A Brave New World or A World of Opportunities

Canada’s immigration system is undergoing a fundamental transformation. The use of artificial intelligence (AI), automated tools, and digital triaging is no longer theoretical. It is actively reshaping how applications are processed, prioritized, and decided. These technologies now influence everything from work permit approvals to complex permanent residence decisions.

While IRCC has provided limited transparency about its specific AI tools and decision models, we know that systems such as Chinook and ITAT are being used to streamline officer workflows, flag applications for concern, and, in some cases, generate decision-ready files with minimal human review. This shift raises critical legal and procedural questions—especially when automation replaces meaningful individualized assessment.

Our firm, led by our founder, Zeynab Ziaie Moayyed, is at the forefront of litigation and policy advocacy in this emerging space. We monitor how IRCC is deploying technology, challenge decisions affected by flawed or opaque automation, and work to ensure that fairness, accountability, and legal standards are upheld as technology becomes more deeply embedded in the immigration process.

If your application has been affected by unexplained refusal, procedural shortcuts, or signs of automation, we can help you assess your legal options.

The Tools We Know About 

Since we discovered the use of Chinook in 2021 during repeat litigation in Federal Court, we have worked to uncover more technology-driven tools that are being used to manage and decide immigration applications. The key tools we know about include:

• Chinook, an internal platform designed to streamline officer decision-making by organizing applicant data into simplified spreadsheets, without clear access to file documents and with the ability to automate officer's notes and other aspects of the review process. 
• Identity Trends Analysis Tool (ITAT), used to assess applications against 
• Training tools, used to determine risk level or complexity and assign applications to different streams for processing (including automated approvals). 

The use of these systems marks a clear shift toward high-volume, technology-assisted decision making at IRCC.

The Impact of AI and ADM Tools on Visa Decisions

These digital tools incorporated into the immigration and visa decision-making process are fundamentally altering how decisions are made. While IRCC frames their use as improving efficiency, applicants often experience the downsides: decisions that feel rushed, overly standardized, or lacking in individualized reasoning. Thousands of applicants have turned to the Federal Court in recent years to try to receive individualized attention to their applications that have been summarily refused using these tools. With the increasing use of AI tools to generate reasons to justify decisions, it is becoming harder to determine who made the ultimate decision and how.

How To Tell If Your Application Was Processed With Chinook 

When you receive a refusal letter, there is clear notation that Chinook was used. However, the internal officer's notes (GCMS notes) now include has been involved in a decision—but there are telltale signs. These include decisions issued unusually quickly, refusal letters that rely on boilerplate language, or GCMS notes that are incomplete or missing altogether. In some cases, decisions are issued without any record of the officer weighing your specific evidence—an indicator that a streamlined or automated process may have been used. Through ATIP requests, litigation disclosure, and careful analysis of file records, our firm helps clients uncover whether their application was affected by automation and assess whether there are grounds to challenge the decision.

Explore the Current Uses of AI in Canadian Immigration Decision Making

Judicial Treatment of Chinook & AI Tools in Visa Decisions 

Our firm has led key litigation in Federal Court involving substantive evidence of the working of the Chinook system and the impact that it has on decision making.

There are fundamental challenges that we face in proving the harm caused by these systems and the direct impact that they have on immigration outcomes.  

Mehrara v. Canada (Citizenship and Immigration), 2024 FC 1554

As AI and Automated Decision-Making (ADM) tools become more prevalent in administrative law, including Canadian visa processing, the challenge of contesting decisions influenced by these technologies continues to grow. While previous court rulings have touched on the use of the Chinook tool in visa refusals, no decision has fully explored its inner workings - until now.

In Mehrara , we presented evidence on how Chinook spreadsheets function and how they impact decision-making in study permit applications. The key challenge in Judicial Review cases like this is the lack of transparency. Critical evidence, such as how data is processed, what decision-makers actually see, the role of AI versus human input and identifying what is AI generated vs human generated, is controlled by IRCC. Unfortunately, in this case, we couldn't fully establish how the use of Chinook affected procedural fairness, as vital evidence (e.g. deleted spreadsheets) was inaccessible to us.

This case marks an important step in the ongoing legal analysis of how AI and ADMs influence administrative decisions and the framework we need to govern these technologies. I’ll be writing in more about this case in the coming weeks, but ultimately Justice Battista's decision highlighted the limitations of the available evidence and acknowledged that the issue of AI's role in decision-making is far from resolved:

“[64] However, while I have found the record to be complete for the purposes of reviewing this decision based on the nature of the error, the reasons of the Officer, and the current evidence regarding the function of Chinook, this may not be the case in other judicial reviews of applications processed using processing technology, particularly in applications where risk indicators are present. For this reason, the Respondent’s systematic daily deletion of all material generated by processing technology may not reflect best practice. The growing recognition that the exercise of public power must be justified, as articulated in Vavilov and affirmed in Mason, would be hollow without a basic understanding of how the exercise of that power occurs.”

However, our work in this space continues and we welcome cases where applicants believe the use of technology tools has negatively impacted the outcome of their case.

Tips & Tools To Assist in Preparing Applications in the Age of AI

While the internal workings of the AI traiging and processing tools at IRCC are not disclosed, we closely monitor the Federal Court's treatment of emerging technologies in immigration, and we leverage this knowledge to build stronger, more informed challenges on behalf of our clients. We have distilled our knowledge from working on hundreds of successful applications into Tips & Tools to maximize the chance of success each application. Access our FREE MyVisa Tips & Tools here:

• Preparing complete study permit applications 
• maximizing your chance of success for a visitor visa
• challenging AI based visa refusals