Nope. Let me explain my line of thought. Pasting the suitable portions of the notice.
A candidate who reports an age difference between the time they receive an invitation and the time they submit an application for permanent residence (APR) may no longer meet the requirements of the Federal Skilled Worker Class, specifically those requirements pertaining to the number of points required of an applicant and the number of points awarded, under the Immigration and Refugee Protection Regulations (the Regulations), on the basis of their age.
due to the loss of age points as a result of their birthday occurring between the time they were invited to apply and the deadline for submitting an application for permanent residence
delegated officers may grant an exemption from the criteria
- At the time the officer received their application, the foreign national no longer met sub-paragraph 76(1)(a)(iv) and section 81 of the Regulations because the foreign national’s birthday occurred after the invitation to apply was issued;
Provision for grant of exemption
- Sub-paragraph 76(1)(a)(iv) and section 81 of the Regulations, as they pertain to the number of points required on the basis of the age
The wordings are clear that the Age should be considered at the time of ITA, if the birthday falls between ITA and AOR/APR. Infact it states that the points for age should not be deducted if the "
birthday occurring between the time they were invited to apply and the deadline for submitting an application for permanent residence". This means that even if eAPR/AOR is on the last last of the deadline, you will not be deducted the points for change in age.
Mis quoted the first line of public policy act under section A11.2
Exemption to section A11.2: candidates whose birthday occurs after they receive an ITA
An applicant may have a birthday after they receive an ITA but before they submit their e-APR. Their change in age may lower their CRS score below the lowest score in the round of invitations. It may also result in the applicant no longer meeting the minimum requirements of the FSWC and, consequently, no longer meeting the MEC, resulting in a refusal based on
section A11.2.
When a change in age results in the candidate no longer meeting the MEC or having their recalculated CRS points score fall below the lowest points score in that round of invitations, officers should consider applying the
public policy to exempt applicants for permanent residence from certain age-based requirements between invitation to apply and application, based on
section A25.2. This consideration can result in an exemption from the refusal of an application under section A11.2.
This public policy also grants an exemption to applicants who may be refused for failing to meet FSWC program requirements when their birthday occurs between the ITA and e-APR.
Exemption to section A11.2: candidates whose birthday occurs after they receive an ITA
An applicant may have a birthday after they receive an ITA but before they submit their e-APR. Their change in age may lower their CRS score below the lowest score in the round of invitations. It may also result in the applicant no longer meeting the minimum requirements of the FSWC and, consequently, no longer meeting the MEC, resulting in a refusal based on
section A11.2.
When a change in age results in the candidate no longer meeting the MEC or having their recalculated CRS points score fall below the lowest points score in that round of invitations, officers should consider applying the
public policy to exempt applicants for permanent residence from certain age-based requirements between invitation to apply and application, based on
section A25.2. This consideration can result in an exemption from the refusal of an application under section A11.2.
This public policy also grants an exemption to applicants who may be refused for failing to meet FSWC program requirements when their birthday occurs between the ITA and e-APR.