Ottawa Eyeing Expansion of Off-Campus Work Hours for International Students 

International students asked Ottawa to let them work off campus more than just 20 hours per week back in November last year, and now Immigration, Refugees and Citizenship Canada (IRCC) is considering doing just that as part of a review of its regulations.

On June 29, the immigration department launched its 30-day review of the Regulations Amending the Immigration and Refugee Protection Regulations (Designated Learning Institutions), a series of proposed changes which primarily affect colleges and universities deemed to be Designated Learning Institutions (DLI).

Boost in off-campus hours touted as way to resolve labour challenges

A DLI is a school approved by a provincial or territorial government to host international students. All primary and secondary schools in Canada are automatically DLIs.

Although international students were allowed to work up to 24 hours off campus during the COVID-19 pandemic starting November 2022, those off-campus work hours were cut back down to 20 hours on Apr. 30 of this year. 

“There is a need to reassess the appropriate balance between the need some students have to work for supplementary income while respecting the purpose of a study permit, ensuring academic outcomes of the student and remaining consistent with other like-minded countries that have limits on work hours for international students,” notes the IRCC.

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“For example, the United Kingdom, New Zealand, and Ireland allow certain students to work up to 20 hours per week, while Australia changed its work hours limit in 2023 to 48 hours every two weeks.”

An IRCC survey of international students suggests that more than half of them – which amounts to more than a quarter million of them – would work more than 20 hours per week off campus if this were allowed. 

“It is anticipated that 296,906 eligible international students would benefit from the increase to work hours, having the opportunity to work an additional 128 hours per year,” notes the IRCC.

“The benefit to international students is estimated as their increase in earnings for the additional hours that they would be able to work off campus.” 

“At an hourly wage rate of $24.29, the benefits of the increase to off-campus work hours limit are estimated at $10.2 billion (in present value) over 10 periods.”

Ottawa is hoping the boost in allowed work hours for international students would help resolve labour shortages in many industries, particularly those which only offer lower wages.

“Although this may result in increased competition for Canadian workers in these industries, it is important to note that some of the industries where there is a high labour participation rate for this cohort of international students have experienced high job vacancy rates in recent years,” notes the IRCC.

More than half of international students expected to want to work 24 hours per week

“For example, according to the Canadian Employer Employee Dynamics Database (CEEDD) 2021 data, approximately 23.9 per cent of international students without a work permit and who had T4 earnings, had earnings in the accommodations and food services industries. 

“Based on the Job Vacancy and Wage Survey from March 2023, accommodation and food services sector had the highest job vacancy rate across all sectors.”

Late last year, the Canadian Federation of Students’ (CFS) policy and research analyst James Casey reportedly claimed international students were disproportionately experiencing the effects of rising rents and other costs of living because they were not being given any federal or provincial loans or grants or housing vouchers.

At least some international students were apparently turning to food banks.

“It’s a very dire situation that speaks to the huge gap between what life is for an international student in this country versus the average Canadian student,” Casey reportedly said.

He warned the situation of many international students, who were said to be sharing beds and single rooms and even winding up homeless, would only get worse unless they were allowed to work more hours off campus.

The regulations now being reviewed by Canadian immigration include allowing IRCC to have the authority to suspend study permit processing for non-compliant educational institutions and requiring that students apply for new study permits when transferring schools.

Canada’s International Student Program (ISP) is a shared responsibility between the IRCC and the provinces and territories and colleges and universities need to be designated by provinces or territories to receive international students to study in Canada.

But there’s a snag.

”Under the existing regulations, the federal government does not have the regulatory authority to compel reporting from DLIs as part of the compliance program and letter of acceptance verification system,” notes IRCC.

Proposed regulatory changes to give IRCC more power over DLIs failing to report

“Where DLIs are not reporting, IRCC does not have a reliable way of determining whether a student is attending the DLI and complying with their study permit requirements, and IRCC cannot effectively detect fraudulent letters of acceptance.”

Not only do Canadian immigration officials lack an effective method for detecting fraudulent letters of acceptance but they also lack the ability to stop the processing of study permit applications from international students planning to attend those non-DLI schools. 

“Currently, IRCC cannot impose conditions on a non-compliant DLI, such as the suspension of study permit processing. This means that IRCC is required to issue study permits for students attending the DLI even when the DLI is not reporting to IRCC on student enrollment status or participating in the letter of acceptance verification system,” notes the IRCC.

Similarly, Canadian immigration officials currently lack the authority under the existing regulations to require international students to notify them when they change colleges or universities.

“As a result, IRCC is unable in many cases to confirm student attendance and study permit compliance when a student changes DLIs,” notes the IRCC. 

“When students move between institutions without notification, this risks circumventing the study permit cap which has a negative effect on DLIs.”

Under the proposed regulatory changes, DLIs would have to:

• confirm, within 10 days of a request, that a student has been accepted to undertake a program of study indicated on the study permit application;
• submit a compliance report, within 60 days, about the enrollment status of each student who has been accepted to that institution and an indication of whether they are actively pursuing their course or program of study;
• within 10 days, correct or provide additional information to the information in a compliance report and;
• within 10 days, provide any further information required, such as information related to study permits or study permit applications that name the DLI.