Absolutely. I went through this process myself, trying to assist one particular family and trying to get help from UNHCR here in Islamabad. You go to the website, and it says you can't come to its office without an appointment. To get an appointment, you have to call a particular number. I called that number 29 times. Most of the time, it just rang and no one answered. Three times someone answered, and then hung up on me.
I'm a privileged white American lawyer who works for an NGO, so I tweeted about it, and somebody sent me a phone number of a friend who works at UNHCR. I was able to get an appointment that way, but that's not a route available to Afghans who come here and don't necessarily speak English or Urdu, and can't get a SIM card if they don't have a valid visa. It's impossible.
Another friend of mine was similarly trying to help a family get to the UNHCR, so they could register. She said she was calling the same number, and she got through the 258th time she called. That's a completely unworkable system that's set up to stop people from accessing it.
Absolutely, Canada should waive that requirement.