For an RCIC client file transfer, section 36(3) of the CICC Code requires you to deliver all documents relating to the client’s file to the new representative within 10 business days of the client’s request, even if payments are outstanding. If that is not feasible for reasons beyond your control, tell the client and the new representative and deliver within 30 days. Within 30 days of the agreement ending, you must also return the client’s documents, account for funds, issue a final invoice and refund any excess held in trust.
- When a client asks, deliver all documents relating to the file to the new representative within 10 business days.
- Outstanding payments do not delay the transfer; you can still issue a final invoice.
- If delivery is not feasible for reasons beyond your control, tell both parties and deliver within 30 days.
- Within 30 days of the agreement ending, return documents, account for funds, invoice and refund any trust excess.
- Notify IRCC and any other department that you no longer represent the client, using its procedure.
Clients change representatives. When they do, the Code sets hard deadlines for the outgoing licensee, and unpaid fees do not change them. This guide sets out what the rules require when a service agreement ends early, when you may end one yourself, and a closing checklist your team can follow on every file, whether it is being transferred or simply completed.
Source, checked 5 November 2026: the CICC Code of Professional Conduct (SOR/2022-128), current to 19 October 2026, sections 34 to 37. The checklist at the end is our practical routine, not a College template. Lawyers follow their law society’s rules instead.
What does the CICC Code require when a client file is transferred?
| When | What you must do | Code |
|---|---|---|
| The client asks for the file to go to another representative | Deliver all documents relating to the client’s file to that representative within 10 business days of the request, even if payments are outstanding | s. 36(3) |
| Delivery in 10 business days is not feasible for reasons beyond your control | Tell the client and the other representative about the delay, and deliver within 30 days of the request | s. 36(4) |
| The agreement is terminated before completion | Give the client all information you hold that may be required in connection with the file | s. 36(2)(a) |
| There is a successor representative | Cooperate with them to minimize expense and avoid prejudice to the client | s. 36(2)(b) |
| You are listed as the representative with a federal or provincial department or agency | Give notice that you no longer represent the client, following that department’s procedure, or in writing within 10 days if it has none | s. 36(2)(c) |
| Within 30 days of completion or termination | Return the client’s documents and property, account for all funds received, issue a final invoice and refund any funds held in trust beyond the invoiced amount | s. 36(1) |
Two different clocks run at once: 10 business days for the transfer to the new representative, and 30 calendar days for closing out the engagement. Put both dates on the file the day the request arrives.
Can you hold the file until the client pays?
No. Section 36(3) says you must deliver the documents to the new representative “even if there are payments outstanding.” You can still issue a final invoice for services rendered and disbursements made (s. 36(1)(c)) and pursue it through your normal process, but the transfer cannot wait for payment. Fee disputes often turn into complaints, so handle them through your written procedure; see RCIC complaint handling procedure.
Money held in trust follows the client account rules: account for it and refund any excess within 30 days. See RCIC client account rules.
When can an RCIC end a service agreement?
Sometimes the transfer starts with you. The Code separates the cases where you may end an agreement from those where you must.
- You may terminate (s. 34) only with reasonable notice to the client, for good reason, and only if it will not cause the client serious prejudice. The Code’s examples of good reason are a client who deceived you, failed to give adequate instructions, failed to follow your advice on a significant point, or failed to pay fees or disbursements as agreed.
- You must terminate (s. 35(1)) if the client no longer wants your services; if the client, despite your advice, asks you to act dishonestly, fraudulently or illegally or below the Code’s standards; if continuing would put you in a conflict of interest without the client’s consent under section 15 (see RCIC conflict of interest); or if you lack the competence to continue and do not get help under section 20(1)(b).
- Referral (s. 35(3)). If you end the agreement because of a conflict of interest or a lack of competence, you must, if possible, refer the client to another authorized representative who is competent to provide the services.
Whatever the reason, section 36 then applies. Write the notice, the reason and the date on the file.
How do you tell IRCC that you no longer represent the client?
Section 36(2)(c) requires notice to every department or agency where you are listed as the client’s representative, following its own procedure. For IRCC, that procedure runs through the IMM 5476 Use of a Representative form. If the application is in your account, read how representation changes in the IRCC Authorized Paid Representatives Portal before the new representative tries to link it. If you are listed with a provincial nominee program or another agency, check its procedure too; where none exists, the Code requires written notice within 10 days.
A client file transfer checklist for your team
- Log the request. Record the date and how it arrived, the new representative’s name and contact details, and the two deadlines: 10 business days for delivery, 30 days for close-out.
- Confirm it is the client’s instruction. Get the request in writing from the client, not only from the new representative.
- Check open deadlines. List any IRCC or other deadline in the next 30 days and tell the client and the successor in writing, so nothing falls between offices (s. 36(2)(b)).
- Assemble the file. All documents relating to the file, including forms, submissions, correspondence and anything received by email or messaging.
- Deliver and record it. Send through a secure channel, keep proof of delivery and note the date. If you will miss 10 business days for reasons beyond your control, notify both parties before the deadline.
- Withdraw as representative. Follow IRCC’s procedure and any other department’s, and note the date.
- Close the money. Final invoice, accounting of all funds received and any refund from trust, within 30 days.
- Keep your record. Keep a copy of the file and the closing record as the College’s by-laws require (s. 37).
Section 37 leaves the retention period to the College’s by-laws, which we could not read for this guide, so we do not state a number of years. Confirm it with the College before setting your data retention in ImmiPractice. For keeping files easy to hand over, see how to organize immigration client documents.
What if you are the new representative?
Ask the client for the outgoing licensee’s details and send your own written request with the client’s instruction, so the 10-business-day clock is clear to everyone. Section 36(2)(b) requires the outgoing licensee to cooperate with you, so ask early about open deadlines. Then put your own service agreement and IMM 5476 in place before you act; see manage retainer agreements.
General information about running an immigration practice — not legal advice. Rules change; confirm current requirements with official sources and your regulator.