The short answer is: in most cases, no.

A Pre-Removal Risk Assessment (PRRA) is not an application you can simply file on your own initiative. With only two narrow exceptions, you can only apply for a PRRA after the Canada Border Services Agency (CBSA) has formally notified you that you’re eligible to do so.

This is one of the most common questions we get from people who are afraid to return to their country but haven’t yet received any communication from CBSA. Here’s how the process actually works, and what your options look like if you’re waiting.

What is a PRRA, and when does it come up?

A Pre-Removal Risk Assessment is a paper-based review of the risks you would face if Canada removed you to your country of nationality or habitual residence. It looks at the same kinds of risks a refugee claim does: persecution, torture, risk to life, and cruel and unusual treatment or punishment.

The PRRA is designed as a last-stage safeguard, meaning it’s triggered when CBSA is preparing to remove you from Canada. It isn’t a general protection application that anyone in Canada can submit, and it isn’t a substitute for a refugee claim before the Immigration and Refugee Board of Canada (IRB).

The short answer: a PRRA usually starts with a CBSA notification

Under section 160 of the Immigration and Refugee Protection Regulations (IRPR), a person generally cannot apply for a PRRA until CBSA has issued a Notification Regarding a Pre-Removal Risk Assessment.

In practice, this notification is usually delivered in person by a CBSA removals officer once your file is considered “removal-ready,” often during an in-person reporting meeting. It comes with a PRRA application kit and sets out the deadlines for filing.

Until that notification arrives, you cannot file a PRRA application, no matter how strong your risk profile is.

When can you apply for a PRRA without an invitation?

The regulations contain two narrow exceptions under subsection 160(2):

• Removal orders made at a port of entry (POE): If a removal order is made against you at a port of entry, such as an airport or land border, you may apply for a PRRA without first receiving a notification.
• Subsequent PRRA applications: If you have already received a PRRA notification in the past and are filing a second or later PRRA, you may also apply without a new notification, provided you meet the other eligibility requirements.

Outside these two scenarios, the rule is firm: no notification, no application. CBSA officers, not applicants, decide when the PRRA process begins.

What happens once you receive the PRRA notification?

Once CBSA hands you the notification, the timelines are short and unforgiving:

• 15 days to submit your completed Application for a Pre-Removal Risk Assessment (Form IMM 5508), if you received the kit in person.
• An additional 7 days if the notification was delivered by mail (in other words, 22 days from receipt).
• A further 15 days after submitting the application to provide your written submissions and supporting evidence.

If you submit a timely first-time PRRA application, you also benefit from an automatic regulatory stay of removal, meaning CBSA cannot remove you while the application is being decided. Miss the 15-day deadline, however, and that stay disappears, and removal can proceed.

Why this matters more after Bill C-12

Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, received royal assent on 26 March 2026 and introduced new bars on refugee claims, including a one-year deadline from first entry into Canada (for entries after 24 June 2020) and a 14-day deadline for irregular crossings at the Canada–US land border.

For people who are now ineligible for a hearing at the Refugee Protection Division because of these bars, the PRRA has become the main remaining mechanism to ask Canada to assess risk before removal. But the basic rule hasn’t changed: you still cannot file a PRRA on your own, and you still have to wait for CBSA to issue a notification.

That makes timing, preparation, and legal strategy more important than ever.

What if I fear removal but haven’t been invited?

If you’re worried about being returned to your country and haven’t yet received a PRRA notification, trying to “get ahead” by submitting a PRRA isn’t the answer. The application will not be accepted.

What you can do is build your case in advance. That may include:

• Gathering identity documents, evidence of risk, and country-condition material now, rather than waiting for the 15-day clock to start.
• Considering whether you remain eligible for other protection mechanisms, such as a refugee claim before the IRB or a Humanitarian & Compassionate application.
• Reviewing whether any prior negative decision could be challenged through judicial review at the Federal Court.
• Maintaining your immigration status in Canada wherever possible, so that removal proceedings don’t begin prematurely.

If and when CBSA does issue a PRRA notification, you’ll already have the evidence and legal framework ready, instead of scrambling within a 15-day window.

How can Kabir & Alam help?

We help clients prepare for, respond to, and pursue PRRA applications, including subsequent PRRAs and applications filed from a port of entry. We also advise on what to do before a PRRA notification arrives, so that you’re not caught flat-footed if CBSA initiates removal.

If you’re worried about being removed from Canada, or you’ve just received a PRRA notification from CBSA, time is critical.

Book a consultation with us today, so that we can hear your story and advise you on your options.