IRCC Updates How Officers Assess Study Permit Compliance — June 2026

On June 18, 2026, IRCC published a Program Delivery Update revising the instructions its officers use when assessing whether a study permit holder is complying with their conditions. This update does not change the Immigration and Refugee Protection Act or its Regulations — your legal obligations as a study permit holder remain the same. What has changed is how carefully and consistently officers are now expected to examine compliance, and what they are specifically instructed to look for. In practical terms, that distinction matters: more structured officer guidance means more thorough compliance reviews at every stage where your study history is relevant — extensions, post-graduation work permit applications, restoration of status, and permanent residence pathways.

Transferring to a different institution: get authorization before you move

The update makes clear that changing from one post-secondary Designated Learning Institution (DLI) to another requires obtaining the appropriate study permit authorization before the transfer takes effect. Officers are now explicitly instructed to check whether the student attended the institution named on their permit, whether a new study permit or condition amendment was obtained before changing DLIs, and whether the transfer complied with the rules in place at the time. An unauthorized transfer — moving to a new school without first updating your study permit — can be treated as a breach of conditions regardless of how long ago it occurred or whether you have since completed a program.

• If you transferred DLIs without first obtaining the required permit update, raise this with your immigration consultant before filing any extension, PGWP, or status application
• If you are currently planning a transfer, obtain the new authorization before attending any classes at the new institution
• Retain all documentation of the transition: acceptance letters, correspondence confirming your transfer date, and proof of the permit update

Changing programs or majors at the same institution

The update draws a clear line between DLI transfers — which require permit authorization — and program changes within the same institution, which are treated differently. Changing your major, switching to a different program, or moving between levels of study (for example, from a diploma to a degree program) at the same DLI is generally acceptable, provided you remained enrolled at the same institution, continued actively pursuing studies, and continued to meet all permit conditions. Officers are not instructed to treat every internal program change as a problem — they are expected to assess whether the student remained genuinely engaged in their studies throughout.

• Keep written confirmation from your institution of the program change and the date it took effect
• Ensure there was no gap in enrollment between programs — a period of non-enrollment at the same institution can attract scrutiny
• If you moved to a significantly different level of study than the one originally permitted, confirm this was authorized under your existing permit conditions

What "actively pursuing studies" now means under the updated guidance

Officers have always been required to assess whether a study permit holder was genuinely studying. The June 2026 update gives officers much more specific guidance about what evidence to look for when making that assessment. The question is whether the student was making reasonable progress toward completing their program — not whether they had a perfect academic record. Officers are instructed to look at the whole picture, including explanations for interruptions.

• Enrollment records confirming registration in each academic period
• Transcripts showing courses completed and grades received
• Evidence of progression toward the credential
• Attendance records where available
• Explanations for any interruptions — medical issues, institutional disruptions, or personal circumstances
• Supporting letters from the institution confirming academic standing
• If you had a difficult semester, documented circumstances supporting your compliance record should be retained and disclosed proactively

Authorized leaves: what qualifies, the 150-day limit, and what you cannot do

The updated instructions clarify more precisely when a leave from studies is considered authorized. The core rules have not changed, but the guidance is now explicit enough that officers have fewer reasons to give students the benefit of the doubt on undocumented leaves.

• Authorized leaves generally cannot exceed 150 days in total during the permit period
• The leave must be approved by your Designated Learning Institution — informal or self-declared absences do not automatically qualify
• Exceptions apply where an institution temporarily closes, for example due to a labour disruption or public health emergency
• A leave that exceeds 150 days, or that was not formally approved by the institution, is likely to be treated as a compliance issue
• Retain written evidence of any approved leave: confirmation emails, formal leave letters, and any institutional documents specifying the approved dates

You cannot work during an authorized leave — even if your permit shows work authorization

This is the point where the most misunderstandings occur in practice. Many study permit holders assume that because their permit authorizes on-campus or off-campus employment, they can continue working during an approved leave from studies. The updated instructions make the position clear: work authorization under a study permit is conditional on being actively enrolled and pursuing studies. During an authorized leave — even one that is properly approved and within the 150-day limit — the right to work is suspended. Students who worked during a leave period face a compliance finding regardless of what their permit says about employment.

• Stop working when a leave begins — the employment authorization on your study permit does not carry over to leave periods
• If you need income during a leave, seek advice on whether another work authorization applies to your specific situation
• If you worked during a past leave period, disclose this to your immigration consultant before applying for an extension, PGWP, or permanent residence

Documents officers may now request in a compliance review

The updated manual gives officers a standardized list of documents they may request when verifying compliance. Officers will not request all of these in every case, but this list tells you what you should be retaining throughout your study period — because any of these items may be requested at extension, PGWP, restoration, or permanent residence application stage.

• Official enrollment confirmations for each academic term
• Complete transcripts covering the full period of the permit
• Withdrawal records if you withdrew from any courses
• Suspension or academic probation letters if applicable
• Leave documentation approved by the institution
• Medical records or letters if health-related interruptions occurred
• Proof of institutional closure or disruption where relevant
• Any other documents establishing enrollment status and academic standing throughout the permit period

Consequences of a non-compliance finding

The update reiterates existing consequences while signalling that officers are now better equipped to reach and document a compliance finding. A finding that you violated study permit conditions can have effects that extend well beyond the application in which the finding is made.

• Loss of student status, meaning you are no longer authorized to remain in Canada as a student
• Requirement to apply for restoration of status, which is only available within 90 days of losing status and involves its own eligibility requirements
• Possible requirement to leave Canada if restoration is unavailable or refused
• A compliance finding can affect future temporary resident applications — visitor visas, work permits, and subsequent study permits — as officers assess prior adherence to conditions
• Post-graduation work permit eligibility can be affected if non-compliance is identified at that stage
• Non-compliance history can surface in Express Entry or provincial nominee applications when permanent residence is pursued

What to do if any of these situations apply to you

If your study permit history involves any of the situations described above — an unauthorized DLI transfer, a gap in enrollment, a leave during which you continued working, or periods where you were not actively pursuing studies — the right step is to seek advice before your next application, not during it. Undisclosed compliance issues are more damaging when discovered by IRCC than when raised proactively.

• Review your full enrollment history with your immigration consultant before filing any application
• Gather and organize all documentation now: transcripts, enrollment letters, leave approvals, and correspondence with your institution across the whole permit period
• If a compliance issue exists, assess with your consultant whether voluntary disclosure or a restoration application is the right approach
• If a PGWP is your next step, verify your study record meets the compliance requirements before submitting — a refused PGWP is difficult to recover from
• Keep these records permanently: compliance history questions can arise in permanent residence applications years after your study permit has expired

Study permit compliance reviews are now more structured and more consistent as a result of this update. If your study history is clean and well-documented, the practical impact is limited. If there are gaps, unauthorized transfers, or leave periods where you were working, those issues are better addressed before IRCC encounters them independently. Contact our office to review your study permit history before your next application.