Over the last four to six weeks, Immigration, Refugees and Citizenship Canada (IRCC) has updated a number of its internal policy, procedures and guidance documents. These are primarily used as reference documents by IRCC staff, but the department also publishes some of these files “as a courtesy to stakeholders”. In their public form, they also serve as an important guide for students and advisors.
This is in many respects an underappreciated resource in that these publicly shared files provide detailed guidance into the rules and compliance requirements for Canada’s various immigration streams. They also provide a window into how, over time, that guidance can be expanded, clarified, or otherwise changed.
The larger context here is that many students gather information about compliance or the fine points of their visa status from peers, in online message boards, or from other unofficial sources. Many too file their own applications for visas or renewals – that is, without assistance from an authorised advisor or lawyer – and may or may not be aware of the latest official guidance.
That all puts a greater importance on a number of changes that have been published in recent weeks to the reference files for study permit and post-graduate work permit (PGWP) compliance. We should be clear that these are not all rule changes. Rather, many take the form of useful clarifications of established policy or practice. That said, keeping track of those changes can be tricky as they may not be publicly announced or otherwise highlighted in the published files.
In broad terms, the series of revisions made in the second half of June are all pointing to greater scrutiny of the enrolment status and academic progress of continuing students, of students transferring between programmes and institutions, and students’ absence or leave from studies. They also introduce important updates to PGWP eligibility, and mark the end of an exception for temporary residents to pursue studies in Canada without a study permit.
Actively pursuing studies
The current version (as of 18 June 2026) of the IRCC reference file “Study permits: Assessing compliance with study permit conditions” expands on the department’s expectations for the active pursuit of studies and academic progression with additional detail on when the programme of studies is considered to be completed.
Specifically, it stipulates that:
“Studies are considered officially completed on the date the DLI first notifies the student by any of the following:
- completion letter
- transcript
- degree or diploma
The date stated on the document will be considered the date of notification unless the applicant and/or DLI can provide proof of a different date.”
The significance of that mechanism is underscored by a related note in the study permit guidance, which specifies that the student’s study permit “will become invalid…90 days after the day the study permit holder completed their studies.”
Changing DLIs or programmes of study
The 18 June updates include considerable expansion of the rules around transferring between institutions.
This guidance is based in a rule change, effective 8 November 2024, which stipulates that “study permit holders in Canada, whose permit names a DLI [Designated Learning Institution], must apply for a new study permit if they wish to change designated learning institutions (DLIs).”
The updated file expands on this point by specifying that “study permit holders must adhere to the condition that they remain enrolled at the DLI named on their study permit until they complete their studies.”
And that “their study permit becomes invalid on the day that they are no longer enrolled at the DLI named on their study permit, other than as a result of completing their studies.”
“Therefore, if a student whose study permit names a DLI has changed DLIs without applying for a new study permit, their previous study permit is rendered invalid and the student is considered to be studying without authorization at the new DLI.”
The updated guidance also addresses the scenario where a student may have a study permit that does not specify a DLI: “If a post-secondary student holds a study permit issued prior to November 8, 2024,that does not name a DLI, they should apply for a new study permit when changing DLIs. Once that study permit with no DLI is expired, they must apply for a new study permit which will be issued with the name of the DLI they are attending.”
The bottom line is that students cannot change institutions before they obtain a new study permit that specifies the new DLI.
The exception to this pertain to students who transfer to a different programme of study within the same DLI: “Students engaging in post-secondary studies in Canada are authorized to change programs of study within the same DLI at the same level of study, provided they are not limited from doing so by conditions imposed on their study permit.”
Finally, the expanded guidance in this area also provides some clear provisions for secondary students transitioning to post-secondary education:
“Students must apply for a new study permit with the DLI’s name on it when they transition to post-secondary studies to avoid any non-compliance issues.”
and
“If a student is attending a secondary school while on a visitor record, they must wait for their study permit application to be approved before beginning studies at the post-secondary level.”
Leave from studies
The study permit guidance remains consistent that, “Students may be required or may wish to take leave from their studies while in Canada. For the purpose of assessing if a student is actively pursuing their studies, any leave taken from a program of studies in Canada should not exceed 150 days from the date the leave commenced and must be authorized by their DLI.”
However, the 18 June updates add some important expansions around multiple leave periods and work rights during a leave from studies.
The point regarding multiple leave periods is in keeping with an overall pattern towards greater scrutiny of student progress: “In cases where a student has taken multiple periods of authorized leave in Canada during their program of study, the officer should consider the student’s reasons for the various periods of leave. If the multiple periods of leave do not appear to support the expectation that the student is making reasonable progress toward the completion of their course or program of study in the time allotted by the course or program of study, the officer may determine that the study permit holder has not fulfilled the condition to actively pursue their course or program of study.”
And on the question of working during a leave from studies, the updated document sets out plainly that, “If a study permit holder is not attending class full time, they are not eligible to work as per the condition listed on their study permit…During any leave from studies, including DLI closures, a study permit holder cannot work on or off campus.”
PGWP and non-credit programmes
IRCC also updated its guidance for post-graduation work permit (PGWP) eligibility on 24 June 2026. The notable change here occurs in the section “Who’s not eligible for a PGWP” which has been changed to specify that students are not eligible if they have “completed a non-credit program of study (except for a flight school program)”.
The significance of such updates is underscored by the high-profile case of a large number of PGWP application rejections this month for graduates from the Canadian Institute of Osteopathic Therapy (CIOT) in Calgary. CIOT delivers programmes in partnership with Portage College, and students in such public-private partnerships (P3) are no longer eligible for PGWPs following a rule change that came into effect on 15 May 2024.
However, many of the CIOT students that have had their PGWP applications refused began their studies prior to that May 2024 effective date, and therefore should be grandfathered under the previous policy that allowed students in P3 programmes to be eligible for post-study work.
Livewire Calgary, an independent news outlet, reports that, “The students immediately inquired about this with [IRCC], which said the mass rejections were due to recent policy changes, including that non-credit courses were no longer eligible for work permits….This modification was made on June 24, years after the students initially started their programs and 18 to 21 months after they submitted their work permit applications.”
In a written response to Livewire Calgary, IRCC explained that “There have been no changes to the eligibility criteria. We updated our PGWP webpage in June 2026 to clarify the existing eligibility requirements related to non-credit programs of study.”
The inference from that reporting is that (i) the policy around non-credit study may have been clear within IRCC but may not have been commonly understood otherwise; (ii) IRCC appears to have determined that there was some ambiguity in this area, thus the 24 June update; and (iii) because this does not represent, in the apparent view of IRCC, a rule change (but rather a clarification), students may not be automatically grandfathered.
ICEF Monitor understands that many of the affected students are appealing their PGWP refusals and that the published guidance in this area may be further tested as a result.
Study for work permit holders
Finally, IRCC has also closed out a temporary policy that allowed some work permit holders to study in Canada without a study permit.
This policy had been in place from 27 June 2023, and it officially expired on 27 June 2026.
For additional background, please see: