IRCC Minister Transition Binder 2025-05

Proactive Disclosure

Corporate Secretariat
May 2025

Overview

Introduction

What is Proactive Disclosure?
Summary of Proactive Disclosure Legislative Requirements

Proactive Disclosure Requirements Applicable to IRCC

Briefing Materials
Travel and Hospitality Expenses
Contracts over $10,000
Grants & Contributions over $25,000
Reclassification of Positions
Reports Tabled in Parliament
Ministers’ Offices Expenses

What is Proactive Disclosure?

Purpose and Legislation:

As part of the Government of Canada’s commitment to enhance transparency and accountability, Part 2 of the Access to Information Act (the ATI Act), since the coming into force of Bill C-58 (amendments to Part 2 of the Act adopted in 2019), requires all federal departments, including Immigration, Refugees and Citizenship Canada (IRCC), to proactively disclose specific types of information within their respective timeframes.

Publications:

• Ministers and government entities must publish the following to open.canada.ca, using the templates provided on the Open Government Portal:
  • titles and reference numbers of memoranda
  • Question Period notes
  • travel expenses
  • hospitality expenses
  • contracts over $10,000
  • grants and contributions over $25,000
  • reclassification of positions
• For proactive publications that do not have a template, such as reports tabled in Parliament, briefing materials for new ministers and deputy heads, and briefing materials for Parliamentary Committee appearances, institutions can publish to open.canada.ca as an “Open Information” resource or publish to their institutional page and create a metadata record on open.canada.ca. This ensures that all proactive publications are searchable on open.canada.ca.
• Publications must meet official language and accessibility standards as per the government’s Policy on Communications and Federal Identity.

Accountability and Compliance:

• Starting in the 2022-2023 fiscal year, the Treasury Board Secretariat added a requirement pertaining to proactive disclosure to the Annual Report on the Administration of the Access to Information Act (report prescribed by s. 94 of the Act).
• This annual report is for the purpose of federal institutions to account for their administration of the Act, including their successes and challenges.
• This report must be tabled in each House of Parliament on any of the first 15 days on which that house is sitting after September 1 of the year on which the report is prepared and published on the IRCC website within 30 days after the report was tabled.

Summary of Proactive Disclosure Legislative Requirements

Briefing Materials

Types of Briefing Materials Being Proactively Disclosed:

• Titles and reference numbers of memoranda prepared by a government institution for the Minister and for a deputy head or equivalent, that is received by their office (within 30 days after the end of the month received)
• Packages of briefing materials prepared for the Minister’s and or a deputy head or equivalent’s appearance before a committee of Parliament (within 120 days after appearance)
• Packages of briefing materials prepared by a government institution for new or incoming ministers and for new or incoming deputy heads or equivalent (within 120 days after appointment)
• Packages of question period notes prepared by a government institution for the Minister and in use on the last sitting day of the House of Commons in June and December (within 30 days after last sitting day of the House of Common in June and December)

IRCC Approval, Notification and Publication Process:

• Proactive Disclosure Unit, Corporate Secretariat, is responsible for collecting required information/material in a timely manner, requesting review for redactions by relevant IRCC groups, including review by Access and Privacy Management Branch (APMB), Communications and Legal teams, and obtaining necessary approvals (up to Assistant Deputy Minister level).
• When the above is complete, a memorandum to the Minister for information is prepared and routed to the Deputy Minister’s Office (DMO) via email and WebCIMS, at least 8-10 business days in advance of the legislated publication date.
• Once the Deputy Minister approves, the memorandum is sent to Minister’s Office (MINO) by DMO advisors for red flags check, at least 4-5 business days prior to legislated publication date.
• Should there be anything flagged by DMO or MINO, PDU will address that.
• Final, DMO-approved and MINO-reviewed version of material is prepared by PDU for proactive publication to reflect redactions, if any, and published on the Open Government Portal by PDU employees (memoranda titles, Question Period notes) or Comms Web team (Committee appearance briefing materials, transition binder briefing materials).

Exemptions and Exclusions under the ATI Act:

Applicable exemptions and exclusions are listed in sections 13–26 (exemptions) as well as sections 68 and 69 (exclusions) of the ATI Act.

Travel and Hospitality Expenses

Types of Information Being Proactively Disclosed and the Timeframe:

• IRCC provides monthly information on the travel and hospitality expenses incurred by the Minister, Parliamentary Secretary, and exempt staff, as well as by senior-level employees at the Deputy Minister, Associate Deputy Minister, Senior Assistant Deputy Minister, and Assistant Deputy Minister levels.
• The Access to Information and Privacy Act states that departments are required to disclose information within 30 days after the end of the month in which the expenses were reimbursed.

IRCC Approval and Notification Process:

• Once all related travel and hospitality expenses are reimbursed for the month, Finance provides a copy of the proactive disclosure information in a report format to the appropriate executive office (including MINO, if applicable, for Minister’s office expenses, through the attestation form process).
• The senior executive must then sign an attestation form, confirming their responsibility for the accuracy and integrity of the information. They also have the option to request modifications to the travel purpose if necessary.
• A memorandum for information, including Communications implications, is sent each month to the Deputy Minister and the Associate Deputy Minister on the Department’s proactive disclosure of travel and hospitality expenses.
• Finally, monthly information on the travel and hospitality expenses is disclosed on the Open Government website, in accordance with the Access to Information and Privacy Act.

Exemptions and Exclusions under the ATI Act:

• Applicable exemptions and exclusions are listed in the sections 13–26 (exemptions) of the ATI Act.

Contracts over $10,000

Types of Information Being Proactively Disclosed and the Timeframe:

• The proactive publication discloses information on contracts valued over $10,000, including amendments that either increase or decrease the contract value by more than $10,000.
• Quarterly proactive publication of contract data, including both positive and negative amendments over $10,000, will occur within 30 days after the end of each of the first three quarters of the fiscal year (April to June, July to September, and October to December), and within 60 days after the end of the fourth quarter.

IRCC Approval and Notification Process:

• Contract data for amounts over $10,000 is extracted from SAP on a quarterly basis.
• The data is validated for accuracy by the Procurement and Contract Management Team and approved by the Senior Designated Official, Procurement (DG, Financial Operations, Procurement and Deputy Chief Financial Officer).
• The report, along with a memorandum and input from People and Communications Sector, is sent quarterly for CFO approval and forwarded to the DM and DMA for information.
• The final report is then uploaded to the Open Government website within the required 30–60 days after the end of each fiscal year.

Exemptions and Exclusions under the ATI Act:

• Information related to national security can be exempt from proactive disclosure of contracts.
• Information pertaining to memoranda of understanding and service level agreements with other level of government and foreign governments, as well as agreements between federal departments or Crown corporations, are excluded.

Grants & Contributions over $25,000

Types of information being proactively disclosed and the timeframe: On a quarterly basis, new and amended grants and contributions agreements signed by the Department during the previous quarter are disclosed. The information disclosed includes the name of the recipient, agreement title, program, agreement value, project start and end dates, location, brief project description, expected results, and the date when IRCC signed the agreement.

IRCC approval and notification process: One month after the end of each quarter, the leads extract a list of new and amended Grants & Contributions that were signed during the previous quarter from the Grants and Contributions System (GCS). This report is sent to the Research and Data Branch that publishes the information on the Open Government Portal (open.canada.ca). Notification is not provided to the Minister’s Office.

Note that GCS only contains information about agreements funded under the Settlement, Resettlement Assistance (not including income support to individuals), and Francophone Immigration Support Programs. Each branch that manages Grants & Contributions programs is responsible for its own proactive disclosure process of this.

Exemptions and Exclusions under the Access to Information Act: Grants and Contributions data is not redacted before it is disclosed. Only classified information can be excluded.

Reclassification of Positions

Types of Information Being Proactively Disclosed and the Timeframe:

On February 25, 2004, the Government of Canada mandated the publication of information regarding the reclassification of occupied positions within the Public Service. When assessing changes to a position that may result in reclassification, management must ensure the principles of responsible, effective, and efficient allocation of public funds. Additionally, it is essential  to ensure transparency and fairness during the classification evaluation process.

Within 30 days following the end of the quarter in which a reclassification of an occupied position occurs, the head of a government institution – whether a department listed in Schedule I to the Financial Administration Act or a portion of the Core Public Administration listed in Schedule IV to that Act – must ensure the publication of the following information is in electronic form.

• the organizational unit in question;
•  the position number and title of the reclassified position;
• the previous classification and the new classification;
• the purpose of the reclassification;
•  the effective date of the reclassification; and
• any other information that, in accordance with Treasury Board policies, must be published.

IRCC Approval and Notification Process:

The data outlined above is extracted monthly from our PeopleSoft system. The Corporate unit of the Organizational Design and Classification Division then manually uploads this information to the Open Government Registry on a quarterly basis, as per requirement. Once published, the information becomes publicly accessible on the Proactive Disclosure website.

Exemptions and Exclusions under the ATI Act: N/A (There is no requirement of redaction or excluded information to be performed as all the information extracted is published on the viewable site.)

Reports Tabled in Parliament

IRCC process:

• All the reports are transmitted to DMO and MINO via a memorandum and require the Minister’s approval.
• Upon approval IRCC teams upload all the reports to IRCC’s page of Canada.ca and can be found here.

Ministers’ Offices Expenses

*Note: This consolidated report is currently published by TBS on behalf of all institutions

Types Of Information Being Proactively Disclosed and the Timeframe:

A report on ministers’ office expenditures, categorized by type of expenditures, is prepared and sent to the Receiver General (RG) annually in May by the Chief Financial Officer Sector for each fiscal year. This report is published annually in Volume III of the Public Accounts of Canada and made publicly available by the Treasury Board Secretariat on the Open Government website, within 120 days after the fiscal year-end.

The report includes only the total expenditures, broken down by type, for each minister. For an example, please see the linked Open Government Expenditures of Ministers' Offices page.

IRCC Process:

The report details expenditures charged to the Minister’s budget in accordance with the Policies for Ministers' Offices,covering operating costs incurred by parliamentary secretaries, exempt staff, and departmental staff. It includes only direct operating expenditures related to official government departmental business and excludes civilian termination benefits and statutory expenditures (e.g., Minister’s salary and motor vehicle allowance, employer contributions to superannuation, and certain benefit plans). Throughout the year, the Chief Financial Officer Sector reviews the information recorded in the departmental financial system for accuracy. The report is reviewed and approved by the Minister’s Chief of Staff before submission.

Exemptions and Exclusions Under the ATI Act:

According to the Access to Information Act, information disclosed under section 78 is not considered personal information and must be published in accordance with section 80(3).