I am applying for PR through PNP. Last week, I had my US Visa application held under admin. processing (AP) under section 221(g) and still pending decision. Back in 2018, I also had my first US Visa (and my first visa ever), underwent AP, and was eventually approved after a few weeks back then. I am currently in Canada under a study permit. Because my first US Visa was approved, I did not disclose it in my subsequent Canadian study permits and TRV applications.
Now, as I am submitting my PR application, I've become aware that failure to disclose US Visa AP history is considered a serious misrepresentation, regardless of the eventual outcome that it was ultimately approved. I have made sure to disclose this information in my PR application clearly. I attached an explanation letter in my PR application in which I explained that I was unaware that I should've disclosed this information in my prior study permit applications and that, within the PR application, I have fully disclosed this information now with dates, locations, application numbers, and outcome (all approved, except the last one still pending decision).
Do I need to include such information in the explanation letter (regarding not disclosing the AP in my study permit application)?
If I mention it, is this going to cause me any trouble?
Do you need to include this information in the explanation letter (regarding not disclosing the AP in your study permit applications)?
Yes, it is wise to include it — and you already have, which is good. Administrative processing under 221(g) is considered a visa refusal for Canadian immigration purposes, even if the visa was later issued. IRCC expects full disclosure of any such prior visa refusals or holds, even temporary ones, across all applications.
Since your omission was not intentional and you’re now disclosing it voluntarily in your PR application, that reflects honesty and an effort to correct past errors. Including an explanation that:
You were unaware it should have been disclosed;
The visa was eventually approved;
You’re now disclosing it fully and transparently;
is exactly the right approach.
If you mention it, is this going to cause you any trouble?
Not necessarily, and certainly less than if you didn’t mention it at all. Here’s why:
Voluntary disclosure of prior mistakes and a good-faith explanation usually works in your favour.
Since your initial visa was ultimately approved, and you’re now correcting the record, IRCC may consider it an innocent oversight rather than intentional misrepresentation.
The risk of misrepresentation mainly arises when IRCC discovers the omission without your acknowledgment — which is not the case here
That said, IRCC officers do have discretion, and they might ask for further clarification. But by proactively disclosing and explaining it, you are significantly reducing the risk of a finding of misrepresentation.
Recommendations:
Stick with the explanation you’ve provided — you’re handling this the right way.
If possible, keep documentation that supports your AP and visa approval history (e.g., emails from the US consulate, visa stamps, DS-160 confirmations).
If IRCC contacts you for further clarification, respond promptly and thoroughly.
