Canada Immigration Update: Key Changes to IMP Work Permit Exemptions (C31, C32, and C33)

757

Canada’s immigration authorities have updated critical rules for work permits under the International Mobility Program (IMP). These changes affect foreign nationals involved in research, education, and training programs, particularly international students and researchers participating in Canadian institutions.

This announcement covers the updated eligibility criteria, work hour limits, port of entry application rules, fee exemptions, and special conditions for exemption codes C31, C32, and C33.

What Are IMP Work Permit Exemptions C31, C32, and C33?

The IMP provides several exemption codes allowing certain foreign nationals to work in Canada without the need for a Labour Market Impact Assessment (LMIA). Three key codes related to work connected to research, education, and training programs are:

• C31 — For international researchers
• C32 — For post-secondary co-op/internship students
• C33 — For secondary school co-op students

These exemptions simplify the work permit process for these groups while ensuring work is integral to their academic or research programs.

Overview of the Update

The Immigration, Refugees and Citizenship Canada (IRCC) has revised its policies regarding how international students and researchers can work under specific IMP exemption codes. Key changes were made to the Post-secondary Co-op (C32) eligibility and work authorization.

Main update:

• The maximum number of hours international students can work off campus has increased from 20 to 24 hours per week during an academic term. Previously, students working off campus were limited to 20 hours per week during academic sessions. As of November 2025, this limit has increased to 24 hours per week. This change applies to all work hours combined (including co-op placements and part-time jobs). Students can still work full-time during regularly scheduled academic breaks.

These adjustments ensure consistency between study permits, co-op work permits, and Canada’s labor market balance goals.

Important Port of Entry Changes

Effective immediately, most foreign nationals in Canada are no longer eligible to apply for a work permit at a port of entry (POE).
However, some applicants remain exempt from this restriction, including:

• U.S. citizens or permanent residents
• Professionals and technicians under Free Trade Agreements (FTAs)
• Professionals covered under FTAs with the USA and Mexico (T36), Chile (F22), South Korea (F32), Panama (F42), Colombia (F12), and Peru (F52)
• Spouses or common-law partners of applicants under these FTAs
• Truck drivers leaving Canada for employment purposes (excluding domestic-only operators)
• Applicants with pre-scheduled CBSA appointments

Research-Based Work Permits – Exemption Code C31

The C31 exemption is designed for foreign nationals participating in Canadian research programs. Eligible individuals include:

• Researchers working temporarily for the International Development Research Centre (IDRC)
• Distinguished scientists or post-doctoral fellows sponsored by Atomic Energy of Canada Ltd.
• Researchers or scientists under federal programs like NRC, NSERC, or Natural Resources Canada (NRCan)
• Holders of research chair positions at Canadian universities, funded partially or fully by government bodies

These positions are typically connected to Canada’s Post-doctoral Research Program, which supports advanced research participation.

Post-Secondary Co-op Work Permits – Exemption Code C32

C32 applies to international students enrolled in post-secondary programs where work experience is an essential part of their education.

Eligibility Requirements:

• The work placement must be an integral part of the student’s program at a Designated Learning Institution (DLI).
• The co-op or internship should not exceed 50% of the total academic program duration.
• The DLI’s acceptance letter must confirm that the work placement is mandatory for graduation.

Work Hours:

• Students can now work up to 24 hours per week off campus during academic terms.
• The 24-hour limit includes all paid work — co-op placements, part-time jobs, or both.
• Students can work full-time during scheduled academic breaks.
• On-campus work hours remain unlimited under paragraph R186(f).

For Students Already in Canada:

Students may start their co-op placements before receiving a co-op work permit, provided they have valid on-campus and off-campus work authorization.

For Students Outside Canada:

They can:

• Work remotely with a Canadian employer while waiting for their permit, or
• Work for a local company in their home country with school approval.

Conditions and Permit Details for Officers

Co-op work permits under C32 are coded as open work permits with these details:

• Employer: DLI
• Occupation: NOC 99999
• Fee exemption: E02
• Location: Unspecified or unknown

Mandatory conditions include:

• Condition 18: “Must leave Canada by [date]”
• Condition 26: “Not valid for employment in businesses related to the sex trade.”

If medical exams are incomplete:

• For non-designated countries: Restriction on working in child care, teaching, and health services (Condition 15)
• For designated countries: Same as above plus agricultural occupations (Condition 16)

Officers must include the following remark in the case file:

“Employment practicum cannot form more than 50% of the total program of study. Authorized to undertake employment that forms an integral part of studies.”

Work permit validity should match the duration of the corresponding study permit.

Secondary School Co-op Work Permits – Exemption Code C33

The C33 exemption covers international secondary school students who must work to complete Canadian vocational or academic programs — including those in Quebec that lead to a diploma or certificate of graduation.

Not Eligible Under C32 or C33:

Students in the following types of programs do not qualify:

• General interest or preparatory courses
• Work-study programs in institutions mainly teaching ESL or FSL (English/French as a Second Language)
• Business programs heavily focused on ESL/FSL training

IRCC officers may request confirmation of curriculum details from the school if eligibility is unclear.

Fee Exemptions

Applicants applying under exemption codes C31, C32, or C33 are not required to pay:

• The work permit processing fee under R299(2)(e)
• The open work permit fee under R303.2(2)(a)

---

Key Takeaways for International Students and Researchers

• New work limit: Up to 24 hours per week off campus during class sessions
• No POE work permit applications for most applicants
• Automatic fee exemptions for eligible C31, C32, and C33 applicants
• C32 and C33 only apply to programs offered by Canadian institutions — not foreign schools

These changes aim to simplify work authorization for international students and align post-secondary co-op programs with Canada’s evolving labor and research frameworks.

About Author