CIMM – Fraud – October 30, 2025

Key Messages

• Immigration, Refugees and Citizenship Canada (IRCC) has a multi-layered approach to prevent, detect, and address fraud in immigration applications.
• This approach targets fraud in individual applications as well as coordinated fraud schemes to prevent systemic abuse within immigration and citizenship programs, and hold bad actors accountable.
• IRCC actively targets organized and coordinated fraud schemes through its administrative investigations and undertakes fraud disruption techniques in collaboration with the Canada Border Services Agency (CBSA), who is responsible for pursuing enforcement action related to foreign nationals in Canada.

Key Facts And Figures

• Between January and August 2025, IRCC approved 86,100 study permit applications compared to 209,200 in the same period in 2024 (decrease of 59%).

International Student Fraud

• IRCC has taken actions over the last several years to strengthen the integrity of the International Student Program (ISP) and deploy a multi-layered approach to prevent, detect, and address fraud in study permit applications.
• When it comes to fraud, IRCC is primarily focused on two issues: (1) identifying organizers of coordinated fraud and (2) individuals who knowingly commit fraud or attempt to deceive IRCC.

Study Permit Refusal

• Recent figures show that the refusal rate for study permit applications has increased to 58% between January and August 2025, compared to 48% in the same period in 2024.
• The total percentage of refusals for misrepresentation reasons has increased since 2023:
  • January to August 2025: 2.0%
  • January to August 2024: 1.9%
  • January to August 2023: 1.5%
• A combination of recent program reforms, and an enhanced focus on program integrity is increasing refusal rates. However, rates are expected to stabilize over time as prospective students and institutions adapt to the updated requirements, and non-genuine students are disincentivized from accessing the ISP.

Program Integrity Improvements

Regulatory amendments

• In addition to addressing unsustainable growth, the government has also introduced a number of integrity measures to strengthen the integrity of the international student program and to better protect students:
  • Setting a 24 hours per week limit international student can work off campus each week;
  • Requiring international students to attend the Designated Learning Institutions named on their permit. Students wishing to change learning institutions need to apply for and be approved for a new study permit;
  • Introducing consequences for DLIs that do not comply with reporting requirements and Letter of Acceptance verification procedures.

If pressed…

• Since December 2023, IRCC verifies Letters of Acceptance (LOA) directly with Designated Learning Institutions (DLIs) before issuing a study permit. This helps ensure only genuine students are approved.
  • In 2024, over 650,000 LOAs were verified. About 14,000 were flagged as “no-match”, i.e., not matching school records, prompting further review by officers.
    • All “no match” cases are further reviewed by an officer before a decision is made on the application.
    • In 2024, about 25% of “no match” cases were resolved as the applicant was able to produce a verifiable LOA through the procedural fairness process. In many cases, the initial “no match” was the result of applicant or DLI error.
    • The remainder of “no match” cases in 2024 were either withdrawn or refused, thereby preventing these applicants from entering Canada as students.
• Fewer LOA verifications in 2025 are producing “no-match” results than last year (1.3% compared to 2.2%).
• This suggests the system is not only catching fraud but may also be deterring it.

International Student Compliance Regime (ISCR)

• The ISCR was launched in 2014 to help identify students who may not be genuinely studying and to track trends in student compliance.
• DLIs report twice a year on whether international students are actively enrolled and studying.
• If a student is flagged as non-compliant, it can affect future immigration applications and may lead to enforcement action.
• In spring 2025, 655 out of 709 DLIs (93%) answered IRCC’s request to report on the enrolment status of 605,810 international students:
  • 93% of schools responded to IRCC’s request for data.
  • 91% of students were reported as likely compliant.
  • Around 47,000 (8%) were flagged as potentially non-compliant.
  • 1% had no data reported.
• IRCC is working with the Province of Quebec to onboard the DLIs in Quebec to the ISCR and include enrolment status of international students in Quebec.

If pressed on possible non-compliance of the 47,000:

• The number of 47,000 potentially non-compliant students is prepared based on initial compliance reporting from the respective DLIs, and does not constitute confirmed non-compliance. A verification must be completed to determine non-compliance.
  • The enrolment statuses should only be considered an indication of potential compliance or non-compliance.
  • IRCC must still verify the study permit holders’ statuses, and procedural fairness may be undertaken to inform a final decision. Depending on the outcomes, the student may be subject to enforcement action.
• Once reporting of enrolment status is received, IRCC analyzes the set of students who are reported as potentially being non-compliant.
  • Procedural fairness (PF) is offered to all students who are suspected of being potentially non-compliant. Upon completion of the PF process, a student confirmed to be non-compliant is flagged in IRCC’s systems. This may inform future applications the student submits or notify border officers if the student attempts to re-enter Canada.
  • The CBSA may place removal orders on individuals who are found to no longer be admissible to Canada.
• IRCC is working with the Province of Quebec to onboard the DLIs in Quebec to the International Student Compliance Regime and include enrolment status of international students in Quebec.

DLI Compliance Regime

• DLIs must actively report to IRCC, including verifying LOAs and confirming students are studying.
• The new regulations impose consequences, including suspension of processing of associated study permit applications for certain DLIs, if those DLIs fail to comply with the reporting requirement.
• IRCC conducts verification activities when a DLI is non-responsive, or suspected of providing inaccurate information, improperly issuing LOAs, or failing to comply with departmental requests for student information.
• The process is fair and evidence-based. DLIs can respond before any decision is made. Outcomes range from guidance to suspension of DLI status for up to a year.
• This enhanced process will launch this fall, with findings available in spring 2026.

Organized Crime and Other Public Investigations

• Canada maintains a zero-tolerance approach to fraud and organized crime. Under the Immigration and Refugee Protection Act, individuals convicted of serious crimes are inadmissible and may lose their immigration status, with the CBSA empowered to enforce removal orders.
• IRCC collaborates with the CBSA, the Royal Canadian Mounted Police (RCMP), and international partners to detect and disrupt organized crime while raising public awareness to encourage reporting of suspicious activity.
• IRCC has been monitoring recent fraud concerns related to recent media coverage in Quebec. IRCC takes a firm stance against abuses of our programs. When information is uncovered, it is shared with our partners such as CBSA and RCMP to take enforcement action. We are also able to flag cases to our processing offices to prevent further abuse and disrupt the activities of these criminals.
• Permanent and temporary residents who are convicted of criminal offenses may be inadmissible to Canada and subject to removal. Business owners participating in illegal activity may also be charged with criminal offences.

Misuse of the Temporary Foreign Worker Program

• The Temporary Foreign Worker Program (TFWP) allows employers to fill short term, temporary labour market gaps when Canadians and permanent residents are not available. The Program is jointly administrated by Employment and Social Development Canada (ESDC) and IRCC with the support of CBSA. Questions related to misuse or fraud under the TFWP program should be directed to ESDC.
• Canadian employers who want to hire a temporary foreign worker under the TFWP must submit and obtain a positive Labour Market Impact Assessment (LMIA) through ESDC. ESDC assesses LMIA requests received and makes an assessment on the genuineness of the employer and on the impact these temporary foreign workers would have on the Canadian labour market. IRCC reviews and processes the work application submitted by the temporary foreign workers by assessing whether applicants meet admissibility (health, criminality, and security), eligibility and regulatory requirements necessary for work permit issuance, including the genuineness of the job offer.
• LMIA misuse is a principal concern for the Temporary Foreign Worker Program (TFWP) and refers to the buying and selling of LMIA applications, as well as the unethical recruitment and exploitation of vulnerable foreign nationals for personal and financial gain. LMIA misuse can be carried out by employers, third parties and/or temporary foreign workers including stakeholders overseas.
• ESDC has a number of tools already in place to mitigate risks linked to program misuse, including:
  • an enhanced LMIA assessment employers and/or sectors identified as high-risk for LMIA fraud to ensure their business operations and employment needs are genuine;
  • tightening documentation requirements to prove their business legitimacy;
  • increased administrative monetary penalties (AMP) for non-responsive employers when it is determined through an inspection that the business does not exist or if they appear to be engaging in LMIA misuse, from $15,000 to up to $45,000 with a 5-year program ban, and applied to every position on the LMIA instead of one single penalty;
  • increased use of Ministerial Instructions to suspend positive LMIAs (e.g., in cases of suspected program misuse, and/or when there is serious risk to the worker’s health and safety)—work permit applications associated with suspended LMIAs are also suspended until ESDC has either lifted the suspension or revoked the LMIA;
  • suspending and/or revoking previously approved LMIA positions where there is reason to suspect program misuse, at an earlier stage in the inspection process. This prevents employers from hiring additional workers until the situation is resolved or until the inspection is completed.
• While LMIA misuse is primarily addressed by ESDC, IRCC also addresses this issue by:
  • training officers to detect misuse when assessing the genuineness of a job offer prior to issuing a work permit;
  • participating in domestic and international outreach with a focus on advancing ethical recruitment practices;
  • maintaining dedicated web pages on LMIA Fraud on IRCC websites;
  • implementing a new temporary measure making it so Express Entry candidates no longer receive additional points for having a job offer. This temporary measure, instituted in Spring 2025, will reduce fraud by removing the incentive to illegally buy or sell labour market impact assessments to improve a candidate’s chances of being selected to come to Canada as a permanent resident.
• Canadian employers hiring foreign workers on employer-specific work permits under both the IMP and the TFWP are subject to an employer compliance regime to promote safe and fair working conditions for foreign workers, to help prevent program misuse, and to ensure that they comply with the conditions imposed under the Immigration and Refugee Protection Regulations (IRPR).
• Employer compliance inspections under the IMP are conducted by IRCC, whereas inspections under the TFWP are conducted by ESDC.
• Under both programs, should an employer be found non-compliant following an inspection, they may be subject to a warning, an Administrative Monetary Penalty (AMP), or a ban from the Program. The AMP amount and the length of the ban are determined based on several factors, including the type or classification of the condition, any past history of non-compliance, and the severity of the violation. All employers found non-compliant who have received an AMP and/or a ban under either program are listed on a public website.
• To support workers, Service Canada offers a confidential tip line, available 24/7. Live agents are available in 200 languages. Concerns can also be reported anonymously through an online reporting tool. Workers are encouraged to report any concerns about unsafe conditions and protections are in place to help ensure workers can speak up without fear of reprisal.
• Instances of suspected criminal activity, including fraud, are referred to the appropriate authorities including the CBSA, RCMP or local police force.

Updated Regulations to Address Misconduct by People who are Paid for Representation or Advice

College of Immigration and Citizenship Consultants Regulations

• The government established the College of Immigration and Citizenship Consultants in 2021 to regulate immigration and citizenship consultants and protect the public from fraud.
• The College is an important part of the government’s efforts to fight fraud in Canada’s immigration system. IRCC maintains oversight to ensure the College fulfills its mandate to protect the public and strengthen the integrity of the immigration and citizenship consultants’ industry.
• New regulations are being introduced to strengthen how the College operates. These include:
  • Clear rules for how the College handles complaints, investigations, and its public register.
  • Guidelines for managing a compensation fund for victims of unethical consultants.
  • Clarifying the Minister’s authority to step in if the College’s board fails to meet its obligations.
• These draft regulations were published in December 2024 for public feedback. They are expected to come into force in spring 2026.

Administrative Penalties and Consequences Regime

• The Government of Canada is introducing a new system called the Administrative Penalties and Consequences regime. This system is being added to immigration and citizenship system to help protect people from fraud and unauthorized advice.
• The new regime allows IRCC to issue monetary penalties to people who give immigration or citizenship advice or representation without proper authorization, or who encourage others to lie or misrepresent information. In addition to monetary penalties, IRCC will be able to publish the names of those who break these rules.
• IRCC will also be able to inspect records and request documents from anyone offering paid services—whether authorized professionals or unauthorized individuals, in Canada or abroad.
• Penalties are issued per application, meaning repeat violations can lead to multiple fines. Individuals can request a review of any penalty by an independent reviewer.
• Fines range from:
  • $5,000 per case of unauthorized practice;
  • $15,000 per case of encouraging misrepresentation;
  • Up to $1.5M in total penalties.
• The proposed changes were published in the Canada Gazette on December 21, 2024, with a 45-day public consultation with the final rules expected to come into effect later in 2025 or early 2026.