Sorry, but one word is insufficient.
Nonetheless, in response "YES"
I telephoned CIRA yesterday, and ran this scenario past the CSR (which actually is happening).
Previously, I could transfer away a domain that was suspended for 29 day, 23 hours, and 59 minutes, by paying for my order, logging into CIRA and clicking my consent.
DONE.
ABSOLUTELY NO INVOLVEMENT WITH THE LOSING REGISTRAR, which is the way it should be.
Now, I have a domain 8 days from suspension (and fortunately I started the process now, and not in 7 days), at a little registrar.
I asked yesterday for the EPP key - no reply as of yet.
I phone the CIRA CSR if this scenario is correct:
The registrar has FIVE DAYS to send you the EPP key.
With the key, you request a transfer. The transfer fails. You do not know why.
It turns out that the losing registrar has "locked" your domain without your knowledge, which prevents transfers.
CIRA has no policy on domain locking, nor on informing the registrant of domain locking, NOR OF TIMEFRAME FOR DOMAIN UNLOCKING.
CIRA has no policy on registrar responding to support inquiries.
At some point, you involve CIRA to order the domain unlocked.
NOW, you can request A NEW EPP Key (they are only valid for 5 days), and the registrar has a fresh FIVE DAYS to send you the EPP Key.
You calculate the time to get it transferred, never mind the insane amount of time and work to get your domain freed.
This is CIRA's idea of "improved customer experience", "now easier for Canadians to register and maintain their .CA domain names."
I have NEVER been more DISGUSTED with outright $&%$*&%.