Reviewing student enrolment status reporting by DLIs

These instructions will provide guidance related to student enrolment status data collected during the twice-yearly DLI reported compliance exercises, and how to find and interpret this information to inform decision-making.

Please note: As of November 8, 2024, submitting a compliance report has become mandatory under R222.1(1)(b). For more information, see Conditions on DLIs.

On this page

• International Student Compliance Regime (ISCR)
  • Who is subject to the International Student Compliance Regime
  • Student compliance reporting by post-secondary Designated Learning Institutions
    • Compliance reporting verification results: Adverse vs. Non-adverse enrolment statuses
  • Important considerations for interpreting compliance data
    • Applying compliance results to application processing
    • Study Permit (SP) holders changing Designated Learning Institutions (DLIs)

International Student Compliance Regime (ISCR)

Since 2016, a compliance process has been in place to monitor the enrolment status of study permit holders studying at a post-secondary designated learning institution (DLI) in Canada (excluding Nunavut). The ISCR is a monitoring regime that collects enrolment statuses from DLIs. This allows IRCC to identify individuals who may no longer be enrolled or actively pursuing their studies, which are both conditions of their study permit per subsection R220.1(1) of the Immigration and Refugee Protection Regulations (IRPR).

By assessing study permit conditions, non-compliance may be confirmed during processing of a subsequent application, entry to Canada or through follow-up verifications, followed by enforcement action against those confirmed to be non-compliant. Reporting a student as having a compliant enrolment status would indicate that the student is actively pursuing their studies; however, this compliant status would also need to be verified.

Who is subject to the International Student Compliance Regime (ISCR)

Per subsection 220.1(1) of the IRPR, study permit holders in Canada (with the exception of those described under R220.1(3)) are subject to both of the following conditions:

• They shall enroll at the designated learning institution that is named in their permit and remain enrolled there until they complete their studies.
• They shall actively pursue their course or program of study.

This means that study permit holders in Canada must make reasonable progress toward completing their program of study.

Study permit holders included in the scope of the ISCR are those who

• are currently studying at the post-secondary level at a Canadian DLI
• are enrolled in a program of study of at least 6 months in duration

Study permit holders excluded from the scope of the ISCR include

• all students at the primary and secondary level
• study permit holders who are exempted from both the requirement to enrol and remain enrolled at a designated learning institution until they complete their studies, and to actively pursue their course or program of study under subsection R220.1(1), including
  • persons described in any of paragraphs R300(2)(a) to (i) (for example, a refugee claimant [and their family members] who made a claim that has not yet been decided on),
    or
  • family members of a foreign national who resides in Canada and is described in any of paragraphs R215(2)(a) to (i) (for example, a family member of a foreign national who is subject to an unenforceable removal order)

Student compliance reporting by post-secondary Designated Learning Institutions

IRCC sends each DLI a request to complete a compliance report through the DLI Portal twice a year. The compliance report is a list of all foreign nationals with an active study permit associated with their DLI number in GCMS. On the first day of the reporting period, the list is automatically generated in GCMS and sent to DLIs through IRCC’s DLI Portal. DLI representatives can access their report by logging into their DLI Portal account.

The compliance reporting periods occur during fixed 60-day periods in the Spring and Fall:

• March 1 to April 30
• November 1 to December 30

DLIs must select an enrollment status for each study permit holder that appears on their compliance report. They have 60 days to complete the report and submit it to IRCC.

Compliance reporting verification results: Adverse vs. Non-adverse enrolment statuses

A full list of definitions for each enrolment status may be found at Designated Learning Institution Portal: Compliance Reporting. Adverse verification results indicate that the DLI has reported on the study permit holder with an enrolment status which indicates the SP holder may not be enrolled or actively pursuing their studies.

No adverse indicates the DLI has reported on the study permit holder with an enrolment status indicating the international student is enrolled and actively pursuing their studies.

An adverse verification result is an indicator of potential non-compliance; however, procedural fairness principles must be followed to confirm SP holder non-compliance. The enrolment data collected may be used for post-reporting investigations to verify a student’s compliance. Officers can proceed with an interview or request more information (e.g., transcripts, completion letters, etc.) as required to make a decision.

Enrolment Statuses considered non-adverse:

• Academic break
• Authorized Leave
• Deferred Enrolment
• Full-time Studies
• Not started
• Part-time Studies
• Program or Degree Completed

Enrolment Statuses considered adverse:

• Academic suspension
• No longer registered or enrolled
• No show
• Unknown or no record

Important considerations for interpreting compliance data

The enrolment statuses of international students are reported to IRCC twice yearly via compliance reports submitted by the DLI with which the SP application is associated. However, the information should only be considered an indication of compliance or non-compliance.

Procedural fairness must be undertaken if the information is used to inform an adverse final decision.

Compliance investigations are currently taking place on a small portion of potentially non-compliant international students. A study permit holder is provided a procedural fairness opportunity when IRCC requests additional evidence of their studies per subsection R220.1(4). See Study permits: Assessing study permit conditions.

If investigations confirm students are non-compliant, enforcement action is taken if students are found non-compliant following procedural fairness. In addition, IRM analyzes compliance investigation results to identify possible risk trends to assist with future processing activities.

Applying compliance results to application processing

The primary objective of collecting enrolment data is to monitor student compliance in alignment with the conditions of the study permit, and to identify potentially non-compliant study permit holders. Students who have been reported with an adverse status are considered to be potentially non-compliant until post-reporting verifications occur, the process of procedural fairness is followed, and non-compliance is confirmed. However, processing officers may leverage the compliance data to determine if additional documentation to show proof of study should be requested from the client. Regular protocols that are currently in place should be followed in verifying student non-compliance.

Study Permit (SP) holders changing Designated Learning Institutions (DLIs)

Due to regulatory amendments implemented November 8, 2024, students need to apply for a new study permit to change DLIs at the post-secondary level.

Before November 8, 2024 study permits were not restricted to a specific DLI, and SP holders could change schools without needing to apply for a new study permit. Students were expected to inform IRCC of the change in DLI by updating their IRCC MyAccount. Students who failed to inform IRCC of a change in DLI remained associated with their previous DLI in GCMS, and were likely reported with an adverse status.

For more information and how to assess this condition in cases of study permits issued prior to and as of the coming-into-force of these regulations, please refer to Study permits: Assessing study permit conditions.