New IRCC Study Permit Compliance Update For International Students

Last Updated On 23 June 2026, 9:33 AM EDT (Toronto Time)

Immigration, Refugees and Citizenship Canada (IRCC) quietly updated its program delivery instructions for assessing study permit conditions on June 18, 2026.

The revised guidance newly clarifies enforcement rules around unauthorized transfers between designated learning institutions and narrows how program changes within the same school are assessed.

These are not cosmetic edits or minor wording adjustments.

Several of the changes directly affect whether a student’s study permit remains valid, how IRCC determines when studies are officially completed, and what happens during institutional closures.

IRCC also removed three entire sections from the page and consolidated its guidance around working during a leave from studies.

For the 423,850 people who only hold a study permit in Canada, plus others who hold both work and study permits, this update demands immediate attention.

Here is everything that changed, what it means for current and prospective international students, and what steps to take right now.

Unauthorized DLI Transfers Can Invalidate Study Permits

The single most consequential change in the June 18 update is the addition of a new section titled “Students who change DLIs without authorization.”

Under the updated guidance, section R217.1 of the Immigration and Refugee Protection Regulations requires study permit holders whose permit names a DLI to apply for a new study permit before transferring to a different institution.

This requirement has technically been in force since November 8, 2024, but the new program delivery instructions spell out the enforcement consequences with unmistakable clarity.

If a student whose study permit names a specific designated learning institution changes to a different DLI without first applying for a new study permit, their previous permit is rendered invalid under paragraph R222(1)(a.1).

The student is then considered to be studying without authorization at the new institution.

This is a critical distinction from the pre-update guidance, which did not include a dedicated section explaining the invalidation consequences of unauthorized transfers, and it arrives amid a year of sweeping immigration policy revisions across multiple IRCC streams.

Students who transferred between schools after the online DLI change feature was removed should review whether they submitted a new study permit application, as IRCC confirmed that the online DLI change feature was removed on November 1, 2024.

Guidance Before June 18, 2026	Guidance After June 18, 2026
No dedicated section on unauthorized DLI transfers	New section: Students who change DLIs without authorization
Invalidation consequence not explicitly stated for transfers	Study permit rendered invalid under R222(1)(a.1) upon leaving named DLI
Students could update DLI through online account prior to Nov 1, 2024	Online DLI change removed; new study permit application required

New Guidance For Students Whose Permit Does Not Name A DLI

IRCC also added an entirely new section addressing students who hold older study permits that do not name a specific designated learning institution.

This applies primarily to post-secondary study permit holders whose permits were issued before November 8, 2024, when the requirement to name a DLI on the permit took effect.

Under the new guidance, students in this situation should apply for a new study permit when changing DLIs, even though their conditions may not have explicitly prohibited the switch.

Once the unnamed permit expires, they must apply for a new study permit that will be issued with the name of the DLI they are attending.

Officers are instructed to verify whether the student’s conditions actually prohibited changing schools before making a non-compliance finding.

If the conditions did not prohibit the transfer, the student cannot be found non-compliant with subsection R220.1(1), and their permit will not become invalid under paragraph R222(1)(a.1), since the permit did not name a DLI in the first place.

The update also addresses secondary-to-post-secondary transitions specifically.

Students using a secondary-level study permit to begin post-secondary studies must apply for a new study permit with the DLI’s name on it when they transition to post-secondary.

If a student is attending secondary school on a visitor record, they must wait for their study permit application to be approved before beginning post-secondary studies.

If the study permit application is refused, the student must stop studying at the post-secondary level immediately.

Program Changes Within The Same DLI Restricted To Same Level Of Study

The previous IRCC guidance allowed students to change programs of study within the same designated learning institution, provided their study permit conditions did not prohibit the change.

The June 18th program delivery instructions now clarify that this flexibility applies to program changes within the same DLI at the same level of study.

The June 18 guidance update appears to narrow this flexibility by adding four critical words: “at the same level of study.”

This means a student enrolled in a diploma program at a particular DLI who wants to switch to a bachelor’s degree program at the same institution may now need to apply for a new study permit to authorize the change.

The same logic applies to any level change, whether from a certificate to a diploma, a diploma to a degree, or an undergraduate to a graduate program, and could affect future permanent residency pathways that depend on the specific credential earned.

This restriction is particularly relevant for students planning their post-graduation work permit eligibility, since PGWP duration and eligibility depend on the level and type of program completed.

Students who have already switched levels within the same DLI without applying for a new permit should review their compliance status immediately.

IRCC Defines When Studies Are Officially Completed

IRCC has also added explicit guidance defining the date on which studies are considered officially completed.

Under the new guidance, studies are officially completed on the date the DLI first notifies the student through any of the following documents.

Document Type	What Counts	Key Detail
Completion Letter	Official letter from DLI confirming program completion	Date on the letter is the default notification date
Transcript	Final transcript showing all requirements met	Date on the transcript is used unless proof of earlier or later notification exists
Degree or Diploma	Formal credential issued by the institution	Date stated on the document is the default unless applicant or DLI provides proof of a different date

This matters because the post-graduation work permit application window is 180 days from program completion.

Students who previously assumed their completion date was the final exam date, the convocation ceremony date, or the last day of the semester now have a clear regulatory reference point.

The date stated on the first notification document is the default unless the applicant or the DLI can provide proof of a different date.

DLI Closures: Students Explicitly In Compliance During Transition

The updated guidance adds meaningful clarity to the rules governing institutional closures, including closures resulting from strikes or bankruptcy.

Under the previous instructions, students affected by DLI closures were given up to 150 days to transition to a new program, change status, or leave Canada.

However, the previous wording did not explicitly state whether those students were considered in compliance during that transition period.

The June 18 update resolves that ambiguity by adding the phrase “they are considered in compliance” to the closure guidance.

This means students caught in a DLI closure are not automatically treated as non-compliant while they arrange their next steps, provided they complete the transition within 150 days.

This is a welcome clarification, especially in light of recent enrollment disruptions across several provinces where smaller private DLIs have lost designation or closed operations.

Three Entire Sections Removed From The Compliance Page

IRCC removed three complete sections from the study permit compliance guidance page in the June 18 update.

Removed Section	What It Previously Covered
Change of Status	Rules for students who changed to visitor or worker status and wanted to resume studies using their previous study permit, including the IMM 5709 form process and maintained status under R183(5)
Spouses or Common-Law Partners of Full-Time Students (C42)	How C42 work permits for spouses remained valid even when the student took a leave longer than 150 days and changed status
Children of a Full-Time Student	Authorization for children to continue studying without a study permit when the parent held a valid study permit or a spouse held a valid C42 work permit

The removal of these sections does not necessarily mean the underlying regulatory provisions have changed, but the fact that IRCC deleted the guidance from this specific compliance page signals a shift in how officers will approach these scenarios during assessments.

Students who rely on their spouse’s C42 open work permit or whose children study without their own permit should seek updated guidance directly from IRCC or a licensed immigration professional.

Consolidated Guidance For Working During A Leave From Studies

The June 18 update merges what were previously two separate sections on working during a leave from studies into a single consolidated section.

The old guidance had separate headings for on-campus and off-campus work and for co-op and internship placements, each with their own explanations.

The new version simplifies the language into a single clear guidance: 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.

Students who hold a valid co-op work permit may not undertake a co-op or internship placement during any leave from studies or school closure.

Notably, the updated wording removes the previous reference to “internship work permits” as a separate category, streamlining the terminology to focus on co-op work permits only.

This consolidation aligns with IRCC’s broader move toward clearer, less ambiguous compliance rules across all temporary resident categories.

Additional Wording Changes Worth Noting

Beyond the headline changes, the June 18 update includes a series of smaller but meaningful wording adjustments throughout the compliance page.

The language governing study permit conditions was changed from “shall enrol” and “shall actively pursue” to “must enrol” and “must actively pursue,” reinforcing the mandatory nature of these conditions.

The heading “Study permit invalidity” was renamed to “Study permit invalidation,” which more accurately describes an active process rather than a passive state.

IRCC added a new reference directing officers to the “Reviewing student enrolment status reporting by DLIs” program delivery instructions for additional guidance on interpreting twice-yearly compliance reporting data.

The guidance on authorized leave now consistently uses the term “authorized leave” rather than just “leave,” clarifying that only leave formally granted by the institution counts toward the 150-day window.

The progress-toward-completion standard was simplified from requiring reasonable progress “in the time allotted by the program” to requiring reasonable progress “toward the completion of their program,” which gives officers marginally more flexibility when assessing individual cases.

What International Students Should Do Right Now

The June 18 update to IRCC’s study permit compliance instructions is already in effect and applies to all current study permit holders in Canada.

Students who have transferred between DLIs at any point since November 8, 2024 should verify whether they applied for a new study permit before making the transfer.

Anyone who changed their DLI using the now-removed online portal feature without submitting a formal study permit application should consult a licensed immigration consultant or lawyer immediately.

Students who changed programs within the same DLI but at a different level of study should determine whether a new study permit was required for that change.

Students holding permits issued before November 8, 2024, that do not name a DLI should plan to apply for a new study permit before their current permit expires.

Students approaching graduation should confirm their official completion date using the DLI’s first written notification and begin preparing their post-graduation work permit application well before the 180-day deadline.

Students affected by DLI closures should document their timeline carefully and ensure their transition to a new program, change of status, or departure from Canada falls within the 150-day compliance window.

Students on a leave from studies should confirm that their leave was formally authorized by their institution and should avoid any on-campus, off-campus, or co-op employment until they resume full-time classes.

Summary Of All Major Guidance Changes At A Glance

Change	Impact On Students
Unauthorized DLI transfers invalidate permit	Transferring without a new study permit application renders the previous permit invalid under R222(1)(a.1)
New guidance for permits without a named DLI	Pre-November 2024 permit holders should apply for a new permit when changing DLIs; must do so when the unnamed permit expires
Same-DLI program changes restricted to same level	Switching from a diploma to a degree or between different credential levels at the same DLI may require a new study permit
Official completion date defined	Studies are completed on the date the DLI first notifies the student via completion letter, transcript, or degree/diploma
DLI closure compliance clarified	Students are explicitly in compliance during the 150-day transition window after a closure
Three sections removed	Change of Status, C42 spouse work permits, and children-of-student guidance deleted from the page
Leave work rules consolidated	Single rule: no on-campus, off-campus, or co-op work during any leave from studies, including DLI closures

The June 18 IRCC update represents one of the most significant clarifications to IRCC’s study permit compliance framework since the November 2024 regulatory changes took effect.

This is a reminder for the International students to treat this as an immediate action item, not a future planning exercise, and verify their compliance status against every change outlined above.

Follow Immigration News Canada for continued coverage of every IRCC policy update affecting international students in 2026.

Frequently Asked Questions (FAQs)

Can I transfer to a different DLI if my current study permit names my school?

You must apply for a new study permit before transferring to a different post-secondary DLI if your current permit names your institution, as per section R217.1 of the IRPR. Failing to do so renders your existing permit invalid and places you in unauthorized study status at the new school.

What happens if my pre-November 2024 study permit does not name a DLI and I already switched schools?

Officers are instructed to verify whether your permit conditions prohibited you from changing DLIs. If your conditions did not prohibit the switch, you cannot be found non-compliant with subsection R220.1(1), and your permit remains valid. However, you should still apply for a new study permit to ensure your DLI information is accurate for compliance reporting purposes.

Does the new completion date rule affect when I can apply for a PGWP?

Yes, the 180-day PGWP application window now starts from the date the DLI first notifies you via a completion letter, transcript, or degree. If the notification came earlier than you assumed, your 180-day window may already be running. Check with your institution and confirm the specific date on your earliest completion notification document.

Am I allowed to work during a leave of absence from my program?

No, the updated guidance is explicit: during any leave from studies, including DLI closures, study permit holders cannot work on or off campus and cannot undertake co-op placements. This applies regardless of whether your study permit includes a work authorization condition.

Can I switch from a diploma program to a degree program at the same DLI without a new study permit?

Under the updated guidance, you may change programs within the same DLI only at the same level of study. Switching from a diploma to a degree, or between any different credential levels, may require a new study permit application. Students who already made such a switch without applying should review their compliance status with a licensed immigration professional.

Fact-checked against IRCC’s official program delivery instructions update published on June 18, 2026, and the current study permit compliance guidance on Canada.ca.

Disclaimer: This article is for informational purposes only and does not constitute legal or immigration advice. For case-specific guidance, consult a licensed immigration consultant or lawyer.

Kamal Deep Singh, RCIC

Kamal Deep Singh, RCIC (Regulated Canadian Immigration Consultant) licensed by CICC (formerly known as ICCRC) with member number R708618. He brings extensive knowledge of immigration law and new changes to rapidly evolving IRCC.