There is NO support for this in the context of a citizenship application. Your experience in the hiring process for law enforcement, in particular, is NOT relevant to the citizenship application process.
Applicants should read and follow the instructions in the form and guide. They clearly state that those who have spent 183 or more days in another country within the preceding four years need to check "yes" when responding to item 10.b. A simple calculation. The FAQs confirm this.
If the applicant checks "yes" the applicant needs to either include the police certificate or give an explanation. If the applicant does not do one or the other, the application will most likely be returned to the applicant as incomplete.
An applicant who concurs in what you propose could check "no" and add a supplemental page to the application, explaining that the reason for the "no" check is that the applicant has not spent 183 days in another country since landing and becoming a PR, and see how that goes. It might pass.
But just checking "no" could be construed to be a misrepresentation if the applicant has, in fact, spent 183 or more days in another country within the FOUR years that count. Checking "yes" and not providing a certificate or explanation will render the application incomplete.
BUT it is true that there is NO rule, as such, that citizenship applicants should submit a PCC for the time prior to becoming a PR. In fact there is NO rule that any applicants must submit a PCC at all.
But to make a complete application, to have an application for citizenship processed, IRCC can and does require some applicants to submit a PCC upfront, with the application.
That is, the rules are that an applicant is prohibited from a grant of citizenship if the applicant has been convicted of an offence in another country within the preceding four years, and that IRCC has broad discretion in adopting policy and practices to enforce such requirements, including authority to require applicants provide certain information to allow IRCC to assess the applicant's qualifications, and to require applicants meeting certain criteria to submit a PCC UPFRONT with the application. It is pursuant to this authority that IRCC requires applicants to declare whether they have spent a total of 183 or more days in a country within the preceding four years, and likewise to require any applicant who has to submit a PCC upfront with the application. Thus of course IRCC can also waive this, generally or individually. An applicant can ask for such a waiver, in effect, by submitting an explanation in one of the multiple ways I describe above.
Most of the IRCC website information about police certificates is relevant for visa applications rather than citizenship applications. The information about how to obtain a police certificate is the same for both types. But who must submit a police certificate is not the same for citizenship applicants as it is for visa applicants.
In particular, in the citizenship context it is NOT about residing or living in another country. The criteria for who must submit a certificate is based on days present in a country. In particular, a citizenship applicant could be required to submit a certificate from a country where the applicant NEVER LIVED. A person who regularly goes to the U.S. Friday to Sunday, twice a month, and never spends more than a couple whole days in the U.S. at a time, will nonetheless need to provide a U.S. police certificate (3 days X twice/month X 4 years = way more than 183 days).
Last I looked, there was no IRCC information about how current the police certificate must be for a citizenship application. But the information for visa applicants offers some guidance. Thus, a certificate that is less than six months old should suffice even if the applicant has returned to that country within the last six months. A certificate more recent than the last time the applicant was present in that country should suffice. Thus an older certificate may work. But who has such an original police certificate to submit? (Note that one of the alternatives I have discussed, for the applicant who came to Canada less than four years ago, who was in his or her home country for more than 183 days in the preceding four years, but none of those days have been since coming to Canada, could try explaining this rather than submit a police certificate . . . but how that will actually go is uncertain . . . worst case scenario is the application is returned and the applicant will have an opportunity to re-submit it with a police certificate, but IRCC might accept this.)
