Obsessing over "Primary" vs. "Secondary" evidence as an IRCC preference hierarchy and a reason not to submit other evidence is counterproductive. IRCC will review all relevant evidence.
It's the amount of review required that you want to limit.
We have all spent a lot of time chatting about "primary" vs. "secondary" records to substantiate a claim for citizenship by descent under Bill C-3. It often comes up when people ask the question of whether a particular historical document might be acceptable to IRCC adjudicators.
I've been doing some research to try to figure out why we default to using these terms when they are not used in any binding policy guidance. The best source I have found, which is not official policy, is the slides that were presented to the Association of Canadian Archivists in August of 2026. You can find the slides here on their website.
Per the slides, the answer to this question of whether a particular document will be considered is always this: "Officers must assess all relevant evidence provided by the applicant when assessing an application."
So why obsess over this "primary" vs. "secondary" distinction?
Lawyers will sometimes talk about "primary sources of law" vs. "secondary sources of law." They generally mean that one is a binding governmental source—like a constitution, a statute, a regulation, or a directly applicable case—and the other is a persuasive one—like a scholarly treatise, a dictionary, or a law review article.
The same often goes with evidence submitted to IRCC in complex citizenship cases.
The best way to think about "primary" evidence is probably through a similar lens. Consider the "primary" list in the slides as evidence that a government source that has the authority to decide that a fact has been established as a matter of law has created a document that serves as evidence on which any other governmental agency can rely. It's likely even binding on IRCC.
"Secondary" evidence can be almost anything else from an original or archival custodial authority (church registers, censuses, military records), as long as it's relevant. An officer just has to undertake actual fact-finding under the "balance of probabilities" standard.
Here is the IRCC’s own evidentiary standard: “balance of probabilities – refers to circumstances where the existence of a fact is more likely than its non-existence, and that the issue to be determined is not only possible, but probable, rather than improbable”.
With "primary" evidence, satisfying that balance of probabilities is straightforward because the fact is effectively already established as a matter of law. IRCC only needs to verify the document is genuine; absent contradictory evidence, they don't look behind an official birth certificate to re-litigate where someone was born or to whom.
With so-called "secondary" evidence, the officer can't rely on a legal presumption of validity. They have to evaluate the record's source and weigh whether the cumulative evidence on the record is sufficient to prove that people were born where, when, and to whom the evidence says they were.
If you think about it, in using this distinction, IRCC is primarily interested in not making a decision that is counter to what some other governmental body has already established (in addition to making their own lives much easier).
So in considering what evidence to submit, consider that you need to prove that:
- There probably isn't a "primary" governmental record to help facilitate IRCC's job, putting the agency on notice that they have to go into factual-review mode;
- The documentation you did submit is probably true and accurate; and
- There is sufficient cumulative evidence to prove that the person in question was probably born where, when, and to whom they need to have been to substantiate the citizenship claim.
So, if you don’t have a decisive government document, say why with a few documents and then submit that death certificate alongside that 1850 United States Census and maybe an obituary if that's all you have. Cite to an official agency/archive or original source whenever you can. Try to back up who the informant or respondent likely was and why they are probably qualified to offer that evidence. You don't need to overwhelm the officer, but you should prepare for them to ask questions about what you submitted and perhaps to offer more.
tl;dr: IRCC weighs all relevant evidence. Primary evidence is official documentation that proves a fact quickly. Secondary evidence is the rest that IRCC must actually examine to determine if a fact is more likely than not true.
Edit: Incorporated requested clarification in the closing paragraph about submitting evidence that a decisive government record doesn’t exist.