GCMS Notes Say "Security: In Progress" - What It Means and When to File for Mandamus

For many Canadian immigration applicants, the journey is a marathon of paperwork, waiting, and checking online statuses. But few phrases cause as much anxiety and confusion as seeing “Security: In Progress” lingering in your Global Case Management System (GCMS) notes for months, or even years. It feels like your future is trapped in a black box, with no clear timeline or explanation. You’ve done your part, submitted everything, and now you wait. But for how long is that wait considered reasonable?

This is more than just an administrative delay; it's a profound period of uncertainty that can halt careers, keep families apart, and put life plans on indefinite hold. When that wait becomes unreasonable, the Canadian legal system offers a powerful remedy: a Judicial Review application for an order of mandamus. This is a formal request to the Federal Court to compel Immigration, Refugees and Citizenship Canada (IRCC) to make a decision. But how does the Court decide when a delay, especially one attributed to security screening, has crossed the line? A review of real court cases reveals the critical difference between a necessary pause and an unjustified standstill.

The Federal Court's Stance on Unreasonable Delays

When an application is stuck in processing, applicants often turn to the Federal Court through Judicial Review. They aren't asking the Court to approve their application, but to order IRCC to simply do its job and render a decision. This is where the concept of "unreasonable delay" becomes the central issue, and the justification of "security in progress" is put to the test.

When "Security in Progress" Isn't a Good Enough Reason

The Federal Court has consistently made it clear that IRCC cannot use security screening as a shield to justify indefinite delays. Vague, blanket statements are simply not enough. In Saqib Javed v. The Minister of Citizenship and Immigration, 2025 FC 987, an Express Entry applicant waited 49 months-eight times the standard processing time. The Court rejected IRCC’s explanation, stating, “The Respondent's bare submission that the GCMS notes show ongoing security checks is the kind of blanket statement that this Court has consistently held to be inadequate.” This powerful statement underscores a key principle: the burden is on IRCC to provide a satisfactory justification for the delay.

This principle was echoed in Peng v. Canada (Minister of Citizenship and Immigration), 2025 FC 2, where a Provincial Nominee Program applicant waited over three years. The Court found that IRCC had provided “hardly any justification at all” and ordered a decision within 90 days. Similarly, in Habibi v. Canada (Citizenship and Immigration), 2025 FC 1675, a 36-month delay for a citizenship application was deemed unreasonable. The Court noted that security checks are not a “blank cheque for delay” and, in a rare move, awarded costs to the applicant because IRCC's justification was so unsatisfactory.

Even when a case involves complex investigations, the delay must be reasonable and the investigation diligent. In Alasmar v. Canada (Minister of Citizenship and Immigration), 2025 FC 1260, citizenship applications were suspended for over six years. The Court found the investigation had been “languishing” and that the suspension was no longer necessary, ordering IRCC to make a decision.

Update: the Federal Court reinforced this in July 2026

In Roghangar v. Canada (Citizenship and Immigration), 2026 FC 987, the Federal Court ordered IRCC to decide an Iranian applicant’s study permit within 45 days after a delay of about three and a half years tied to a security assessment triggered by his mandatory military service. That delay ran roughly 20 times IRCC’s own 60-day service standard. The Court held that “blanket statements” that a security screening is in progress, without any evidence about the nature of the screening, are not enough to justify the delay, and it awarded the applicant costs.

Not sure whether your delay is bad enough yet? The Mandamus Readiness Check walks through the same factors the Federal Court weighs, including how long you have waited against the posted processing time and whether you have asked IRCC for a decision. It takes about two minutes.

Update: August 2026, the Court compels a decision after a four and a half year wait

The Federal Court returned to this issue in August 2026 in Abdelrahman v. Canada (Citizenship and Immigration), 2026 FC 1076. A family of permanent residence applicants had waited four and a half years while IRCC repeatedly reported only that security screening was still in progress. Justice Kane granted mandamus and ordered a decision within 120 days, finding that a delay of roughly double the average processing time was longer than the nature of the process required and that IRCC had not adequately explained it (at para 40).

The Court restated the rule that matters most to a delayed applicant. It has, in its words, "consistently rejected ‘blanket statements’ that security screening is in progress as an adequate justification for delay and has required at least some details with respect to what security concerns or issues are the cause of the delay" (at para 43). A generic note that screening is ongoing, with no specifics, does not justify an open-ended wait.

Abdelrahman also applied the Federal Court of Appeal’s recent decision in Benison v. Canada, 2026 FCA 53, which clarified how these cases run. Once an applicant shows the delay is longer than the process reasonably requires, the burden shifts to IRCC to justify it with evidence tied to that specific file (at para 29). The Court added a practical warning for the Minister: a sudden burst of activity after a mandamus application is filed, such as a late request for an interview, shows the file is finally moving but does not excuse the years of inaction before it (at para 44).

When Security Concerns Can Justify Longer Waits

While the Court is critical of unexplained delays, it also recognizes that some security screenings are complex and genuinely require more time. The key is whether IRCC can provide a reasonable explanation. In Cheloei v. Canada (Minister of Citizenship and Immigration), 2025 FC 820, an Iranian citizen's visitor visa application was delayed for 18 months due to security screening related to his mandatory service in the IRGC. The Court dismissed the mandamus application, finding the delay was not unreasonable given the specific security context and that IRCC was taking steps to move the application forward.

Similarly, the Court has recognized that high-volume programs with government-set quotas can lead to long, but justified, waits. In Wang v. Canada (Citizenship and Immigration), 2025 FC 1832, a seven-year wait for a Québec Investor Program application was deemed not unreasonable. The Court explained it would not allow applicants to “jump the queue” where an orderly, albeit slow, first-in, first-out system was in place.

The Applicant’s Role and the Path to Mandamus

Successfully obtaining a mandamus order isn't just about showing IRCC's delay; it also depends on the applicant's own actions and circumstances.

The Importance of Compliance and Prejudice

The Court looks favorably on applicants who have done everything asked of them. In Donzo v. Canada (Minister of Citizenship and Immigration), 2025 FC 154, a 40-month family sponsorship delay was found unreasonable, with the Court highlighting the applicant's timely responses to all requests. Conversely, if the delay is the applicant's fault, a mandamus application will fail. This was the outcome in Mahboobehsadat Emadi v. The Minister of Citizenship and Immigration, 2025 FC 1316, where the delay was caused by the applicant’s spouse being unavailable for a mandatory interview.

While some decisions, like Tousi v. Canada (Minister of Citizenship and Immigration), 2025 FC 671, confirm that demonstrating “significant prejudice” is not a strict requirement for mandamus, providing evidence of hardship can tip the scales. In Chirum v. Canada (Minister of Public Safety and Emergency Preparedness), 2025 FC 259, the Court noted that a five-year wait was unreasonable for any applicant, but “even more unreasonable” for an applicant in his 70s with a precarious status. In contrast, the spousal sponsorship case of Muhammad Atiq Ur Rehman v. Minister of Citizenship and Immigration, 2025 FC 388 was dismissed because the applicant's affidavit about prejudice was too vague to meet his burden.

The Limits and Risks of Judicial Review

Filing for Judicial Review is a powerful tool, but it has its own rules and risks. The process must be respected. In Chen v. Canada (Minister of Immigration, Refugees and Citizenship), 2025 FC 425, an applicant tried to bypass court rules by discontinuing one application to file an identical new one. The Court struck the application as an abuse of process, a serious finding that can impact future legal credibility.

Finally, timing is everything. A mandamus application exists solely to compel a decision. If IRCC makes a decision-even a refusal-before the court hearing, the mandamus application becomes moot, as its purpose has been fulfilled. This happened in both Khan v. Minister of Citizenship and Immigration, 2025 FC 1324 and Khamdamov v. Canada (Immigration, Refugees and Citizenship), 2025 FC 1855. The court cases were dismissed because there was no longer a live controversy to address.

Key Lessons

• “Security in Progress” is not a blank cheque for delay. The Federal Court requires IRCC to provide a satisfactory justification for long waits, and blanket statements about security checks are often deemed insufficient.
• The burden of proof is on IRCC. Once a delay is shown to be significantly longer than the norm, the responsibility shifts to the government to explain why.
• Your own compliance is critical. Ensure you have responded to all requests from IRCC and that the delay is not your fault. Any failure on your part, like missing an interview, will likely cause a mandamus application to fail.
• Demonstrate the impact. While not always a strict requirement, providing specific evidence of how the delay has negatively impacted your life, family, or career can strengthen your case.
• Judicial Review is a catalyst. In many cases, the very act of filing for mandamus prompts IRCC to take action on a file that has been dormant for years.

Navigating an unreasonable processing delay can be one of the most stressful parts of the immigration process. Seeing "Security: In Progress" month after month in your GCMS notes is disheartening, but it is not the end of the road. Understanding your rights and the power of a mandamus application is the first step toward regaining control. With careful preparation and clear legal guidance, you can challenge the administrative silence and compel the decision you have been waiting for.