Sections 44 to 46 of SOR/2022-128 govern how every RCIC may advertise — required disclosures, prohibited claims, testimonials, and the licence-class rule almost nobody checks. Plain language, quoted from the regulation.
Every Regulated Canadian Immigration Consultant is bound by the Code of Professional Conduct for College of Immigration and Citizenship Consultants Licensees. It is a federal regulation, SOR/2022-128, and three of its sections govern how you are allowed to market yourself.
Most consultants have never read them. That is understandable — it is a regulation, not a marketing guide. But the College does not grade on intent, and the penalty for getting it wrong reaches $50,000 per contravention. This is what those three sections actually say, in plain language, with the wording quoted so you can check it yourself.
Section 44 — Marketing of services
Section 44 is the one that catches most people, because it has two halves and the second half is broad.
44(1) tells you what must appear. Your registered name has to be displayed prominently at or near the beginning of your marketing materials. Written advertisements must carry the College's public register address. Your RCIC designation and licence number need to be visible.
That last point is worth pausing on. We audited a licensed, in-good-standing consultant's website recently and searched the homepage for every form of their credential — the R number, "RCIC", "CICC", "College of Immigration". All four returned zero. The one thing that proved they were legitimate was the one thing missing, while the page confidently claimed something they were not.
44(2) prohibits false, misleading or inaccurate representations. In practice that covers more than outright lies:
- Guaranteed outcomes. "100% success rate", "approval guaranteed", "PR in six months". You do not control IRCC's decision, so you cannot promise it.
- Implied government affiliation. "We work directly with IRCC", "special connections", anything that reads as if you are part of the department.
- Success-rate statistics that are not accurate, verifiable and in context.
- Professional titles you do not hold. This is the one nobody expects.
The title problem almost nobody checks
A page headed "Immigration Lawyer in [Your City]" is a representation about who you are. If you are an RCIC and not a lawyer, that is a misleading representation under 44(2) — and a footer that says "consultant" does not cure a heading that says "lawyer".
The test is the impression created in a prospective client's mind, not what you meant. Someone landing on that page from a Google search sees the heading, not your disclaimer.
This is not hypothetical. Running our compliance scanner across real RCIC sites, we found city pages titled "Immigration Lawyer in [City]" — four of them, on one licensed consultant's website, with no clarifying statement anywhere. Words like attorney, law firm and legal representation carry the same risk.
The licence-class trap
Here is the rule almost no marketing advice mentions, because it requires reading the register rather than the website.
The CICC public register lists your licence class next to your name, and the classes are not decorative:
- Class L1 — RCIC. A new licensee who has not yet completed the New-Licensee Mentoring Program. Same full scope of practice as L2.
- Class L2 — RCIC. Full scope of practice. In the College's own words, these licensees "cannot practise before the IRB unless they also are a paralegal licensed by the Law Society of Ontario."
- Class L3 — RCIC-IRB. The same full scope as L2, "with the additional qualifications to represent clients before the IRB."
Appeals to the Immigration Appeal Division, detention reviews and refugee hearings are all IRB matters. If you hold L1 or L2 and your website advertises appeal representation, you are marketing a service your licence does not permit — a 44(2) problem layered on top of a scope problem.
And the reverse is worth saying too. If you are L3, say so. Fewer than one in five licensees hold RCIC-IRB, and in our experience most who do never mention it anywhere on their website. It is the strongest differentiator in the profession and it is sitting unused.
Section 45 — Client endorsements
Testimonials are governed separately, and the requirement is specific: a client endorsement requires actual written approval from the client or former client, and it must be truthful and accurate.
Practical consequences:
- Get permission in writing, before publishing — not after, and not implied by the client having said something nice.
- Do not edit a testimonial in a way that changes its meaning.
- A testimonial that implies a guaranteed outcome is still a problem even though the client wrote it. You published it.
- Never fabricate reviews, and never use AI-generated ones.
A one-page release form solves this permanently: permission to use their words, permission to use their name or mark it anonymous, and an acknowledgement that it reflects their own experience.
Section 46 — The College's name, logo and marks
Short and absolute. You may use the College's name, logo and marks only as the College permits. Do not modify them, do not restyle them to match your brand, and do not use them in any way that implies endorsement of your practice by the regulator.
A five-minute self-audit
Open your own website and check:
- Is your registered name visible near the top of the page?
- Does your R number appear anywhere? Search the page for it.
- Is the CICC public register link present in your footer?
- Does any page use "lawyer", "attorney", "law firm" or "legal representation" about you?
- Does any page advertise appeals or IRB representation? Check your class on the register before leaving it up.
- Does any page promise outcomes, timelines or success rates?
- Do you hold written permission for every testimonial currently published?
Most consultants fail items 2, 3 and 4 without realising it. All three are an afternoon's work to fix, and all three are visible to anyone who looks — including a complainant.
Where to check the source
Do not take our word for any of this. The regulation is public: SOR/2022-128, current as of 14 June 2026, sections 44 to 46. Your licence class and standing are on the College's public register at register.college-ic.ca.
This article is a plain-language summary written by a marketing agency, not legal advice, and it does not replace your own compliance review.
Frequently Asked Questions
No. If you are a Regulated Canadian Immigration Consultant and not a licensed lawyer, describing yourself as an immigration lawyer, attorney or law firm is a misleading representation under section 44(2) of SOR/2022-128. The test is the impression created in a prospective client's mind, so a page headed "Immigration Lawyer in [City]" is a problem even if a footer elsewhere says consultant.
Only Class L3 — RCIC-IRB. The College states that Class L2 licensees cannot practise before the Immigration and Refugee Board unless they are also a paralegal licensed by the Law Society of Ontario. Class L1 holds the same scope as L2. If you advertise IAD appeals, detention reviews or refugee hearings, confirm your class on the public register first.
The Discipline Committee can order a monetary penalty of up to $50,000. Complaints and investigations also carry reputational cost well before any penalty is decided.
Yes. Section 45 requires actual written approval from the client or former client, and the endorsement must be truthful and accurate. A testimonial implying a guaranteed outcome remains a problem even when the client wrote it themselves, because you are the one publishing it.
The College's public register at register.college-ic.ca lists every licensee's name, standing and licence class. The register shows the class code but not a description of what it permits, which is why so many consultants are unaware of the IRB restriction attached to L1 and L2.
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