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Study Permit in Canada: Proposed IRCC Changes for DLI Transfers and New Permit Applications

Canada has long been one of the top destinations for international students. However, the study permit system is constantly evolving to strengthen regulatory control, prevent abuse, and maintain the quality of education for foreign students.

Recently, Immigration, Refugees and Citizenship Canada (IRCC) published a proposal in the official Canada Gazette introducing significant policy changes concerning study permits for students transferring between educational institutions (Designated Learning Institutions — DLI).

Below is a detailed explanation of the proposed initiative, potential impacts on students and institutions, financial and administrative aspects, as well as the anticipated implementation process.

Essence of the Proposed Changes by IRCC

According to the new proposal, which is currently at the public consultation stage:

  • Any international student wishing to transfer from one Designated Learning Institution (DLI) to another must submit a new study permit application before the start date of the program at the new institution;
  • Students will be allowed to remain in Canada and temporarily attend the new DLI without having an updated study permit, provided they comply with all other conditions of their existing permit.

The goal of this change is to enhance oversight over student mobility between DLIs, which are the only institutions authorized to enroll international students in Canada.

Why Such Regulation is Necessary

At present, DLIs fall under the jurisdiction of provincial and territorial authorities, and the federal government of Canada has no direct control over their internal policies, standards, or enforcement mechanisms. As a result:

  • There are gaps in tracking students who change their place of study;
  • Some students may leave a DLI without properly informing IRCC;
  • There is no unified system to verify the authenticity of Letters of Acceptance (LOA) from new institutions.

The proposed change aims to increase transparency, strengthen immigration control, and protect students from potentially unscrupulous educational institutions.

Potential Impact on Students

For international students, the proposal entails:

  • Additional financial costs: $150 CAD for each new application;
  • Time investment: approximately 30–45 minutes to prepare the new application;
  • Estimated administrative costs exceeding $55 million CAD over 10 years (discounted value);
  • Possible delays in processing applications, as IRCC anticipates a significant increase in workload, though internal resource reallocation is planned to mitigate delays.

The process may also introduce additional uncertainty and risks of academic disruptions for students planning to transfer between institutions.

Implications for Educational Institutions (DLI)

For DLIs, the proposed changes mean:

  • Increased administrative burden due to mandatory verification of Letters of Acceptance (LOA);
  • An estimated total cost of $4.8 million CAD over a 10-year period to implement these measures;
  • Initially, LOA verification is expected to take approximately 3 minutes per application, with a reduction to 30 seconds as staff become familiar with the process.

The changes could also affect the competitiveness of smaller private colleges that rely heavily on international students.

Will These Changes Be Implemented?

Currently, the proposed changes are undergoing a 30-day public consultation period, which includes input from:

  • Provincial and territorial ministries responsible for education and immigration;
  • National education associations and DLI organizations;
  • Student representative groups.

Since fall 2022, IRCC has been conducting a series of consultations to update international student program policies. Many previously proposed policies have already been implemented. Given this trend, the likelihood of these specific changes — requiring new study permits when changing DLIs — being adopted remains high.

IRCC is expected to make a final decision after the consultation period ends on July 29, 2024.

Conclusion

The proposed changes to Canada’s study permit policy are part of a broader federal initiative to enhance transparency, combat fraud in the education sector, and strengthen control over migration flows.

However, for students, this means additional financial and administrative obligations, along with the risk of academic disruptions if documents are not properly or timely prepared.

We strongly recommend that all students:

  • Stay informed of updates from IRCC;
  • Plan any transfer between institutions well in advance, considering the need to submit a new study permit application;
  • Consult with immigration professionals to ensure proper document preparation and compliance with all conditions of their stay in Canada.

For personalized assistance regarding adapting to new rules, reviewing academic plans, or support with submitting applications to IRCC, professional advice is available.

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