OTTAWA, March 16, 2025 – Immigration, Refugees and Citizenship Canada (IRCC) is strengthening its monitoring of international students through updated guidelines on student enrolment status reporting by Designated Learning Institutions (DLIs). As detailed in the latest policy update effective November 8, 2024, compliance reporting has become a mandatory requirement under Regulation 222.1(1)(b) of the Immigration and Refugee Protection Regulations (IRPR). This shift aims to ensure study permit holders are actively pursuing their education, a key condition for remaining in Canada, while providing IRCC with robust data to uphold program integrity.
International Student Compliance Regime: A Closer Look
Since 2016, the International Student Compliance Regime (ISCR) has tracked enrolment statuses at post-secondary DLIs across Canada (excluding Nunavut). Twice yearly, in Spring (March 1–April 30) and Fall (November 1–December 30), DLIs submit compliance reports via the secure DLI Portal. These reports, automatically generated from the Global Case Management System (GCMS), list all study permit holders tied to a DLI’s unique number. Institutions then have 60 days to assign an enrolment status to each student, offering IRCC a snapshot of compliance.
The ISCR targets post-secondary students in programs lasting at least six months, excluding primary and secondary learners, as well as specific groups like refugee claimants or family members of those with unenforceable removal orders. Under R220.1(1), study permit holders must enrol at their designated institution and actively pursue their studies, making reasonable progress toward completion.
Mandatory Reporting: What’s New?
As of November 8, 2024, submitting these compliance reports is no longer optional. DLIs must now detail whether students are enrolled and studying, with failure to comply potentially leading to sanctions, such as suspension from hosting new international students. This marks a significant evolution from the voluntary framework, where 6-8% of roughly 700 DLIs historically failed to report, according to regulatory analyses.
Adverse vs. Non-Adverse Enrolment Statuses
DLIs categorize students into “non-adverse” or “adverse” statuses:
- Non-Adverse: Includes “Full-time Studies,” “Part-time Studies,” “Academic Break,” “Authorized Leave,” “Deferred Enrolment,” “Not Started,” and “Program or Degree Completed”—indicating compliance with study permit conditions.
- Adverse: Covers “Academic Suspension,” “No Longer Registered or Enrolled,” “No Show,” and “Unknown or No Record”—flagging potential non-compliance.
An adverse status doesn’t automatically mean a violation. IRCC emphasizes procedural fairness, requiring further verification—such as interviews or requests for transcripts—before confirming non-compliance and pursuing enforcement actions.
Interpreting the Data: Caution Required
While compliance reports offer valuable insights, IRCC cautions that they’re only indicators. Enrolment statuses reflect a moment in time and may not capture a student’s full story. For instance, a “No Longer Enrolled” status could stem from a legitimate DLI switch unreported before November 2024. Officers must apply procedural fairness, ensuring students have a chance to explain before any adverse decisions, like permit cancellation, are made.
Impact on Application Processing
The primary goal is monitoring compliance, but the data also informs processing. Officers can use adverse statuses to prompt additional documentation requests, though standard verification protocols remain unchanged. Post-reporting investigations, currently limited in scope, analyze trends to refine future strategies, helping IRCC spot risks like fraudulent enrolment or non-genuine students.
Changing DLIs: New Rules in Play
A major update since November 8, 2024, requires students switching post-secondary DLIs to apply for a new study permit. Previously, students could change schools freely and update IRCC via MyAccount—failure to do so often led to adverse reporting by their original DLI. Now, this formal process ensures accurate tracking, reducing misreported statuses and aligning GCMS records with reality.
Why It Matters
This enhanced regime reflects IRCC’s push for accountability amid rising international student numbers—437,000 study permits targeted for 2025, per the latest Levels Plan. By mandating compliance, IRCC aims to protect genuine students, curb program abuse, and ease pressures on housing and services. For DLIs, it’s a call to sharpen reporting practices; for students, it’s a reminder to stay enrolled and engaged—or face scrutiny.
Stay tuned as IRCC rolls out these changes, with Quebec DLIs set to join the reporting fold by late 2025 after an onboarding period. For now, the DLI Portal remains the backbone of this evolving oversight system—keeping Canada’s student program sustainable and secure.
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