Vancouver, Canada — In 2025, the Government of Canada will enter a formal evaluation phase of its national Entry/Exit Program. This multi-year initiative systematically records the cross-border movements of travelers entering or leaving the country. Designed initially to modernize border security, strengthen immigration enforcement, and improve the accuracy of travel histories for federal services, the program is now at the center of an evolving conversation about how travel risk scores are calculated and used.
Government officials emphasize that the program’s purpose is to enhance efficiency and ensure compliance with Canadian laws. Yet as the program has matured, its role has expanded beyond simple record-keeping toward predictive risk analysis, where travel histories and patterns are analyzed to assign a numerical or categorical risk score to each traveler. These scores influence decisions such as whether to refer someone to secondary inspection, how to prioritize enforcement resources, and, in some cases, whether to approve participation in trusted traveler programs.
Origins and Expansion of the Entry/Exit Program
The foundations of the Entry/Exit Program date back to 2011, when Canada and the United States signed the Beyond the Border Action Plan. This bilateral initiative aimed to create a shared approach to border management, including the exchange of entry and exit records at land crossings. The initial pilot phase began in 2012 with the exchange of biographic entry data for third-country nationals, permanent residents of Canada, and lawful permanent residents of the United States.
By June 2013, the pilot expanded to cover all travelers at land ports of entry. In 2019, the program was extended to include all commercial air carriers, requiring them to submit passenger manifests to the Canada Border Services Agency (CBSA) before departure. By 2020, air exit data was fully integrated with existing land entry/exit records, creating a near-complete travel history database for most travelers.
Today, the system captures exit information for commercial air and land crossings, with discussions underway about extending it to marine and rail travel. The evaluation phase is reviewing both the operational benefits and the legal implications of these expanded capabilities.
From Historical Record to Risk Score
Initially, entry/exit data served as a historical record, primarily used for immigration compliance, tax residency verification, and criminal investigations. The current evolution involves applying data analytics and algorithmic modeling to predict potential non-compliance or security risks before they occur.
Risk scores are generated using criteria such as:
Frequency of travel to certain regions
Duration of stays compared to declared purposes
Consistency with employment, visa status, or residency claims
Links to other travelers under investigation
Historical customs compliance records
Payment patterns for travel bookings
Travelers with higher scores may experience more frequent inspections, questioning, or delays, even in the absence of a specific violation.
Case Study 1 — Frequent Business Traveler Flagged for Pattern Risk
A Vancouver-based mining executive who makes frequent trips to South America noticed a sharp rise in secondary inspections. An access to information request revealed that his travel pattern matched one associated with high-value mineral smuggling, despite no evidence of wrongdoing. Amicus International Consulting advised restructuring itineraries, adding pre-departure declarations, and consolidating multiple short trips into fewer, more extended visits to normalize the pattern within the risk algorithm.
Case Study 2 — Tax Residency Discrepancy Triggering Delays
A Canadian–U.K. dual citizen returned from the Middle East after a six-week business engagement and was delayed at the border for hours. The CBSA risk model flagged his travel as inconsistent with declared Canadian tax residency. While eventually cleared, the incident prompted him to obtain a copy of his official travel record to correct errors and add explanatory notes for future trips.
Case Study 3 — NGO Worker Misclassified Due to Conflict Zone Travel
A humanitarian coordinator traveling between Canada and East Africa for relief missions was repeatedly referred to secondary inspection. The algorithm assigned her a higher score based on repeated visits to conflict zones. Amicus assisted the NGO in implementing a travel documentation protocol that included advance mission notices to CBSA and presentation of supporting evidence at entry points, which resulted in a lower score over time.
Case Study 4 — Family Vacation Impacted by Data Error
A family returning from a Caribbean vacation was pulled into secondary inspection after the father’s travel record incorrectly showed overlapping entries to two different countries. The discrepancy was traced to a misreported connecting flight. By filing a correction request under the Privacy Act, the family restored their records and avoided future disruptions.
International Comparisons — How Other Jurisdictions Use Exit Data
In the European Union, the upcoming Entry/Exit System (EES) will track all non-EU travelers, retaining data for three years, or five for overstays. This system is tied to the ETIAS pre-travel authorization platform, creating a layered risk assessment process. While designed for Schengen security, the system has faced legal challenges in member states concerned about proportionality and retention.
In the United States, CBP uses entry/exit data alongside Passenger Name Records and other databases to maintain watchlists and risk profiles. Unlike Canada, where domestic oversight bodies can review practices, U.S. law gives border agencies broad discretion in determining scoring criteria.
In the Gulf states, such as the United Arab Emirates and Qatar, exit and entry data is integrated with national ID systems, allowing governments to link border movements to banking, housing, and employment records. While efficient, these systems operate in legal environments with limited avenues for challenging data errors.
Case Study 5 — Corporate Mobility Program Facing Collective Flagging
A Canadian engineering firm sending teams to the Gulf for infrastructure projects noticed that several employees were consistently flagged for inspection upon return. The review showed their collective travel created a pattern in CBSA’s models, suggesting organized activity in a high-risk jurisdiction. Amicus developed a staggered travel schedule and centralized declaration process to reduce algorithmic clustering.
Case Study 6 — Retiree Penalized by Misinterpreted Long Stay
A retired teacher who wintered in Portugal each year was flagged for exceeding Canadian residency absence thresholds. The system miscalculated his return date due to a ferry trip booked separately from his flight. Amicus assisted in correcting the record and advised pre-registering all segments in the official travel log to avoid future misinterpretations.
Case Study 7 — Student Visa Holder Monitored for Compliance
An international student attending a Canadian university made frequent weekend trips to the United States. His travel triggered reviews of his class attendance and part-time work eligibility, as the risk model associated frequent short cross-border trips with unauthorized employment. With guidance, he provided CBSA with proof of full-time enrollment and compliance with work restrictions, lowering his risk score.
Case Study 8 — Export Business Owner Navigating Multiple Jurisdictions
A Toronto-based entrepreneur exporting agricultural equipment to Africa and Southeast Asia managed multiple visa categories and business registrations. Divergent data in foreign and Canadian systems created conflicting travel histories. Amicus coordinated record reconciliation across agencies to ensure consistent profiles and avoid high-risk flags.
Privacy and Oversight Concerns
The Office of the Privacy Commissioner of Canada has cautioned that travel risk scoring must be transparent, fair, and subject to meaningful oversight. Key recommendations include:
Publishing general scoring criteria without compromising operational integrity
Allowing travelers to view and challenge their scores
Limiting data retention to what is necessary for the stated purposes
Conducting regular audits to detect algorithmic bias
Operational Recommendations from Amicus International Consulting
Maintain Comprehensive Travel Logs — Keep boarding passes, visa copies, and accommodation receipts for at least five years.
Review Official Records Annually — Use the Privacy Act to request and verify CBSA records.
Document Legitimate Deviations — Provide written explanations for unusual travel before departure when possible.
Coordinate Corporate Travel — Avoid group travel patterns that may be misclassified as suspicious.
Use Legal Avenues for Corrections — File formal record correction requests promptly when errors are found.
The Road Ahead for the Entry/Exit Program
The evaluation phase is expected to run through 2026, with policy adjustments to follow. Key questions under review include whether travelers should have direct access to their risk scores, how to ensure fairness in algorithmic profiling, and what independent oversight should look like in practice.
For individuals, the increasing reliance on predictive risk modeling means that awareness and proactive management of one’s travel history are essential. For businesses, particularly those with mobile workforces, integrating border data awareness into compliance planning will soon be as critical as managing immigration status.
Conclusion
Canada’s Entry/Exit Program has evolved from a simple border record system into a cornerstone of travel risk assessment. Its expansion offers operational benefits for enforcement and policy planning, but also raises important questions about privacy, fairness, and transparency.
Amicus International Consulting advises that travelers and organizations alike adopt structured, lawful strategies for interacting with entry/exit systems, ensuring mobility while minimizing the impact of opaque risk algorithms. In an era where movement patterns significantly impact access, security, and opportunity, informed preparation serves as the best safeguard.
Contact Information
Phone: +1 (604) 200-5402
Email: [email protected]
Website: www.amicusint.ca
