Issues

Under the existing Immigration and Refugee Protection Regulations (IRPR), Immigration, Refugees and Citizenship Canada (IRCC) and the provinces and territories share responsibility for international students. Under Memoranda of Understanding (MOUs), provinces and territories (PTs) establish the minimum common standards with IRCC for designating educational institutions, called designated learning institutions (DLIs) that are allowed to receive international students, and to remove designation status where applicable. IRCC is responsible for processing study permit applications for international students who have been accepted to attend a DLI.

Three issues have been identified that impact program integrity

• Under the existing regulations, the federal Government does not have the regulatory authority to compel reporting from DLIs as part of the compliance program and letter of acceptance verification system. Where DLIs are not reporting, IRCC does not have a reliable way of determining whether a student is attending the DLI and complying with their study permit requirements, and IRCC cannot effectively detect fraudulent letters of acceptance.
• Currently, IRCC cannot impose conditions on a non-compliant DLI, such as the suspension of study permit processing. This means that IRCC is required to issue study permits for students attending the DLI even when the DLI is not reporting to IRCC on student enrollment status or participating in the letter of acceptance verification system.
• Under the current regulations, IRCC cannot compel international students to notify the Department if they change DLIs. As a result, IRCC is unable in many cases to confirm student attendance and study permit compliance when a student changes DLIs. When students move between institutions without notification, this risks circumventing the study permit cap which has a negative effect on DLIs.

The IRPR also limits the number of hours eligible international students may work off campus without a work permit to 20 hours per week during regular academic sessions. International students and some stakeholders have indicated that 20 hours of work per week is not sufficient to keep up with the cost of living in Canada.

Background

The administration of the International Student Program (ISP) is a shared responsibility between IRCC and Provinces and Territories (PTs). For its part, IRCC is responsible for setting policy regarding the entry of international students, establishing the conditions study permit holders must meet while in Canada, and deciding whether a study permit should be issued to an applicant.

For DLIs to receive international students to study in Canada, they must be designated by the province or territory based on a set of standards embedded in the MOUs with each PT. PTs also set their own standards that DLIs must meet in order to be designated by their jurisdiction. PTs inform IRCC when institutions need to be added or removed from the public DLI list, which enumerates the institutions who are allowed to receive students within a given province or territory. Quebec currently designates its own DLIs as per its own regulations, therefore the province is exempted from the requirement to enter into an MOU with IRCC.

In 2023, Canada welcomed an all-time high number of international students, with approximately 1 040 000 primary, secondary, and post-secondary study permit holders, up 151% from 352 305 study permit holders in 2015. In 2023, the Department received 914 405 applications for new study permits, compared to 713 775 in 2022, which represents a 28% increase. This spike in demand can be attributed to a number of factors, including greater interest to come study, and then potentially work, in Canada, as well as increased promotion and marketing activities to identify Canada as a choice destination for pursuing post-secondary studies.

Under existing regulations, international students may change their DLI at any given time, but IRCC recommends that they inform the Department through a secure portal. This is an administrative practice and currently it cannot be enforced. International students that switch DLIs without notification, could be reported for non-attendance at their original DLI and could be found non-compliant with their permit conditions, which could negatively impact their ability to obtain a subsequent study permit. It is in the collective interest of clients, DLIs and levels of government, to have mandatory and accurate information on the student’s current DLI.

Since 2014, students who meet certain criteria as specified by the regulations have been authorized to work 20 hours off campus without a work permit. Starting in November 2022, the Minister of Citizenship and Immigration issued a series of public policies, which included waiving the 20 hour per week limit for eligible post-secondary students. The public policies were intended as a temporary measure to fill post-pandemic labour market needs, as international students are primarily admitted to Canada to study, not to work. These public policies expired on April 30, 2024. However, there is a need to reassess the appropriate balance between the need some students have to work for supplementary income while respecting the purpose of a study permit, ensuring academic outcomes of the student and remaining consistent with other like-minded countries that have limits on work hours for international students. For example, the UK, New Zealand, and Ireland allow certain students to work up to 20 hours per week, while Australia changed its work hours limit in 2023 to 48 hours every two weeks. A review of these factors has led to the proposal to moderately increase work hours to a maximum of 24 hours.

Objective

The main objective of the proposed amendments is to provide IRCC with the appropriate tools to ensure that study permits are issued to those who will be attending genuine DLIs that comply with both federal and provincial requirements and to verify that students are complying with their study permit conditions. Additionally, IRCC requires the proper means to take action against DLIs who fail to comply with the proposed regulations.

Finally, the proposed amendments also seek to allow international students to work four additional hours off campus, raising the maximum to 24 hours per week, to help offset the cost of living in Canada.

Description

The proposed regulatory amendments apply exclusively to post-secondary DLIs and post-secondary international students. Any reference to DLIs in this document refers to institutions at the post-secondary level only.

Conditions on DLIs

The proposed regulations would require that post-secondary DLIs comply with the following conditions, using the electronic means specified by the Minister:

• confirm, within 10 days of a request from the Minister, that a student has been accepted to undertake a program of study indicated on the study permit application;
• submit a compliance report, within 60 days of a request from the Minister, about the enrollment status of each student who has been accepted to that institution and an indication of whether they are actively pursuing their course or program of study;
• within 10 days of a request from the Minister, correct or provide additional information to the information in a compliance report; and,
• within 10 days of a request from the Minister, provide any further information that the Minister requires, such as information related to study permits or study permit applications that name the DLI.

The proposed regulations allow the Minister, based on their own initiative or at the request of the DLI, to extend the time provided so that the institution can confirm, provide information, or provide a report, if the Minister determines that

• The DLI’s confirmation of the acceptance of a student has been impeded by infrastructure failure, such as power or communications, a natural disaster, a public health emergency, or a labour dispute; or
• the DLI’s provision of information under any other condition has been impeded by exceptional circumstances.

Verification of DLI compliance with conditions

The proposed regulations would allow an IRCC officer to verify a DLI’s compliance with the conditions if

• The officer has reason to suspect that the DLI is not complying or has not complied with the conditions, including providing inaccurate information;
• The officer has reason to suspect that a letter of acceptance was improperly issued;
• The DLI is chosen as part of random verification; or
• The DLI has not complied with conditions in the past.

For the purposes of verifying compliance, the proposed regulations would allow the officer to require that the DLI provide any relevant documents and make a representative available to answer questions, at a time and place specified by the officer.

Under the proposed regulations, a failure to comply with a condition would be justified if the DLI made all reasonable efforts to comply or if the non-compliance is a result of the DLI acting in good faith.

The proposed regulations would require an officer, who determines that a DLI is non-compliant with a condition, to issue a notice of preliminary finding. The notice must set out

• The name of the DLI;
• The condition with which the DLI is non-compliant and the details;
• The period of time the officer recommends the DLI be placed on the suspension list and the reasons for the recommendation; and
• An indication that the DLI can make written submissions with respect to the information or any justification within 30 days of receiving the notice. Under the proposed regulations, the notice of preliminary finding is deemed to have been received 10 days after the day it is sent.

The proposed regulations would allow the officer to correct or cancel the notice at any time before the notice of final determination is issued.

The proposed regulations would allow the DLI to make written submissions within 30 days of receiving a notice of preliminary finding and include any relevant documents. The Minister may grant, at the request of the DLI, an extension of no more than 30 days to make written submissions if the Minister determines that the institution’s ability to make the submissions was prevented or impeded by exceptional circumstances.

If, after the 30-day written submission period, the Minister determines that the DLI has failed to meet the conditions, the proposed regulations would require the Minister to issue a notice of final determination that includes

• The DLIs name;
• The condition that was not complied with;
• Either the period for which the DLI is to be placed on the suspension list or a warning advising the DLI that it will not be placed on the suspension list but that the determination of non-compliance may be factored into the DLI’s placement on the list in any future non-compliance with the conditions; and
• The reason for the determination and the placement on the suspension list, if applicable.

Suspension list and period

In determining whether a DLI is to be placed on the suspension list and the penalty period, the proposed regulations would require the Minister to consider the frequency and seriousness of the DLI’s non-compliance with conditions, the efforts the DLI made to comply with the conditions, the DLI’s level of cooperation during verification, and the DLI’s written submissions to the notice of preliminary finding.

The proposed regulations would require that the Minister publish and maintain a public suspension list that sets out the following for each DLI that received a notice of final determination requiring that it be placed on the list:

• The DLI’s name, mailing address, and website;
• The condition with which the DLI was non-compliant; and
• The date the DLI was placed on the list and the time period it is to remain on the list.

The proposed regulations would allow a non-compliant DLI to remain on the suspension list for a maximum period of 12 consecutive months.

The proposed regulations would require that, during the period that a DLI is on the suspension list, any application for a study permit that names the DLI be returned to the applicant without being processed, along with all supporting documents and the processing fee.

The proposed amendments would require that a study permit holder in Canada who received a letter of acceptance to attend a DLI other than one indicated on their study permit and who wishes to switch DLIs submit an application for a new study permit before the start date for the new program of study. The proposed regulations would allow the student to attend the new DLI without a valid study permit until a decision is made on the application, as long as the student remains in Canada and complies with all other conditions of their study permit.

Amendments to the letter of acceptance provisions

The proposed regulations would amend the existing provisions regarding the issuance of a study permit such that DLIs would be required to confirm the letter of acceptance (LOA) provided by an applicant. The proposed regulations would also amend the existing provision for accompanying family members so that they are exempt from the LOA verification as long as their study or work permit is approved before their entry into Canada. However, once in Canada, if that family member moves to a post-secondary DLI, the proposed regulations would require the accompanying family member to have an LOA that is required to be verified.

The proposed regulations would also add a new provision instructing not to process a study permit application and return it to the student, along with supporting documents and processing fees, if a DLI does not provide confirmation of a student’s acceptance to a post-secondary institution as required under the conditions on DLIs.

Consequences for not complying with the conditions

The proposed regulations would amend existing conditions to specify that t study permit holders must enroll at the DLI listed on their study permit and remain enrolled until they complete their studies. The study permit invalidity provisions would also be amended to add that the day when the permit holder is no longer enrolled at the DLI named on the permit, is the date when the permit may become invalid.

Off-campus work hours

The proposed regulations would increase the limit on off-campus work during regular academic sessions from 20 hours per week to 24 hours per week.

Consultation

Since fall 2022, IRCC consulted extensively with provincial and territorial ministries responsible for both immigration and education, national education associations representing the majority of designated learning institutions across Canada and individual DLIs and student representative organizations. These consultations focused on challenges and proposed initiatives that would raise the bar for all institutions to better recruit and support international students; manage unsustainably high volumes in the ISP; develop regulatory authorities and stronger policy tools that would better address student vulnerability, fraud, and non-genuine actors.

Through the consultations, provinces and territories provided feedback along the following themes:

• Strengthening a designation framework that sees stronger compliance and enforcement action;
• Suspending the issuance of study permits to non-compliant DLIs; and,
• Boosting compliance tools and increasing communication between IRCC and PTs on DLIs of concern.

While there was general agreement on the first and third set of measures, regarding the second one, reactions were mixed. Some PTs showed support for stronger authorities to suspend study permits to DLIs engaged in fraudulent activities or high rates of non-compliance as long as IRCC was mindful of PT role in designating DLIs, while others were concerned that greater federal authorities may encroach on their education mandate.

On LOA verification, PTs actively commented on the success of the measure currently in place through Ministerial Instructions, which also reflected the feedback received from their respective DLIs. Finally, PTs provided general support to strengthen the DLI framework, including the compliance regime.

IRCC also held consultations regarding the modernization of the student program with the following national associations for post-secondary education: Universities Canada, Colleges and Institutes Canada, Canadian Bureau for International Education, Languages Canada, and Association des Collèges et Universités de la Francophonie Canadienne. Associations, on behalf of their members, provided the following feedback:

• Many suggested that the Department should explore how to prevent students from switching DLIs to ensure the effectiveness of the LOA verification process and that students attend the specific DLI listed on their permit;
• Many indicated that the LOA verification process has been working well and are interested in exploring how it could be further leveraged for the purposes of sharing information and reducing fraud; and,
• Many recommended further action in general terms to strengthen the DLI framework and compliance and raise standards.

IRCC is committed to working closely with all PTs, whether in multilateral or bilateral discussions, to advance ISP reform.

IRCC consulted on the issue of off-campus work, including the public policies waiving the 20-hour work limit, through a survey and stakeholder interviews held in the summer of 2023. Consultations on off-campus work hours demonstrated a wide range of views on the number of hours international students should be authorized to work off campus. In consultations with provincial and territorial education ministries, most expressed concerns with unlimited or significantly increased work hours, citing risks to program integrity, students prioritizing work over study, recruitment practices, impacts to student academic success, and concerns regarding exploitation of students by employers. One province sought feedback on the public policies from its public post-secondary institutions, in which the majority of respondents expressed strong concerns regarding students’ well-being and academic performance within the context of unlimited work.

However, the public policy lifting the 20 hour per week limit was popular amongst eligible international students. In summer 2023, IRCC conducted a survey of international students who were eligible for the public policy to better understand the impact of the public policy that waived the 20-hour limit on off-campus work. 89% of the students who responded to the survey were in favour or permanently lifting the cap. The survey also found that 81.4% of respondents worked during the winter/spring 2023 semester. Moreover, 75.1% of eligible students reported that they worked off campus, with 73.1% of those who worked off campus indicating that they worked more than 20 hours per week.

IRCC also heard from a number of employers experiencing labour shortages, who support lifting the 20-hour limit completely.

Academic associations and service provider organizations were also interviewed by IRCC officials regarding the public policy lifting the off-campus work hours limit was largely positive. Several organizations and associations emphasized the principle of equity between international and domestic students, and the importance of respecting international students’ autonomy and agency to make their own decisions regarding their work/school balance. However, the Department also heard that some designated learning institutions have experienced an increase in the number of international students struggling in their studies since the introduction of this temporary policy change, indicating that some are prioritizing work over their studies.

Modern treaty obligations and Indigenous engagement and consultation

The proposal has been assessed for modern treaty implications and the Department did not identify any potential modern treaty or self-government impacts.

Instrument choice

The proposed program enhancements can only be achieved through amending the IRPR.

As the limit on off-campus work is prescribed in regulation, the only option available to change the limit is by amending the regulations.

Regulatory analysis

Benefits and costs

An important first step in developing a cost-benefit methodology is establishing a baseline scenario against which options may be measured. For this analysis, the baseline scenario is one where regulatory requirements for DLIs and study permit holders would be unchanged. The baseline scenario is then compared with the regulatory scenario, in which DLIs would be required to verify LOAs for study permit applications and submit DLI compliance reports to IRCC. The IRCC would be able to take a course of action when DLIs fail to comply with the regulatory conditions, by adding non-compliant DLIs to a public suspension list and preventing the approval of study permit applications that list suspended DLIs. In the regulatory scenario, study permit holders would be required to attend the DLI listed on their study permit unless they reapply for a new study permit to change DLIs. And lastly, full-time international students pursuing academic, professional or vocational training programs would also be permitted to work 24 hours per week off campus, instead of the existing limit of 20 hours per week.

The costs and benefits of the regulatory amendments are monetized for 10 periods of 12 months (2024 to 2033) and are expressed in 2023 dollars. The regulations would come into force on the day they are registered. For further details regarding the methodology, a detailed cost-benefit analysis report is available upon request at the following email address: IRCC.TEIBISPPPolicy-DIETPPEIPolitique.IRCC@cic.gc.ca.

Consultation on cost and benefit impacts were conducted through a summer 2023 IRCC survey of eligible international students, which sought to better understand the impact and participation rate of eligible international students in the public policy that waived the 20-hour limit on off-campus work.

This cost-benefit analysis makes assumptions around variables that may be subject to uncertainty. It is important to acknowledge this uncertainty, in particular the presence of uncertainty in variables on which impacted external stakeholders were not consulted. For this reason, a sensitivity analysis was conducted to examine how changes in uncertain variables would impact the cost-benefit analysis results. For sensitivity analysis results, please consult the cost-benefit analysis report.

The regulatory amendments are estimated to cost $86,957,971 in present value (PV) over the 10 periods. These costs consist of Government of Canada implementation activities, costs to DLIs related to participating in the LOA verification system and submitting compliance reports to IRCC, and costs to study permit holders who wish to change DLIs. The regulatory changes to increase the off-campus work hours limit for full-time international students are not expected to result in any incremental costs. Costs for the Department’s implementation of the amendments would be managed through existing IRCC resources. The benefits of the regulatory amendments would be incurred by international students who are eligible for the four-hour increase in their weekly off-campus work hour limit. These benefits are estimated at $10.2 billion PV in 10 periods.

Costs to DLIs

Mandatory LOA verification

In the baseline scenario, although existing Ministerial instructions with respect to the processing of study permit applications already require LOA verification from post-secondary DLIs, these instructions are a temporary measure. The regulatory amendments would permanently establish an LOA verification requirement. This would be achieved through an existing portal where DLIs would be provided with the applicant’s biographical information, student number from the accepting institution, and the DLI’s confirmation of the student’s acceptance. This requirement is expected to affect between 1 700 to 2 000 DLIs Canada-wide, including those in Quebec.

For the purpose of estimating the cost impacts of the LOA verification requirement on DLIs, the number of study permit applications that would require verification in period 1 is estimated at 884 884. This volume is expected to decrease by 11.8% in period 2, reflecting the effect of the intake cap on most study permit applications. Then, growth is assumed to resume, at a rate of 22.39% in period 3, then at 22.73% in period 4, and lastly stay constant at 11.6% for the rest of the analysis period.

It is assumed that a DLI would spend three minutes verifying one LOA in the first period. As DLIs become familiar with the portal, this time is expected to be reduced to 30 seconds per LOA verification, starting in period 3.

The total cost to DLIs for LOA verification is estimated at $4,806,119 PV over 10 periods.

Compliance reports

In the baseline scenario, all post-secondary DLIs, with the exception of institutions located in Quebec, must complete and submit scheduled reports on the academic enrolment status of their study permit holders at the post-secondary level to IRCC. Although compliance reporting is already a requirement for approximately 700 DLIs, about 6% to 8% of those required to submit reports fail to do so. Besides closing the compliance gap that exists for this requirement, the regulatory amendments would also add Quebec post-secondary DLIs to the compliance reporting regime through an information-sharing arrangement between IRCC and Quebec.

Onboarding of Quebec DLIs for this requirement is expected to take approximately one year. For this reason, Quebec DLIs would start complying with the reporting requirement in period 2. In period 1, for the purpose of this analysis, it is estimated that 39 DLIs would be impacted by the reporting requirement. This reflects the number of non-Quebec DLIs that are non-compliant under the existing regime. In period 2, 363 Quebec DLIs would start complying with the reporting requirement, for a total of 402 Canada-wide DLIs required to submit compliance reports in this period. To reflect the impact of the intake cap on most study permit applications, no growth in the number of DLIs is expected for the first two periods. In period 3, a resumption of growth is assumed, at 3.5% per period. The development and submission of a compliance report is expected to take 37.5 hours per DLI.

Besides requiring the submission of biannual reports, the proposed regulatory amendments would also provide the authority for follow-ups with DLIs where IRCC has questions or concerns with the information submitted in the reports. Only 50% of impacted DLIs are expected to require follow-ups, and these are expected to take 10 minutes for DLIs to complete for multiple student records.

The cost related to compliance reporting requirements to DLIs is estimated at $7,221,881 PV over 10 periods.

Lastly, the regulatory amendments would allow IRCC to take action when a DLI has failed to comply with the reporting conditions in the proposed regulatory amendments. Non-compliant DLIs may be added to a publicly available suspension list and may be suspended from receiving international students for a period of up to 12 months. The cost impacts to suspended DLIs would be losses of revenue from international students not enrolling in their institution during the suspension period. These impacts do not have standing for the purpose of this cost-benefit analysis, as they would be considered a consequence of non-compliance with the proposed regulations.

Cost to study permit holders

In the baseline scenario, although IRCC requires that students notify them when they change DLIs, students are not required to submit a new study permit application if they wish to switch DLIs. The regulatory amendments would require that students obtain a new study permit when they wish to transfer to a new DLI. Movement between DLIs is common and challenging to track. Although IRCC does not have the data to determine how many international students transfer DLIs yearly, based on DLI compliance reporting, it is estimated that approximately 5% do so.

For the purpose of this analysis, in period 1, 30 536 re-applications are expected, this volume would grow at the assumed growth rate of study permit holders. This means it would stay constant for period 2, and then resume growth at 11.6% per period for the rest of the analysis.

The costs to study permit holders include the time spent preparing their new application (30 to 45 minutes per application), and application fees, set at $150 per application. The total cost to study permit holders for submitting new study permit applications is estimated at $55,546,031 PV over 10 periods. This includes $50,440,983 PV in application fees, and $5,105,048 PV in time spent to prepare and submit their applications. The hourly wage rate assumed for study permit holders is $24.29.

An increase in the volume of study permit applications submitted may increase processing times for this line of business. However, the impact of longer processing times would be mitigated as students who have applied to change the DLI would be allowed to attend the new DLI as long as the study permit application has been submitted. The requirement for students to reapply may raise uncertainty costs for this cohort of students. IRCC plans to also reallocate resources to respond to increased volumes and processing pressures, so that students can receive their application decision within reasonable service standards.

Lastly, study permit applications from clients who were planning to attend, or needed to extend their existing study permit to attend a DLI that has been suspended due to non-compliance would be returned during the suspension period. Impacted clients would need to submit an application for a different DLI if they wish to continue with their process.

Costs to the Government of Canada

Transition costs

IRCC would incur transition costs in the first period following the implementation of the proposed regulatory amendments, which are estimated at $2,608,095 PV. These costs include developing program delivery instructions, adjusting web pages and preparing communications products, supporting the technical and administrative onboarding of Quebec DLIs into the compliance reporting regime, and updating the IT system to ensure the Global Case Management System, the DLI Portal, and MyAccount Portal are up to date for the implementation of the regulatory changes.

Ministerial instructions requiring LOA verification from certain DLIs have been in effect since December 1, 2023, for overseas applications and January 30, 2024, for in Canada applications; therefore, the costs of developing an LOA verification system have already been incurred and are thus not included as incremental costs of the regulatory amendments.

Ongoing costs

The majority of costs to IRCC would be ongoing costs, which are estimated at $16,775,847 PV over 10 periods. These include management of the LOA verification system, including processing DLI submissions and managing communication with DLIs, conducting program integrity activities, as well as activities related to the inclusion of Quebec in the compliance reporting regime, administrative and technical activities related to the inclusion of Quebec DLIs, and ongoing updates to program delivery instructions. Ongoing costs also include those associated with follow-up requests to DLIs, and enforcement activities that would arise from non-compliance.

The requirement to submit a new study permit application to change DLI would result in an increase in the number of study permit applications received by IRCC. Although this increase would require additional resources to process higher volumes, the costs to IRCC would be fully recovered through fees received from study permit applications. Therefore, the cost impact to IRCC is neutral.

Benefits

Program integrity benefits

The regulatory amendments would allow IRCC to effectively respond to integrity challenges and address common occurrences of unethical behaviours that undermine the integrity of the program.

The enhanced LOA verification system would allow IRCC to verify each LOA submitted with study permit applications before they are processed, allowing for early identification of fraudulent LOAs and preventing the approval of non-genuine applications or applications from students who have been defrauded.

Codifying the requirement to submit biannual compliance reports would allow IRCC to close the compliance gap that exists in this regime and add Quebec DLIs to this requirement. The codification would help IRCC obtain accurate and up-to-date information about the enrollment status of all international students Canada-wide and identify students who are not meeting the conditions of their study permit.

Requiring international students to obtain a new study permit when transferring to a new DLI would ensure that IRCC can more accurately assess and track student compliance with conditions set out in their permit and identify when they change DLIs.

Both the LOA verification requirement and the codification of compliance reporting imposes requirements on DLIs to provide accurate information about enrollment of international students. The proposed amendments also allow IRCC to request further documentation from DLIs if they do not comply with the conditions as set out in the regulatory amendments, or if there are reasons to suspect non-compliance. When IRCC determines that a DLI has failed to comply, and the frequency, seriousness and corrective efforts from the DLI warrant it, they may be added to a public DLI suspension list for a maximum period of 12 consecutive months, during which any applications that are submitted to IRCC with a DLI included in the suspension list would be returned. These changes would allow IRCC to impose consequences for DLIs that have not submitted compliance reports as required in proposed regulations.

Benefits to international students

The regulatory amendments would increase the hours that eligible international students can work off campus from 20 to 24 hours. This change would help international students offset increasing costs of living, should they wish to work an additional four hours a week.

Based on IRCC’s survey of international students who were eligible for the public policy that waived the 20 hour per week work limit, this analysis assumes that 75.1% of eligible students would work off campus, with 73.1% of those who work off campus estimated to work more than 20 hours per week.^footnote1 For the purpose of this analysis, study permit holders who also hold a work permit, including a co-op work permit, are excluded from the benefits estimation. This cohort of students would already be authorized to work longer hours as per their work permit.

For the purpose of this analysis, in period 1 it is anticipated that 296 906 eligible international students would benefit from the increase to work hours, having the opportunity to work an additional 128 hours per year. The volume of students in period 1 is estimated by using the number of eligible students, and applying percentages obtained from IRCC’s survey of international students for the public policy (i.e. 75.1% are assumed to work off campus, and of those, 73.1% are assumed to work the additional 4 hours per week). This volume is expected to grow at the same rate as study permit holders. This means it would stay constant for period 2, and then resume growth at 11.6% per period for the rest of the analysis.

Students eligible for this change would continue to have the opportunity to work full-time during academic breaks. This includes the summer break for students who are enrolled in programs that run from September to April. The benefit to international students is estimated as their increase in earnings for the additional hours that they would be able to work off campus. At an hourly wage rate of $24.29, the benefits of the increase to off-campus work hours limit are estimated at $10.2 billion PV over 10 periods.

The increase in off-campus work hours would increase the supply of labour hours from international students. This would be particularly evident in low-wage industries where a greater portion of international students’ work. Although this may result in increased competition for Canadian workers in these industries, it is important to note that some of the industries where there is a high labour participation rate for this cohort of international students have experienced high job vacancy rates in recent years. For example, according to the Canadian Employer Employee Dynamics Database (CEEDD) 2021 data, approximately 23.9% of international students without a work permit and who had T4 earnings, had earnings in the accommodations and food services industries. Based on the Job Vacancy and Wage Survey from March 2023, accommodation and food services sector had the highest job vacancy rate across all sectors (7.6%).² The regulatory amendments are expected to benefit industries that are experiencing high vacancy rates, while also alleviating financial difficulty experienced by students in recent times.

Cost-benefit statement

• Number of periods: 10 (10 periods of 12 months 2024–2033)
• Price year: 2023
• Present value base year: Period 1 (2024)
• Discount rate: 7%