Must-Read for Canadian Immigration Applicants Who Have Lived in China: Controversy Over the Formats of China Notarial Certificate of No Criminal Record

Two Formats and the Current Confusion

Since June 2024, there have been continuous reports on Chinese social media that China Notarial Certificates of No Criminal Record (hereinafter, “Notarial CNCR”) are rejected by Canadian immigration authorities due to incorrect formats. The disputed formats are the two types shown below. The format on the left consists of three pages. The other format on the right has more pages, including a photocopy of the CNCR issued by local police and its English translation. (Typically, when applying for a Notarial CNCR, applicants must submit a CNCR issued by the public security authorities, hereinafter referred to as the Police CNCR, as opposed to the Notarial CNCR.) The two formats of Notarial CNCRs are known by different names among Chinese applicants and officials, with the following pairs being commonly used.

Previously, applicants for Canadian immigration invariably used Substantive Notarial CNCRs, the format with fewer pages. However, over the past year, rumors circulating on social media suggested that the substantive version might be rejected by the Canadian immigration authorities. Following these rumors, some applicants switched to the 4-page non-substantive Notarial CNCR, yet a portion of these were still rejected. Subsequently, some immigration agencies and notary offices began advising applicants to obtain both formats simultaneously.

Based on actual cases we have encountered, the following reasons for rejection have been observed:

• Submission of a non-substantive Notarial CNCR resulted in rejection with a request for a substantive Notarial CNCR. (Note: This scenario directly contradicts the rumors. ）
• Submission of a non-substantive Notarial CNCR and the attached Police CNCR does not come with any QR code. The Canadian immigration rejected it and requested a non-substantive Notarial CNCR containing a Police CNCR with a QR code.
• Submission of both a substantive Notarial CNCR and a Police CNCR resulted in rejection, with a request for a non-substantive Notarial CNCR.

Until now, we have not encountered any cases where rejection follows the submission of a substantive Notarial CNCR alone. In the aforementioned case where a substantive Notarial CNCR was rejected, it is worth pointing out that the applicant also submitted a police clearance certificate at the same time. We will continue monitoring this matter. If you experience a rejection after submitting only a substantive Notarial CNCR, please contact us. We would greatly appreciate it and will promptly update this article.

Analysis of the Root Cause of the Confusion

China implemented the Provisions on the Handling of Criminal Record Checks by Public Security Organs (hereinafter, the “Provisions”) effective December 31, 2021. This is the first time that China’s Ministry of Public Security has issued nationwide regulations governing the issuance of Police CNCRs. We believe that the recent rejections by Canadian immigration concerning substantive criminal record certificates are directly linked to the introduction of these Provisions.

Although the Provisions were rolled out way earlier than the first occurrence of Canadian immigration’s rejection, they appear to be relevant if you look at the timing. The Provisions were issued during the COVID-19 pandemic. The Chinese government declared the end of the pandemic in December 2022. That means by the time a large number of Police CNCRs were issued under the Provisions, it was likely around early 2023. Further considering the potential lag between policy implementation and Canadian immigration’s actions, we therefore speculate that the rejections observed in 2024 are connected to the introduction of the Provisions.

There is also direct evidence that links the rejections to the Provisions. In one of the rejection cases mentioned earlier in this article, Canadian immigration specifically requested the applicant to provide a Police CNCR with a QR code. This requirement directly points to the Provisions, as they provide a Police CNCR template that includes a QR code. Prior to the issuance of the Provisions, we had never seen any Police CNCR bearing QR codes.

IMPORTANT UPDATE (May 28, 2026): IRCC has updated its instructions regarding China CNCRs to clarify that CNCRs without QR codes are acceptable.

Disagreement with Canadian Immigration

As mentioned earlier, some Canadian immigration officers have requested applicants to provide Police CNCR with QR codes, which is a requirement that is clearly unreasonable. Although the template provided in the Provisions reserves space for a QR code, not all local public security authorities possess the necessary technical capabilities. When using the “Public Security All-In-One Online Service” app to scan the QR code on a Police CNCR, it will even prompt that “This feature is currently only available in some regions” (as shown below). We have also seen many Police CNCRs issued by county-level public security authorities that lack QR codes.

As mentioned in our previous article (Substantive, Non-Substantive, or Procedural – Understanding Categories of Notarization in China), China’s legal system is based on the civil law system. From its inception, China’s notary system has adhered to substantive notarization. Most countries in the world accept China’s substantive Notarial CNCRs, including Canada’s allies such as the United States, the United Kingdom, New Zealand, and Australia. Therefore, we think Canada’s refusal to accept substantive Notarial CNCRs is not advisable.

Current Recommendations

Many Canadian immigration applicants, upon learning of the controversy, struggle with choosing the format for their Chinese Notarial CNCRs. Over the past year, we have assisted approximately one hundred Canadian immigration applicants in obtaining Chinese Notarial CNCRs. The substantive format was the only format we chose. So far, we have not received any feedback about rejection. However, our experience has a significant limitation: the vast majority of our clients lived outside China, and their Canadian immigration applications were processed outside China. Canadian immigration officers who are based inside China may make decisions contrary to standard practice after they learn about the Provisions. At present, there is no perfect solution.

IMPORTANT UPDATE (May 28, 2026): IRCC has updated its instructions regarding China CNCRs. The current instructions require applicants to provide a “Certificate of No Criminal Record” as well as “a notarized or certified translation”. Following the update, we recommend that applicants submit the following documents for Canada immigration:

• Police CNCR
• Non-substantive notarial CNCR (the 4-page version)

For those who would like to take a more cautious approach, consider obtaining both the substantive (2-page version) and the non-substantive (4-page version) notarial CNCRs.

Disclaimer: The above recommendations are based on our team’s practical experience, case analysis, and understanding of relevant regulations. They do not constitute legal or immigration advice. Applicants should check the latest guidelines published on the official website of IRCC before making any decisions. It is also strongly advised to consult a licensed immigration consultant or lawyer.

Conclusion

Thank you for reading. We welcome your feedback regarding any errors or omissions.

1. This term is not strictly accurate, as another format also has 4 pages but is used for immigration to other countries, such as the United States. For details, see What a China Police Certificate Looks Like. ↩︎
2. For more details, see “Substantive, Non-Substantive, or Procedural – Understanding Categories of Notarization in China” ↩︎
3. From China’s Ministry of Justice’s “Formats for Notarial Certificates (2011 Edition)” ↩︎