The following goes long. And addresses a tangent about completeness screening in general.
(If I am posting a response it is usually to address a more complicated aspect of an issue.)
If it is a close call, and especially if obtaining a Police Clearance Certificate (or equivalent) is not especially inconvenient, as others suggest, it is probably better to simply do it: obtain and submit the PCC.
Waiting until the number of days in a row in the other country, within the preceding four years, falls to 182 or fewer days, that will allow an applicant to truthfully check [No] in item 10. b), and then the application will be COMPLETE, and thus NOT returned as incomplete, even though no PCC is included.
Technically a trip outside that country in the middle of the seven or so months living there will also allow the applicant to truthfully check [No] and not be required to submit a PCC with the application.
And in practice (subject to a caveat I hope to address below), the applicant can check [No], not include a PCC, and the application will not be returned as incomplete EVEN IF the accurate answer should be [Yes] and the applicant should be including a PCC.
Bringing this to the reason for my observations:
There is a difference between failing to submit a *complete* application, which results in the return of the application without processing, and what happens if the application is *complete* but --
-- there may be related questions or concerns otherwise, or
-- the applicant failed to properly or accurately provide information
This is particularly applicable in regards to item 10. b) and whether the applicant is required to submit a PCC
with the application.
Generally, checking [No] in response to item 10. b), or checking [Yes] but giving an explanation (either as to an exception to the requirement, or as to why a PCC cannot be included) in the chart, means the applicant does not need to include a PCC
with the application.
Foremost, applicants should be aware that even if the applicant is NOT required, per the instructions, to submit a PCC
with the application,
IRCC can LATER request a PCC or
pursue other resources to investigate whether the applicant has any prohibition arising from criminal offences in other countries . . . remember, the requirement to include a police clearance is ONLY a requirement applicable to what constitutes a complete application. The related qualifying requirement is that the applicant have NO criminal charges constituting a prohibition, including none in any country within the four years preceding applying. Whether or not the applicant meets the criteria requiring a PCC be included with the application, the applicant MUST nonetheless have NO criminal charges constituting a prohibition.
Thus, for example, where the applicant can TECHNICALLY check [No], based on waiting until the days-in-a-row fall to 182 or fewer, or because there was a break in the days-in-a-row due to a trip outside that country, sure that means the applicant does not need to include a PCC to make a complete application . . . but IRCC can still request a PCC later in the process . . . or, which has the potential for causing a longer delay in processing, IRCC might pursue other means to investigate and verify whether an applicant has a prohibition arising from criminal offences abroad, regarding which we do not know the full range of investigatory means available, but obviously at the least ranging from IRCC visa office inquiries in the respective country or countries, to CSIS investigations, and perhaps other international arrangements for governments to conduct background checks.
Those alternatives are likewise applicable if the applicant inaccurately checks [No], EVEN IF the applicant should have checked [Yes] and submitted a PCC. Again, this will generally (again subject to a caveat I hope to address below)
PASS the completeness screening and the application will NOT be returned as incomplete . . .
even if a PCC should have been included WITH the application (if item 10. b) had been accurately answered). Downside, which should be obvious, is that this can have significantly more negative consequences than merely the inconvenience and time it takes to obtain a PCC to submit with the application.
Similarly for *explanations* entered in the chart; an explanation will, generally (again with the caveat), mean the applicant does NOT need to include a PCC with the application, even if the applicant is not truly entitled to that explanation. Thus, the application will not be returned.
BUT . . .
AN OVERALL REMINDER: There are separate *requirements* for what constitutes a complete application. Submitting a complete application is, itself, just ONE of the qualifying requirements to be granted citizenship. Meeting this particular requirement does not, not by itself, satisfy any of the other substantive requirements.
Including a PCC with the application, for example, does not prove that an applicant has no prohibitions. And applicants who are not required to include a PCC with the application still must meet the requirement they have no foreign criminal charges constituting a prohibition.
Including proof of ability in one of official languages, for another example, does NOT prove the applicant meets the language requirement; it only satisfies the requirements for what constitutes a complete application. (Thus, for example, applicants are still screened for ability in one of the official languages attendant the test and interview.)
What will pass the completeness screening is the bare minimum. And passing the completeness screening (which is indicated by getting AOR) does NOT mean IRCC has verified the applicant has met any of the substantive requirements . . . with some small exceptions.
Leading to the "caveat" I referenced above.
The completeness screening is MOSTLY superficial. It is mostly screening to see the required information is included and is NOT about evaluating the quality or accuracy of that information.
With some exceptions. To some extent, for example, certain items are screened to make sure there are NO gaps in dates. Like employment and address history.
It appears that some cross-checking of information is done attendant the completeness screening. We know, for example, that some applicants who report having listed days in Canada with temporary resident status, to be counted toward meeting the presence requirement, have had their applications returned when, during the completeness screening, IRCC could not verify in GCMS the applicant had status during that period of time (this tends to affect visa-exempt individuals with significant periods of time in Canada as a visitor, for which there was no formal visa or visitor-record in their GCMS records).
We do NOT know to what extent, during the completeness screening, there is such cross-checking . . . even as to cross-checking information in the application itself. It is clearly NOT a lot. Appears to be rather minimal.
For example: During the period of time in which applicants were required to submit a PCC with the application if the applicant spent more than 183 days IN TOTAL in another country, there were scores and scores of anecdotal reports from applicants who improperly (inaccurately) checked [No] for what is now item 10. b) (most failing to consider the total number of days from multiple trips) and even though this may have been obvious in the applicant's printout of the physical presence calculation, their applications were NOT returned (later consequences varied, many simply being requested, during or after their interview, to obtain and submit a PCC). That is, it was clear that the completeness screening did not include cross-checking the item 10. b) information against the physical presence calculation.
It could be different now that what triggers the requirement to submit a PCC is 183 days in a row, which is easier to cross-check in the applicant's printout of the presence calculation.
Similarly, relative to listing a country but then giving an "explanation" which eliminates the requirement (for what makes a complete application) to include a PCC. We do not know to what extent the completeness screening only checks that there is an explanation provided, or to what extent it substantively evaluates the explanation.
The point of all this is to emphasize that the completeness screening is NOT substantive, or at least not much so. For example, as long as the applicant lists employment activities without any gaps in the dates, and enters at least a modicum of information in the chart, the application will LIKELY pass the completeness screening EVEN IF that information is inaccurate or vague or does not make a lot of sense . . . perhaps even listing "playing with two cats and a dog" in the occupation column will pass the completeness screening (though maybe not something so blatantly non-responsive).
Example to follow.
