Immigration Refugees and Citizenship Canada (IRCC) has announced proposed changes to Canada’s international student program, including the requirement for international students to apply for a new study permit when switching their Designated Learning Institution (DLI). DLIs are the only schools in Canada approved to accept international students and must follow IRCC’s regulations. The federal government cannot ensure individual institutions are compliant with new admissions regulations.
IRCC is proposing the following changes for international students who want to change schools in Canada:
- Students who want to switch Designated Learning Institutions (DLIs) must apply for a new study permit before starting their new program.
- Students will be allowed to attend the new DLI without a valid study permit until a decision is made on their application, as long as they stay in Canada and adhere to all conditions of their current study permit.
IRCC’s proposal includes an impact assessment, detailing the costs and benefits for various stakeholders affected by the policy. Key impacts on international students and DLIs are highlighted below:
For international students:
- There is a financial cost of $150 per new application and a time investment of 30 to 45 minutes per application preparation. The total costs are estimated at $55.5 million Present Value (PV) over “10 periods of 12 months.”
- Processing times may become longer due to the influx of applications, although IRCC plans to mitigate this by reallocating resources.
- The administrative burden and uncertainty associated with the new requirement could disrupt students’ academic plans.
For DLIs:
- DLIs will incur compliance and administrative costs related to verifying Letters of Acceptance (LOAs), which are crucial for the new study permit application process. The total estimated cost is $4.8 million PV over 10 periods.
- Initially, LOA verification is expected to take three minutes per application, but this is projected to decrease to 30 seconds as institutions become more familiar with the process.
Will these changes be adopted?
While it is impossible to predict with certainty whether IRCC will implement the proposed changes or to what extent they will be adopted, historical trends offer some insight.
The proposed changes regarding the new study permit requirement are currently in a 30-day “consultation” phase. Since fall 2022, IRCC has consulted on various policies aimed at enhancing the International Student Program. These consultations included input from provincial and territorial ministries responsible for immigration and education, national education associations, individual DLIs, and student representative organizations. Many policies that were previously in consultation have since been implemented.
For instance, a policy focus was the LOA verification process. Feedback from provincial and territorial representatives and national education associations highlighted the success of current ministerial instructions requiring LOA verification and suggested further leveraging this process to share information and reduce fraud. These suggestions were adopted on December 1, 2023.
The current changes to study permit requirements will be in consultation until July 29, 2024. After this period, IRCC will consider the feedback received and decide on the next policy steps accordingly.
