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CICC active vs closed file separation for Ontario RCICs

CICC active vs closed file separation for Ontario RCICs

CICC’s Client File Management Regulation is explicit: Active Files must be stored separately from Closed Files, and a closed client file must be retained in a secure and accessible location for a minimum of six years after closure. Ontario RCICs who treat “closed” as a folder rename still spend time wondering whether a police certificate in a shared inbox belongs to a live file or one that ended two years ago.

Direct answer

Separate live intake from closed archive at the moment you close representation under your firm’s procedure — not when you finally clean up Drive. Before calling a file closed, the regulation’s closure themes typically require settled fees/refunds, returned client property, and written notice that the retainer ended. Then: export a complete checklist PDF package, move it to closed storage, add the file to your closed-file list with the closure date, and record a projected file destruction date. Stop collecting new documents on that client.

Hivi-X helps on the export and completeness side; your CRM, client-account (trust) records, and closure log still own the CICC file.

Active vs closed — what actually changes

StageWhat belongs hereCommon mistake
ActiveRetainer, live correspondence, in-progress supporting docs, billing in flightLeaving guest upload open after submission
ClosedFinal agreements, submitted application copies, complete supporting set, final invoices/receiptsMixing closed PDFs back into “current clients”
Retention (6+ years)Full file as it existed at closure; closed-file list; projected destruction dateDeleting because Drive ran out of space

Related: CICC client file management, Ontario RCIC retention.

When free tools are enough

A solo RCIC with roughly 15 active files can run active/closed separation with:

  • Two top-level folders (Active / Closed-YYYY)
  • A closure checklist in Word
  • Monthly export of completed packages
  • A spreadsheet closed-file list with dates

That costs $0 and works if one person enforces it. The failure mode is a coordinator uploading a new scan into a “closed” client’s old guest link because the missing-item view lived in someone’s head.

When checklist intake earns its keep

Pay for a collection layer when:

  • Multiple staff touch the same client’s documents
  • You cannot answer “what is still missing?” without opening email
  • Closed exports are incomplete because rejects and resubmits lived in threads

Hivi-X gives you item-level approve/reject on active files and a PDF export you drop into closed storage. It is overkill if you close two files a month and already export cleanly from Acrobat.

Honest math

If closure prep takes 45 minutes because someone rebuilds the supporting-doc set from email, and that happens eight times a month, you are burning six hours — often after hours. A checklist layer that keeps “approved items only” visible can shrink that to an export click. Whether that beats a business plan fee depends on your hourly rate and how messy intake already is.

Hivi-X does not certify CICC compliance, auto-close files, or replace trust/client-account software.

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General information only. Not immigration or legal advice. Hivi-X is document-collection software — not a licensed immigration consultant. Not affiliated with or endorsed by CICC or IRCC. Verify all requirements against the current CICC Client File Management Regulation and each client's profile.

Answers are general operational information only — not legal, tax, regulatory, clinical, privacy, immigration, or professional advice. Requirements vary by matter, client, and regulator.

Frequently asked questions

Must Ontario RCICs keep active and closed files in separate systems?
The Client File Management Regulation requires storing Active Files separately from Closed Files. How you implement that — folders, DMS, CRM archive — is your policy choice, but mixing live intake with closed files creates retrieval and confidentiality risk.
When may a file be closed?
Under the regulation, only when outstanding fees or refunds are settled, client property has been returned, and the client (or designate) has been notified in writing that the retainer ended and property was returned. Confirm current CICC text.
When does the six-year retention clock start?
After the file has been closed under those closure steps — not merely when IRCC acknowledges receipt of an application.
Can Hivi-X mark a file as closed for CICC?
No. Hivi-X organizes live document intake and exports PDF packages. Closure, billing finalization, closed-file list, projected destruction date, and long-term archive location remain your responsibility.
Is a spreadsheet list of closed clients enough?
A closed-file list with closure dates is required. CICC also expects the complete client file — agreements, correspondence, billing, supporting documents — accessible and separated from active work.
When is free folder separation good enough?
Solo RCICs with low volume and a disciplined export habit can manage with structured folders. Firms with coordinators chasing live documents across dozens of active files usually need item-level tracking before archive.

Collect complete immigration client files without the chase

Hivi-X helps Ontario RCICs collect passports, police certificates, employer letters, and IRCC forms with reusable checklists, the my-id.ca client portal, self-hosted AI summaries, and exportable PDF packages for your client file archive — alongside your immigration CRM.

CICC Active vs Closed File Separation | hivi-x Docs