IRCC Increases Compliance Checks for International Students After Auditor General Report

A LinkedIn post from Kubier Kamal has highlighted an increase in international student compliance letters. These letters are sent to international students to ensure they are complying with the conditions of their study permit. The letters themselves aren’t new, but we could see more of them going out in future, and more follow-up from IRCC for those who don’t respond or are found non-compliant. 

Key Takeaways  

• Students should be prepared for more compliance letters and closer scrutiny of students flagged as potentially non-compliant 
• IRCC only investigated a small fraction of potential non-compliance cases, highlighting a major enforcement gap. 
• It’s more important than ever for international students to know the conditions of their study permits. 

What the Report Said  

The OAG report found that 153,324 international students in Canada were reported as potentially non-compliant with the conditions of their study permits between 2023 and 2024.  

Of these, IRCC only investigated 4,057 cases over two years. The department was found to not have the funding to investigate more than 2,000 cases a year.   

Still, 40% of the 4,057 cases couldn’t be closed because there was no response from the students; that’s approximately 1,654 students. That means IRCC was able to close only 3,105 investigations out of a possible 153,324 non-compliance cases.  

The report also found that IRCC identified 800 cases of fraudulent documentation between 2018 and 2023. Many of these cases were not flagged, and the individuals later applied for other Canadian permits.  

IRCC’s Response  

The OAG report has caught the attention of media worldwide, and IRCC is now scrambling to implement its recommendations. On the same day the report was released, IRCC acknowledged that the department could be doing more to prevent international student fraud and non-compliance.   

Based on Kamal’s post, we assume that part of the clean-up involves issuing more compliance letters to students flagged by their Designated Learning Institution (DLI) as potentially non-compliant.  

Compliance letters are not a new measure. IRCC has had an international student compliance regime in place since 2014.   

Since then, DLIs have reported to IRCC twice a year to confirm the enrolment status of their international students. IRCC can also request ad hoc reports on individual students if it has reason to believe a student is not complying with the conditions of their permit.   

Why Does it Matter?  

The findings reveal a system struggling to enforce its own rules. This points to a system that is not only under-resourced but also reactive rather than proactive.  In effect, IRCC has had visibility into the issue for years but has had limited ability—or will—to act on it until now.  

It means that it is increasingly important for international students to comply with the conditions of their study permits. It’s likely that IRCC will continue to look for ways to find non-compliant students and ramp up its efforts at enforcement.  

What are Some Conditions that Could Flag Students for Non-Compliance?

So, what are some of the conditions that raise a red flag for IRCC? A few basic ones involve verifying that you are enrolled in your program and attending your classes on a full-time or part-time basis, as stated on your study permit.   

You also need to ensure you do not exceed the maximum number of hours you are allowed to work as an international student, if your study permit allows you to work.  

This generally means 24 hours per week during the academic year. You may be able to work full-time through breaks and holidays. However, you may have something different on your permit. Always check it carefully. 

Check out our article for more information on study permit conditions that could lead to non-compliance issues.  

What to Do if You Get a Letter  

If you get a letter, IRCC will likely ask you to provide several documents. These could include official documents from your school confirming:  

• your enrolment status  
• the reason for and start date of any leave you’ve taken  
• the date you withdrew from a school or study program  
• the date you were suspended or dismissed from a school or study program  
• the date you stopped studying at the school  
• official transcripts  
• references from people who know you  
• proof from a medical professional confirming the medical need for a leave from your study program  
• document confirming your school has closed and no longer offers your study program  
• any other document an officer finds relevant  

It’s important that you gather your documents and submit them. Ignoring IRCC may result in your profile being flagged, making it more difficult to apply for another type of permit or visa down the road.  

What Can IRCC Do if You’re Non-Compliant  

If IRCC finds that you aren’t following the conditions of your study permit, you may be asked to leave Canada. You’ll have to wait at least six months before applying again for a study permit. It may also have a negative impact on any future applications you want to make for other immigration permits.  

Also, if IRCC decides you misrepresented yourself (such as through false documentation or withholding information), you could be found inadmissible to Canada for up to 5 years.   

The Takeaway 

The OAG report and the resulting media attention has caused IRCC to jump into action on potential non-compliance issues for international students.   

To start, we can expect to see more compliance letters going out. However, we don’t know whether IRCC will be able to follow up with every student or what kind of enforcement measures might be taken.   

We might see fewer potential non-compliance cases for permits issued after the Letter of Verification system was introduced in early 2024. The OAG found that overall, the system is successful in identifying false letters of acceptance. This will cut down on at least one type of fraud. 

For international students, the takeaway is simple: compliance matters more than ever. Make sure you meet the conditions of your study permit, keep records of your enrolment and work hours, and respond promptly to any communication from IRCC. Ignoring a request could have serious consequences for your status in Canada.