What do major study permit reforms mean for Alberta?

Dramatic changes to Canada’s International Student Program were announced on January 22, 2024.

The changes represent significant reforms designed to stabilize Canada’s International Student Program and remove some of the incentives that have driven explosive international student growth in certain provinces.

Effective immediately, Canada has introduced a two-year cap on the number of study permits that it would issue. For the next two years, Canada will cap the intake of study permit applications with the goal of only approving approximately 360,000 new study permit applications in 2024 (a decrease of 35% from 2023), with each province and territory receiving a portion of that cap weighted according to their provincial population. The new cap on study permits does not apply to students in master’s or doctoral level programs, or young people studying in elementary and secondary programs; it also does not affect current study permit holders.

Since individual provincial caps will be weighted by population, the new cap on study permits will have the greatest impact in provinces such as British Columbia and especially Ontario where a disproportionate number of international students have been recruited and drawn to in recent years.

In Alberta, where international student numbers have been relatively restrained compared to B.C. and Ontario, I don’t expect to see the number of international student approvals to be dramatically affected.

For context, not including study permits for students at the secondary level or lower, IRCC approved 319,260 study permits for students intending to start studying in Ontario in 2023; 99,785 for students intending to start studying in B.C.; and only 30,325 for students intending to start studying in Alberta.

While official figures and calculations have not yet been provided by IRCC, some back-of-the-napkin math can give an idea of what the provinces might expect when it comes to the number of international students that they will be able to welcome in 2024.

According to Statistics Canada’s 2023 Q4 population estimates, 11.7% of Canada’s population lives in Alberta, 13.8% lives in B.C., and 39% lives in Ontario. If the 360,000 approved study permit applications is weighted by population, Alberta might currently be projected to receive around 42,000 of those approval which would be more than the 30,324 approvals for 2023.

Conversely, Ontario might currently be projected to receive around 140,000 of those approvals, which would represent a massive decrease from the 319,260 study permit approvals for individuals studying in Ontario in 2023.

Interestingly, IRCC is allocating a portion of the cap to each of the provinces and territories and is letting the provincial and territorial governments administer the allocation of the cap to designated learning institutions in their province. Unless exempt from the application of the cap, a new applicant will need to first obtain a provincial/territorial attestation letter (a “PAL”) before submitting a study permit application. Provinces have been given until March 31, 2024, to establish their processes for issuing attestation letters to international students.

I think that it was a wise policy decision on IRCC’s part to force the provinces and territories to be accountable for the designated learning institutions that they approve and accredit to receive international students. Especially when it comes to private/for-profit institutions, the provinces must take greater responsibility for ensuring that standards are met and that international students aren’t being taken advantage of. Requiring provinces and territories to look themselves in the mirror and create their own processes for distributing their provincial study permit allotment will hopefully cause some provinces to take their duties of accrediting and overseeing private post-secondary institutions more seriously.

Other significant changes were introduced at the same time in order to further stabilize the number of study permit applicants.

Whereas international students studying in eligible undergraduate and college programs have thus far been able to obtain open work permits for their spouses; in the coming days, open work permits will only be available to spouses of international students who are studying in a master’s or doctoral program.

In addition, IRCC has determined that starting September 1, 2024, international students who begin a study program that is part of a curriculum licensing arrangement will no longer be able to obtain a post-graduation work permit when they have completed their studies. Curriculum licensing arrangements are quite common in Ontario where private for-profit colleges make arrangements with an affiliated public institution to deliver their curriculum from the public college – IRCC’s stated justification for the change was that “these programs have seen significant growth in attracting international students in recent years, though they have less oversight than public colleges and they act as a loophole with regards to post-graduation work permit eligibility”.

While curriculum licensing arrangements are not as common in Alberta, some do exist. For example, one private college based in Edmonton boasts on their website that through their affiliation with a publicly-funded Alberta college, international students can “earn a recognized credential that is eligible for a Post Graduate Work Permit.” Programs like this, taken through private colleges, will no longer be eligible for post-graduation work permits if they are started after September 2024.

The changes announced on January 22, 2024, complement additional study permit reforms that have been announced over the past three or four months. In all, I like the package of changes and think that they should help to restore some integrity to Canada’s international student permit program – especially in provinces like Ontario where the program was growing unchecked. Since Alberta has had relatively modest numbers of international students and curriculum licensing arrangements, my expectation is that the province’s public post-secondary education sector will emerge relatively unscathed.

Through these reforms, I hope that Canada’s post-secondary institutions can once again be destinations of choice because of the quality of education and experience that they offer and expect that in-turn Canadian society would benefit from the quality of student coming to Canada to study and then potentially making their lives here.

This article first appeared in the February 2024 edition of the Millwoods Mosaic – the Multicultural Voice of Southeast Edmonton (www.mwmosaic.ca) and is intended to provide general information only and should not be relied on as legal advice or opinion.  We invite you to contact one of the members of our experienced immigration group for assistance.

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