CIMM – International Student Compliance Regime – October 24, 2023

Key Facts and Figures

• In 2014, IRCC implemented an international student compliance regime as an integrity tool to identify potentially non-genuine students and to gather additional data and trends on international students in Canada.
• Designated Learning Institutions (DLIs) participate in twice-yearly compliance reporting exercises where they are required to report to IRCC on the enrollment status of their international students.
• In the Spring of 2023, 661 out of 709 DLIs (93%) answered IRCC’s request to report on the enrolment status of 558,197 international students. The data shows that 91% (509,164) of the international students were reported on as potentially compliant, while 33,266 (6%) were reported on as potentially non-compliant and 15,767 (3%) were not reported on at all.

Key Messages

• IRCC has different measures to enforce program integrity and is continuously seeking to improve the integrity of it programs through new initiatives.
• The international student compliance regime is designed to uncover potential fraud, fraud trends, international student movement, non bona fide students and questionable institutions.
• Data collected from these reporting exercises is critical to monitoring the success of the international student program, and gives IRCC insight into whether or not international students are compliant with their study permit conditions, to actively pursue their studies.
• IRCC investigates students who have been reported as potentially non-compliant. A non-compliant status can have implications to any future applications a student may make to IRCC (such as post-grad work permit, study permit extensions, other temporary and permanent visas). Those who are confirmed to be non-compliant with their study permit conditions may be subject to enforcement action, which could result in the issuance of a removal order.
• Two important upcoming initiatives will supplement the current compliance regime:
  • IRCC is working to implement an enhanced letter of acceptance verification process that will have all letters of acceptance validated by DLIs .
  • IRCC is working with DLIs, provinces and territories, and national education associations to develop and adopt a ‘recognized’ or ‘trusted’ institution model that would identify designated learning institutions that provide top-quality support and learning experiences for the international students they welcome to Canada.
• The department is also developing a Letter Of Acceptance (LOA) verification tool which will require post-secondary DLIs to verify the authenticity of LOAs submitted for their DLI, before study permits are assessed. This will mitigate fraud. IRCC will be implementing this LOA verification solution in December 2023 for all post-secondary Designated Learning Institutions (DLIs).
• IRCC provides information and resources on its website to help prospective applicants abroad avoid becoming a victim of fraud. IRCC also launches targeted campaigns when they are warranted, such as the 2023 advertising campaign launched in India
• A broad review of the International Student Program is also underway. IRCC has engaged with provincial and territorial ministries of education and immigration to discuss potential measures to strengthen program integrity and enhance protections to address student vulnerability, unethical recruitment and non-genuine actors in the program. These consultations concluded on June 7, 2023 and IRCC is currently incorporating the written feedback received from provinces and territories into options to the Minister.

Supplementary Information

• Non-compliant students:
  • Individuals identified by a DLI as potentially non-compliant can be referred to the Canada Border Services Agency for enforcement action following an investigation by IRCC.
  • When non-compliance is suspected, the information is added to the individual’s file and may be taken into consideration on any subsequent immigration application decisions.
• Unscrupulous/bad actors:
  • IRCC is very concerned about unscrupulous actors and unethical recruiters who seek to take advantage of students to gain large commission fees, or to involve international students in illegal human movement for criminal gains.
  • IRCC is committed to working closely with provinces and territories to disrupt these networks and protect vulnerable individuals from exploitation.
  • When it comes to cases of fraud, we are focused on identifying culprits, not penalizing victims. Victims of fraud will always have an opportunity to demonstrate their situation and present evidence to support their case.
• International Student Compliance Regime
  • The designation and de-designation of post-secondary schools to host international students is carried out by the provinces and territories (PTs). IRCC does not oversee DLI programming and recruitment practices and does not have the authority to de-designate DLIs engaged in fraudulent activities.
    • IRCC currently has no mechanism to take action against DLIs who do not submit their report because education. After reporting is completed, IRCC currently works with PTs so that DLIs who did not submit their report to IRCC are known to them.
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