IRCC may require students to reapply for permits if they change schools

A recent announcement by Immigration, Refugees, and Citizenship Canada (IRCC) in the Canadian Gazette has sparked significant interest due to proposed changes to the international student program in Canada. One of the most notable suggestions is that international students who wish to transfer to a different Designated Learning Institution (DLI) must apply for a new study permit. DLIs are specific schools in Canada authorized to accept international students and are required to follow IRCC regulations.

Currently, DLIs operate under provincial jurisdiction and must adhere to provincial regulations. The federal government, however, lacks the means to ensure compliance with new admissions regulations at individual institutions.

According to the IRCC release, the proposed changes include:

1. Students who want to switch DLIs must apply for a new study permit before starting their new program.
2. Students can 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 comply with all other conditions of their current study permit.

The proposal includes an impact assessment that outlines the costs and benefits for various stakeholders. For international students, the financial cost of applying for a new permit is $150 per application, with an estimated preparation time of 30 to 45 minutes. This could lead to a total cost of $55.5 million over ten years. Additionally, the influx of applications might lengthen processing times, although IRCC plans to reallocate resources to manage this. The administrative burden and uncertainty might also disrupt students' academic plans.

DLIs will face compliance and administrative costs related to verifying Letters of Acceptance (LOAs), which are crucial for the new study permit applications. The estimated cost for this verification process is $4.8 million over ten years. Initially, LOA verification is expected to take about three minutes per application, but this is projected to decrease to 30 seconds as institutions become more familiar with the process.

It is uncertain whether IRCC will implement these proposed changes or to what extent. Currently, the proposals are in a 30-day consultation phase. Since fall 2022, IRCC has consulted various stakeholders, including provincial and territorial ministries, national education associations, DLIs, and student representative organizations. Many policies that were previously in consultation have since been adopted.

For instance, feedback on the LOA verification process led to its adoption on December 1, 2023. The current study permit changes will be in consultation until July 29, 2024, after which IRCC will review the feedback and decide on the next steps.