Will I need to submit a provincial attestation letter as part of my Canadian study permit application?

A recent notice published by Immigration, Refugees and Citizenship Canada (IRCC) has clarified exactly who is required to submit a provincial attestation letter (PAL) when they apply for a Canadian study permit.

In late January this year, the federal government announced that most new post-secondary international students at the college or undergraduate level would now require a PAL from a province or territory as part of their study permit application.

In addition to Letters of Acceptance (LOAs) issued to international students by the Designated Learning Institution (DLI) they apply to, PALs will “serve as proof that the student has been accounted for under a provincial or territorial allocation within the [recently implemented] national cap” on study permits (more on that later).

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IRCC has informed all provinces and territories that they must have a process for issuing PALs to international students in place by March 31, 2024. It should also be noted that, according to IRCC, “the Government of Canada is working with the Government of Quebec to determine how the [Quebec Acceptance Certificate]/Certificat d’acceptation du Québec (CAQ) pour études [for studies] could serve as a PAL.”

Note: IRCC has indicated that they will return any study permit application received without an accompanying PAL unless the applicant is exempt.

Who needs a PAL?

According to IRCC’s notice, first published on February 5 and then updated on February 27, the department’s PAL requirements break down as follows.

PALs are a requirement for:

Most post-secondary study permit applicants
Most non-degree granting graduate programs (for example, certificate programs and graduate diplomas)
Any international student not included in the exception list below

PALs are not required by:

Primary and secondary school students
Master’s or doctoral degree students
In-Canada visiting or exchange students studying at a DLI
In-Canada study permit and work permit holders (including existing study permit holders applying for an extension)
In-Canada family members of study permit or work permit holders
Students who have already been approved for a study permit and intend to travel to Canada for an upcoming program
Students whose application we received before 8:30 a.m. EST on January 22, 2024

Other key changes to Canada’s international student landscape

PALs are just one of several new policies recently/soon to be implemented by IRCC. The department says the measures aim to help maintain and reinforce the integrity of Canada’s international student system while supporting “sustainable population growth.”

Accordingly, the federal government has taken the following steps – in addition to the introduction of PALs – to reform the international student system.

Intake cap on international student permit applications

Over the next two years, the Government of Canada will set an intake cap on study permits “to stabilize new growth” across the country.

In 2024, the cap is expected to result in approximately 360,000 approved study permits, a decrease of 35% from the year prior. This cap will be distributed across Canadian provinces and territories, weighted by population, and local governments in each region will then be responsible for distributing “the allocation among their” DLIs.

IRCC notes that the study permit cap for 2025 will be reassessed at the end of this year.

IRCC’s trusted institution framework

An upcoming Trusted Institutions Framework (TIF) will soon be implemented by IRCC as a way to provide “DLIs who meet certain IRCC integrity criteria [to take advantage of] certain benefits, such as priority processing of study permit applications by IRCC.” More details about this framework are expected in the coming months, as the TIF is expected to be implemented by the Fall semester of 2024.

Changes to Post-Graduation Work Permit program eligibility criteria

IRCC is making certain international students ineligible for a Post-Graduation Work Permit (PGWP) while adding other students to the list of eligible recipients.

Specifically, beginning September 1 this year, “international students who begin a study program that is part of a curriculum licensing arrangement will no longer be eligible for a [PGWP] upon graduation.”

This measure, which was initially announced in January, applies to “students [who] physically attend a private college that has been licensed to deliver the curriculum of an associated public college.”

On the other hand, as of February 15, international students who graduate with a master’s degree are now eligible for a three-year PGWP. Previously, these graduates were restricted to a PGWP where the permit’s validity period was directly correlated with the length of the program of study.

Changes to open work permit eligibility

Open work permits will soon only be available to spouses of international students in master’s and doctoral programs. This means that the spouses of international students pursuing other levels of study, including undergraduate and college programs, will no longer be eligible. IRCC has not yet released details on this measure.

Increased cost-of-living requirement

As of January 1, 2024, IRCC has increased the cost-of-living requirement for study permit applicants. This requirement, according to IRCC, will now be adjusted annually when Statistics Canada updates the low-income cut-off. Before this adjustment on January 1, Canada’s cost-of-living requirement had not been adjusted once since it was first introduced in the early 2000s.

New LOA verification process

Since December 1 last year, DLIs across Canada have been required to confirm every LOA submitted by international students outside of Canada directly with IRCC. Under this new framework, DLIs will now have to verify every LOA submitted by an eligible student through the online portal, “which only their representative(s) to IRCC will have access to.”

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