IRCC proposes amendments that require students to re-apply for a study permit if they change schools in Canada

A recent Immigration Refugees and Citizenship Canada (IRCC) announcement in the Canadian Gazette by has attracted interest due to some proposed changes to Canada’s international student program.

Of particular note among the proposed changes is IRCC’s suggestion that international students who wish to change their Designated Learning Institution (DLI) in Canada must apply for a new study permit. DLIs are the only schools in Canada that are approved to accept international students, and as such must follow the regulations set out by IRCC.

DLIs are currently under provincial jurisdiction and subject to provincial regulations. The federal government has no way to ensure that individual institutions are compliant with new admissions regulations.

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What is IRCC proposing for international students looking to change schools in Canada?

Per the release IRCC is proposing (among other changes) that:

• Students who wish to switch DLIs must submit an application for a new study permit before the start date of the new program; and
• Students will be able to attend the new DLI without a valid study permit until a decision is made on the application, provided they remain in Canada and comply with all other conditions of their current study permit.

How might this impact international students in Canada?

IRCC’s proposal included an impact assessment, outlining the costs and benefits to the different stakeholders that would be effected by the policy. Of note when considering the above policy, are the impacts on both international students and DLIs .

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 , with total costs estimated at $55.5 million Present Value (PV) over “10 periods of 12 months”. Additionally, processing times may get longer due to the influx of applications, though IRCC plans to mitigate this by reallocating resources. The administrative burden and uncertainty associated with the new requirement could disrupt students' academic plans

On the other hand, DLIs will face compliance and administrative costs related to verifying Letters of Acceptance (LOAs)—a key part of the new study permit application process—with a total estimated cost of $4.8 million PV over 10 periods. Initially, LOA verification is expected to take three minutes per application, decreasing to 30 seconds as institutions become familiar with the process.

Will these changes be adopted?

While it is impossible to say with certainty whether IRCC will implement the changes proposed, or to what degree these changes are adopted, history can give us some indication of what may happen.

Currently proposed changes around the new study permit requirement are in a 30-day “consultation” phase. Since fall 2022, IRCC has consulted on several specific policies aimed at improving the International Student Program. These consultations included provincial and territorial ministries responsible for immigration and education, national education associations, individual DLIs, and student representative organizations. Many policies that previously were in consultation have since been adopted.

For example, one policy focus was the LOA verification process itself. Provincial and territorial representatives and national education associations provided feedback on the success of current ministerial instructions requiring LOA verification and suggested further leveraging this process to share information and reduce fraud. These changes were later adopted on December 1st 2023.

The current changes to study permit requirements will be in consultation until July 29th, 2024, after which IRCC will consider feedback and decide on next policy steps accordingly.

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