To better understand the range of potential impact for failing to properly notify IRCC of a change in the information provided in the application, including change of residential address, understanding the range of potential consequences should help. In particular, it should be helpful to more specifically enumerate the potential consequences, generally, for giving inaccurate information or failing to give information as obligated.
Not all inaccuracies or omissions are created equal. The consequences can range rather widely, including:
-- inaccuracy or omission is not detected; historically it appears that fudging the address appears to be something many applicants do and get-away-with; to be clear, not getting caught does not mean it was not a misrepresentation
-- little or no effect, treated as either an oversight, minor mistake, or insignificant omission
-- noticed and considered, mostly in context and in conjunction with other elements of the application, as one factor among many which may or may not affect the decision-maker's perception of the applicant's credibility; this itself can have a varied impact, including --
-- -- negative impact on credibility might be small, pursuant to which the decision-maker might exercise more caution in evaluating the information for which the applicant is the primary or only source
-- -- negative impact on credibility could be substantial, pursuant to which the decision-maker approaches the applicant's information with skepticism, and thus conducts further inquiries or initiates an investigation . . . potentially triggering, for example, RQ-related non-routine processing
-- -- negative impact on credibility could justify broadly disbelieving the applicant and thus result in findings which largely disregard any representations made by the applicant that are not otherwise verified by objective evidence; NOTE, this would require a finding the misrepresentation is material and the reasons therefore must be documented in the record, leading to . . .
-- negative decision-making premised on the lack of credibility, which again requires specific findings and documentation
-- summary denial of application; a serious material misrepresentation justifies the denial of the application even if the applicant otherwise meets all the requirements for a grant of citizenship (Raslan is one example of this)
-- revocation of citizenship; a serious material representation can be grounds for revoking citizenship, no matter how long the individual is a citizen
-- a knowing material misrepresentation can result in CRIMINAL prosecution
You cite the definition of misrepresentation which is applicable
ONLY to the last of these, the standard for convicting an individual for a criminal offence which can be punished by imprisonment. That is Section 29.2(2) in the Citizenship Act. This is probably the most uncommon consequence.
It warrants noting that even inaccuracies which are likely or otherwise appear to have been deliberate are OFTEN NOT subject to the severe end of the range of potential consequences. Even the more egregious instances, and particularly those which appear to be made pursuant to a deliberate scheme to deceive IRCC, most often ONLY result in negative decision making pursuant to which the applicant's representations are largely discounted or not believed unless there is objective evidence to establish those facts.
There are very few cases in which applications are denied specifically on the grounds of misrepresentation, and fewer still later result in revoking citizenship. There appear no more than a few criminal prosecutions for misrepresentation.
BEYOND that, the distinction between a simple or mere MISREPRESENTATION and a MATERIAL MISREPRESENTATION LOOMS LARGE:
It also makes a big difference if the misrepresentation is considered serious or not. But this is very difficult to pin down, even though some might say they know the difference between a serious misrepresentation and one that is not serious when they see it, even if they cannot articulate criteria or even a definition.
There are a lot of decisions which focus on whether an inaccuracy or omission constitutes a "
material" misrepresentation. Many various approaches to this question are discussed in those decisions. This distinction separates cases in which a negative action can be taken based on a finding of misrepresentation (requiring a finding of material misrepresentation) versus those cases in which misrepresentation affects the decision-maker's perception of the applicant's credibility.
Cases with a significant focus on credibility outnumber those addressing material misrepresentations by at least a factor of ten to one, and probably much higher than that.
That is, unless the applicant is engaging in outright fraud, most of the time the biggest RISK there is in failing to give or update accurate information is mostly the potentially negative impact on a decision-maker's assessment of the applicant's credibility. And in the citizenship application context, one of the ways this commonly influences how things go is in whether or not the applicant is diverted into this or that non-routine processing, with full blown RQ looming as among the more, let's say, inconvenient outcomes.
Bottom-line, however, is failing to ACCURATELY give or keep IRCC apprised of the information in the application is misrepresentation. The consequences can range from no impact at all to the more severe penalties for misrepresentation, but are far more likely to be in the range of compromised credibility, which can influence things like whether the applicant is subject to RQ-related non-routine processing.
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