (2025-12-15, fixed by Order in Council SI/2025-129, P.C. 2025-928, dated 2025-12-11, under s.7 of that Act) where the adoptive parent who is a citizen was a citizen by descent or by a grant abroad AND no adoptive-parent citizen was physically present in Canada for at least 1,095 days before the adoption. This 1,095-day substantial-connection test mirrors the descent test at s.3(3) (also replaced by S.C. 2025, c. 5 s.1(8)). The Crown-service exception is at s.5.1(5), parallel to the descent Crown-service carve-out at s.3(5); a death-of-parent rescue tied to coming-into-force is at s.5.1(6); and the deeming/grant-effect for adoptees granted under s.5.1 is at s.5.2. Adoption-evidence rules were adjusted by SOR/2025-278 ('Regulations Amending the Citizenship Regulations, No. 2 (2025)'). The predecessor Bill C-71 (44th Parliament) lapsed and is NOT operative.