When a Parent or Grandparent Sponsor Falls Short of the Income Requirement: What an IAD Decision Can—and Cannot—Show

Published: July 29, 2025

For the 2025 Parents and Grandparents Program intake, an invited sponsor outside Quebec was required to meet the applicable income threshold for each of the 2022, 2023 and 2024 taxation years. Falling short in even one year is a substantive eligibility problem—not a minor documentary defect.

IRCC began issuing invitations for the 2025 intake on July 28, 2025, drawing from the remaining 2020 interest-to-sponsor pool. The department planned to accept up to 10,000 complete applications. For invited families reviewing their income history, an important distinction is often missed: the rules applied by an immigration officer at the initial application stage are not the same as the discretionary authority available to the Immigration Appeal Division (IAD) after a refusal.

The income requirement at the application stage

For sponsors residing outside Quebec, IRCC assesses whether the sponsor—and a qualifying co-signer, if applicable—met the minimum necessary income for each of the three relevant taxation years. Family size is calculated year by year, and the required amount changes with that family size.

If the evidence shows that the sponsor did not meet the applicable threshold, an officer cannot simply disregard the requirement because the family has compelling circumstances or because the sponsor’s income later improved. An applicant should therefore not submit on the assumption that a sympathetic explanation will replace statutory eligibility.

What Singh illustrates at the appeal stage

In Singh v Canada (Citizenship and Immigration), 2023 CanLII 64876 (CA IRB), the IAD considered an appeal involving a parent-sponsorship refusal where the sponsor had not met the applicable income requirements during the assessed years.

The IAD’s authority on appeal is broader than the authority exercised by the original decision-maker. Under paragraph 67(1)(c) of the Immigration and Refugee Protection Act, the IAD may allow an appeal when, taking all of the circumstances into account—including the best interests of any directly affected child—sufficient humanitarian and compassionate considerations warrant special relief.

In assessing whether special relief was justified, the panel considered the sponsor’s improved financial circumstances, the family’s relationship and separation, the sponsor’s personal circumstances, the likelihood that the parents would require public assistance, and the overall evidence bearing on the purpose and consequences of family reunification.

What the decision does not mean

The decision does not create a general exception to the three-year income requirement. It does not require IRCC to approve an application with an income shortfall, and it does not establish that later earnings will cure every deficiency.

An IAD appeal is a separate legal proceeding following a refusal. Its outcome depends on the evidentiary record and the weight assigned to all relevant circumstances. A sponsor relying on humanitarian and compassionate considerations must present more than a desire for family reunification; the evidence must explain why special relief is warranted in that particular case.

Practical considerations for an invited sponsor

• Calculate family size separately for each relevant taxation year.
• Confirm the income figure IRCC will use from each CRA Notice of Assessment.
• Determine whether a spouse or common-law partner can qualify as a co-signer.
• Identify any prior undertakings or family members who must be included in family size.
• If there is a shortfall, obtain advice before submission about eligibility, the likely refusal risk, and whether any future appeal rights may exist.

Bottom line: an IAD decision granting special relief can be important in a genuinely compelling case, but it should not be treated as a substitute for meeting the PGP income requirement. The strongest application-stage strategy remains an accurate year-by-year assessment before the application is submitted.

Official and legal sources: IRCC — 2025 PGP intake notice; IRCC — PGP income requirements; Immigration and Refugee Protection Act, s. 67; and Singh v Canada (Citizenship and Immigration), 2023 CanLII 64876 (CA IRB).