By: Andrew Carvajal and Laura Ricaurte
New Ministerial Instructions (MI) with respect to the processing of certain applications for a study permit made by a foreign national as a member of the student class take effect today, January 22, 2025.
The new Ministerial Instructions establish the 2025 cap for study permit applications and limit the available exemptions to the requirement for a Provincial Attestation Letter (PAL). These updates will significantly impact the processing of future study permit applications and the eligibility of prospective international students without a PAL. Below is a summary of the most important changes introduced by the new instructions.
New Cap for Study Permit Applications – 437,000 Approvals
For 2025, the Government of Canada has set a new cap for the number of study permit applications that will be accepted for processing. The cap is 550,162 applications, which is expected to yield approximately 437,000 approved study permits—marking a 10% decrease from 2024.
Updates to the Provincial Attestation Letter (PAL) Exemptions
The PAL is a critical requirement for many study permit applicants. First introduced in January 2024, this document must be included with all study permit applications unless an exemption applies. The PAL confirms that the applicant has been allocated a space within the provincial/territorial study permit quota for the year. Applications submitted without a PAL will be returned, and processing fees will be refunded.
Since the introduction of the PAL requirement, there have been changes to the exemptions. Below is a summary of the updated rules—the most restrictive to date—along with a comparison of who remains exempt and who is no longer exempt.
Still Exempt from the PAL:
Primary and secondary school students: Applicants for study permits at the primary or secondary school level remain exempt.
Some study permit extensions: Applicants renewing their study permit at the same Designated Learning Institution (DLI) and same level of study are exempt. Last year, this exemption applied to all study permit extensions.
Some minor children accompanying workers or students: Dependent children who are exempt from a study permit and are now switching to a study permit at the same DLI and level of study do not require a PAL. Previously, this exemption applied to all study permit applications for this group.
Family members of foreign government representatives: Family members of foreign government representatives who are exempt from a study permit and are now switching to a study permit at the same DLI and level of study do not require a PAL. Previously, this exemption applied to all study permit applications for this group.
Exchange students on visitor status studying at a DLI.
Recipients of scholarships administered and funded by Global Affairs Canada.
Participants in the Francophone Minority Communities Student Pilot.
Foreign nationals studying at institutions administered by a federal department or agency (per section 211.1(a)(i) of the IRPR).
Other exemptions: This includes certain protected persons, Temporary Resident Permit (TRP) holders with permits valid for at least six months, individuals eligible for permanent residence under specific in-Canada programs, and foreign nationals exempt under the Temporary public policy to exempt certain Indigenous persons and their family members from temporary residence requirements.
No Longer Exempt from the PAL:
Master’s and PhD students.
Work permit holders applying for a study permit: Applicants transitioning from a work permit to a study permit now require a PAL.
Some visitors who were previously exempt: Visitors applying for a study permit, including those who completed prerequisite courses for enrollment at a DLI, must now submit a PAL.
Family members of work permit or study permit holders: Accompanying family members applying for study permits (e.g. 215(2) of the IRPR) are no longer exempt.
Transitional Provisions
Applications submitted between January 1 and January 21, 2025, will be processed under the previous instructions (MI79 from October 2024). Applications submitted before January 1, 2025, but not yet decided, will follow the rules in effect at the time of submission.
What This Means for You
The recent changes to the PAL requirement and study permit application process have significant implications for anyone considering studying in Canada. If you or your clients are applying for a study permit after January 21, 2025, it is crucial to determine whether a PAL is required. With the expanded PAL requirement, applicants in certain categories—such as master’s and PhD students, work permit holders transitioning to study permits, and temporary residents applying as visiting students—will now need to submit a PAL.
Given the complexities of these changes, it is essential to review your specific situation to determine the best course of action and ensure all necessary documentation is in place. As your immigration advisors, we can guide you through this process, advise on how the new policy might affect your eligibility, and help you navigate the application procedures efficiently.
For any questions or to schedule a consultation, please feel free to contact us.
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