The Game of Progress in Canada’s International Student Policy
By Earl Blaney RCIC
As we approach the ten-year mark of the formation of Canada’s International Study Program (ISP) framework (2012)1 it becomes crucial to objectively evaluate Canada’s accomplishments and
challenges in this field. There is no question that the program has enjoyed significant success, but at
what cost? Canada prides itself on its reputation of fairness, but what is happening to our international students is anything but, and the consequences could be devastating for Canada’s international reputation.
Does Canada’s International Study Program cause more harm than good? The question will likely resound as inappropriate in some circles, but that highlights the large imbalance of the perspectives and positioning of the parties involved. It is a concern that an objective analysis may not be forthcoming.
There are plenty of reasons to believe conducting an unbiased, open-minded evaluation is ill-suited to the interests of controlling parties that benefit greatly from the status quo. Of further concern is the increasingly insurmountable evidence that the interests of the consumer, a vulnerable demographic due protection under Canadian law,2 are being trampled by the big business model that international education in Canada has become.
As international students’ ground level struggles with Canada’s ISP begin to gain significant attention, light is shed on serious problems pervasive in all phases of the international student immigration lifecycle.3 Serious concerns related to program integrity, ethics and sustainability combine to call for an urgent re-examination of Canada’s ISP policy. Progress must be made to improve the security of investment students are making, to ensure more well-rounded benefits and to protect Canada’s international reputation.
Across Canada models of student support are so outdated, that they fail to reflect even a nuance of the shift that has turned Canada’s international education program from an academic exercise to an immigration program more than half a decade ago.4
Government of Canada executives would likely rebuke the proposition, highlighting the value of revenue, skill sets and cultural contributions, while championing other broad stroke aspects of progressive internationalization.
Ed-tech, the sector profiting the most from Canada’s resounding growth in edu-export, would likely retort with any one of the countless marketing mottos, paid for by their investment groups out of Southern California. Those who claim to be virtuously dedicated to “educate the world” and to ensure “international education is a right not a privilege” 5 (so long as it’s profitable enough).6
Banks lobby for profits, forecasting doom, if calls for rapid expansion are unheeded.7 Canada’s financial institutions stand a lot to gain from increased levels of international student arrivals, and have managed to coordinate the inclusion of their services as mandatory components of the overseas study permit application process.8
Amongst the celebrations and self-congratulations, there has been a tendency to disregard an often-dangerous set of circumstances that meets hundreds of thousands of international students coming to Canada each year. These issues become harder to ignore, as they gain significant national media attention.9
The vast majority of international students are pursuing education in Canada primarily for the prospects of permanent immigration;10 a better life in Canada. For these stakeholders, the question represents the crux of an investor’s perspective, and it often remains an open question throughout their stay. A persistent stress, echoing in their minds, as they attempt to navigate the uphill challenges ahead.
The Playing Field
While it could be easily argued or excused that any product being sold is subject to the caveat of “buyer beware”, this risk is curtailed by fair messaging principles. But in the case of international students, marketing and consumer messaging is exempt from levels of protection afforded to Canadian consumers. In the edu-export sector, recruitment is predominantly conducted by a massive web of unaccountable, unregulated education agents, either loosely associated (or entirely disconnected) with the commission paying Canadian education institutions that provide lifeblood.
In short, many international students have no idea what they are getting themselves into before they arrive to compete, and once committed, there is very often no choice but to proceed. My experience has been that, when regulations are in place, they are ignored, manipulated, or excused as irrelevant, especially when a conflict has the potential to impact the numbers game.
Within the decade of Canada’s mainstream focus on international education export, only one province in the country has thought to enact legislation to protect consumers. In 2016 Manitoba, a province receiving less than 3% of Canada’s international student intake,11 was concerned enough about recruitment agent ethics to enact The International Education Act, C.C.S.M. c. 175 (“Act”)12 with accompanying regulations.13 One of the two expressed purposes of the Act was to “provide consistent standards for recruiters in recruiting prospective international students.”14 Among firmly established requirements were: that all recruitment agents used by education institutions in Manitoba be listed on institution websites, that recruiters enter directly into a contract with education institutions, that recruiters be subject to training and compliance requirements, and that recruiters be monitored by education institutions on an ongoing basis for compliance with all components of the Act and its regulations.15
By December 2019 the Registration and Accountability Office in Manitoba (Ministry of Education, Division of Education and Training), responsible for overseeing the Act, had received at least one lengthy complaint16 specific to ed-tech companies whose business model centred on outsourcing their respective recruitment contracts with thousands of sub agents. The sub agent entities, typically unknown to respective education institutions in Manitoba, appeared to be operating with carte blanche immunity from the consumer protection mechanisms imposed by the Act. The responsible authority refused to investigate the complaint, on the basis that the Act and regulations, did not (explicitly) prohibit a recruiter from subcontracting recruitment services.17 Arguably, this decision in itself rendered large parts of the legislation ineffective.
Global Affairs Canada also has rules, to protect students from undue solicitation at Edu Export events to maintain an arm’s length objective independence.18 Lest the government of Canada be seen as unduly supporting the interest of certain immigration agencies and education agents over others.19 There are explicit prohibitions built into this policy, designed to maintain the integrity of Edu Canada events, to prevent the inclusion of any “organization, as part of its portfolio, that also acts as an education agent/consultant assisting international students finding study options”20 from a sponsorship role in said events. Despite this, acute violations of this policy have been overlooked for “Internet Technology Companies (ITC)” whose business model appears explicitly tailored as an exact match to the prohibitive ineligibility criteria. Might this be interpreted as a quid pro quo to facilitate the highest edu-export numbers possible?
Coinciding in time with the roll out of Canada’s ISP were changes to Canada’s Immigration Act and regulations that made it a criminal offence to engage in immigration representation, for consideration, unless authorized by section 91 of Canada’s Immigration and Refugee Protection Act.21 Shortly hereafter, in 2013, Caroline Melis, Director General of Operational Management and Coordination (CIC), issued a directive to Canadian educational institutions across Canada warning them that compliance in the
area of student recruitment was a firm requirement. The Melis Directive read, in part, “The goal is to protect clients, including international students, and to ensure that those providing advice are
all subject to the same requirements and achieve the level of expertise necessary to assist in often complex immigration matters. Education agents, recruiters and employees at education institutions who are paid to provide services to their clients are prohibited from providing advice to students.”22
At about the same time (2012) Canada participated in discussion with other countries regarding the development of a Code of ethics for international student recruitment agents known as the London Statement. However, Canada declined to become a signatory party to what otherwise appears to be a very agreeable set of principles likely for the reasons set out above.23 The term education agent is, in my view and in my experience, essentially synonymous with unauthorized immigration practitioner (UAP).24 In fact, the nature of DLI’s recruitment compensation system promotes non-compliance (if an education agent’s clients do not pass immigration, there is no commission pay out from the schools).25 However, despite the fact that senior IRCC officials have insisted overseas missions processing applications
have a strict policy in place to not process applications submitted by UPA’s,26 the department’s own
review process has uncovered that this is often not the case.27 If the Department is positioning itself as a tech revolution that will make Canada’s immigration system “the envy of the world”,28 the review processes must become more rigorous where the technology supports these key protective measures
There are regions around the globe that have taken action to regulate membership and enhance professional standards.
Hong Kong is a market that provides such an example. In 2018 the Hong Kong Consumer Council
published a detailed investigative report entitled Are Students Protected? An In-depth Look Into Overseas Education Advisory Services.29 That report uncovered significant potential
harm to consumers through a secret shopper investigations and student consultations. The report’s recommendations revolved around improving consumer protection through establishing a code of conduct for Hong Kong International Education Consultants’ Association (HKICEA) and bolstering the impact of that self-regulating entity and the government of Hong Kong through increased
Although, Canada’s Trade Commissioner’s office in Hong Kong has detailed how important a tool the HKICEA is to protecting consumers in that market, and referenced the above report, membership in that organization is not a requirement for association with the Canadian embassy in Hong Kong to facilitate edu-export to Canada.
The Numbers Game:
In 2012, Canada’s Advisory Panel on Canada’s International Education Strategy Committee laid out the
groundwork for a massive expansion of international student investment in edu-export.31 The primary recommendation, was to double the number of international investors consuming Canada’s international edu-export product.32 The goal was embraced wholeheartedly by newly created international departments at post-secondary institutions across Canada and positioned front and centre in the government of Canada’s first ever International Education Strategy (2014).33 Likely because of
the direct benefits that this goal presented to education institutions across Canada, the goal was met in less than three years flat (2017).34
Immediate benefits were apparent in record surpluses posted by post-secondary institutions across Canada35 and numbers grew—to the point where calls for incoming targets dropped altogether in the second version of Canada’s International Education Strategy published in 2019.36 By that time, Canada had nearly doubled its target of doubling edu-export totals. Government policy planners had anticipated receiving a manageable 450,000 international students by 2022; according to data from Global Affairs Canada they received 826,000 by 2019.37
By the same year, “internationalization” was accounting for all growth in post-secondary enrollment which allowed respective provincial ministries to continue funding cuts to colleges and universities Canada wide.38 It seems provincial governments have reason to embrace the numbers game as well.
To facilitate new recruitment growth, the government of Canada and DLI’s across Canada have aligned with large private ed-tech companies that accelerate recruitment through vast networks of sub-agents.39 These sub agent recruiters are almost always unknown entities to the education institutions they recruit for but are empowered and semi-legitimized by online-connection platforms which facilitate these kinds of recruitment measures. Some of these recruitment platforms have been so successful
they have been valuated in the billions, while earning millions, and make bold claims about their control of crucial edu-export markets.40
These platforms go so far as to lure prospective clients with the prospects of increased odds of immigration success, something that would be considered professional misconduct if claimed by an authorized immigration practitioner.41 Recently, these aggregator
platforms have initiated another practice of concern, using their fast growing wealth to finance international student loans to assist their client in gaining immigration approval. This practice may be at odds with the government of Canada’s program integrity objectives in ensuring those who apply for student status in Canada have the financial means to support themselves. Certainly, a conflict is apparent with aggregator platforms business agendas, which is to collect commission incentives from
Canadian DLI’s for each successful arrival.42
Even something as disruptive as a global pandemic did not severely impact Canada’s net yields in edu-export numbers. Global Affairs Canada’s Director General of Investment, Innovation & Education recently announced a limited shrinkage equating to less than 12%,43 a temporary setback, which the history of industry initiative suggests is easily recoverable, if necessary to recover in the first place.
With edu-export target numbers secure and with expected benefits to Canadian stakeholders accomplished, the next logical and, in my opinion, crucial step is to balance those interests with the interests and expectations of the consumers, a key factor in any measure of sustainability.
From the international student lens, this period of insatiable expansion is far less attractive. Limitless recruitment initiatives often mean more limited choices in program and institution selection, higher fees,44 less resources available for student support,45 fewer housing options at greater expense,46 more post-grad labour market com- petition and most importantly—fewer seats available for
students to transition to permanent resident pathways.
None of the above substantially impacts Canada’s recruitment impetus but all significantly impact consumer experience.
The Squid Game:
What do these students seek? How are their best interests aligned with program delivery? Is the program designed to attract future permanent residents? While entry to Canada and the study program is the marker of success for the facilitators, many look for permanent residence options. At most 30% of them will be successful by system design.47
How does that equate with messaging on the intake? Granted entry to temporary status cannot be a guarantee of permanent residence but is 30% justifiable? Putting aside larger questions of the impact of students leaving their countries of origin, many crucial domestic questions are abound as to the ultimate goals of the program and how those goals align with the best interests of those most impacted: the students.
In the next part of this article I will be covering the various elusive challenges that international students are forced to undertake. Stay tuned!
1 International Education (2012). “International Education: A Key Driver of
Canada’s Future Prosperity”. Government of Canada. Available:
2 Caroline Melis, Director General Operational Management and Coordination
(24 May 2013). “Directive to Canadian Post-Secondary institutions”.
Citizenship and Immigration Canada.
3 For example: Dakshana Bascaramurty, Neha Bhatt and Uday Rana (6
November 2011). “In India and Canada’s international student recruiting
machine, opportunity turns into grief and exploitation”. The Globe and Mail;
Nicholas-Hune Brown (18 August 2021). “The Shadowy Business of
International Education”. The Walrus Magazine; Grant LaFleche, Isabel
Teotonio, and Nicholas Keung (25 September 2019). “’I’ve given up
everything.’ Explosive growth in international students comes at a steep
cost”. The Standard; Office of the Auditor General of Ontario. (December
2021). Value-for-Money Audit: Public Colleges Oversight.
4 In 2016 Ministerial Instructions from Minister of Immigration, Refugees, and
Citizenship Canada extending the Comprehensive Ranking System (CRS)
points to students earning a Canadian post secondary credential was a
primary factor leading to the explosion of international students in Canada
from 410,000 in 2016 (see: CBIE (August 2018). International Students in
Canada.) to 721,000 in 2018 (see: Immigration, Refugees and Citizenship
Canada. “Greetings from the Minister of Immigration, Refugees and
Citizenship, Building on Success: Canada’s International Education Strategy
(2019-2024)”. Government of Canada.
5 For example: ApplyBoard. Join ApplyBoard for the Educate the World
Conference; ApplyBoard. “Education is a right, not a privilege!”. Youtube.
6 See example of fee schedule for ApplyBoard, which lays out higher sets of
charges for groups representing different demographics (including higher
fees for applicants from particular countries of origin): <https://drive.google
7 Royal Bank of Canada (May 2017). Attracting International Talent. Available:
8 For example, Guaranteed Income Certificates (GICs) issued by major
Canadian banks are now firmly established as main eligibility factors for
Studen Direct Stream study permit applications. Immigration, Refugees and
Citizenship Canada. “Student Direct Stream (SDS)”. Government of Canada. Available:
9 Significant media attention has begun to shine light over dangerous
circumstances that face international students both via the recruiting
process as well as after arrival in Canada. See for example: Nicholas-Hune
Brown (18 August 2021). “The Shadowy Business of International Education”.
The Walrus Magazine; and Isabel Teotonio, Nicholas Keung, and Grant
LaFleche (25 September 2019). “‘I’ve given up everything.’ Explosive growth
in international students comes at a steep cost”. Toronto Star.
10 For example: Statistics published by the CBIE shows that 60% to 68% of
international students recruited to study in Canada intend to transition to
Permanent Residence (PR). CBIE. Retaining International Students in
Canada Post-Graduation: Understanding the Motivations and Drivers of the
Decision to Stay. (Page 2) Available: <https://cbie.ca/wp-content/
11 International Education. “Economic impact of international education in
Canada — 2017 update”. Government of Canada. Available: <https://www.
12 Economic Development and Training. “The International Education Act
C.C.S.M c. 175”. Government of Alberta. Available: <https://www.edu.gov.
13 See regulation 218, “International Education Regulation”, and regulation 1,
“Code of Practice and Conduct Regulation” in The International Education
Act, C.C.S.M. c.175.
14 See section 17(2) of The International Education Act, C.C.S.M c. 175.
15 See in particular sections 17-21 of The International Education Act, C.C.S.M c.
16 Ms. Agnes Wittmann, Director of International Students (20 December
2019). Re: Seeking Remedy in Regard to Alleged Non-Compliance under the
Manitoba International Education Act. Available: <https://drive.google.
17 Ibid. See page 14 (which is a copy of page 2 of the response from Manitoba’s
Advanced Education and Skills Division, which refused to investigate the
18 International Education Newsletter (March 2018). March 2018 Newsletter:
Prepared by the International Education Division (BBY); and ApplyBoard.
Apply to Study Abroad at Your Dream School. Available: <https://drive.
19 Aside from concerns about how favouring one such company over another
might be perceived with suspicion, from a program integrity point of view, it
might also cause conflict with Canada’s Competition Act, R.S.C., 1985, c. C-
20 International Education Newsletter (March 2018). March 2018 Newsletter:
Prepared by the International Education Division (BBY).
21 Bill C-35, An Act to Amend the Immigration and Refugee Protection Act,
received Royal Assent on March 23, 2011, and came into force on June 30,
22 Caroline Melis, Director General Operational Management and Coordination
(24 May 2013). Directive to Canadian Post-Secondary Institutions. See
page 1, paragraph 3. Available: <https://drive.google.com/file/d/
23 Statement of Principles for the Ethical Recruitment of International Students
by Education Agents and Consultants (To be known as the London Statement)
(March. 2012). Accessed via Access to Information Request. File No. A-2019-
02396/RS. Available: <https://drive.google.com/file/d/1nVfsVMeG9
24 Any significant review of service offerings from “education agencies” will
lead you to see a relationship between education agents and unlicensed
immigration service advice. Take for example these education agents,
previously featured on ICEF’s website: <https://drive.google.com/file/d/
25 Earl Blaney (1 July 2017). “No One Listens to the B Side: The Unheard Story of
Canadian Post-Secondary Insitutions’ refusal to Comply with IRPA S 91”.
Linkedin. Available: <https://www.linkedin.com/pulse/one-listens-b-side
26 Standing Committee on Citizenship and Immigration (CIMM). 42nd Parliament,
1st Session (May 6, 2019). House of Commons Canada. Available:
27 Immigration, Refugees, and Citizenship Canada (March 2014). “Evaluation
of the Immigration Consultants of Canada Regulatory Council”. Government
of Canada. Available: <https://www.canada.ca/en/immigration-refugeescitizenship/
28 “My vision for our immigration system going forward is that it is completely
virtual and touchless and that each and every one of these steps is integrated
so that we become the envy of the world,” Mendicino says in an online
interview with TVO. “Transcript: Marco Mendicino: Canada Canadian
Immigration Cope Amid Covid?” (8 January 2021). TVO. Available:
29 Honk Kong Consumer Council (11 March 2018). Are Students Protected? An
In-depth Look into Overseas Education Advisory Services. Available:
31 Global Affairs Canada (August 2012). “International Education: A Key Driver
of Canada’s Future Prosperity. Advisory Panel on Canada’s International
Education”. Government of Canada, Available: <https://www.international
33 Global Affairs Canada. “Canada’s International Education Strategy”.
Government of Canada. Available: <https://www.international.gc.ca/
34 The advisory committee has called for doubling the number of international
students in Canada from 239,000 in 2011 to 450,000 by 2022. Numbers
grew to over 494,000 by 2017. See CBIE (August 2018). International
Students in Canada.
35 Alex Usher (16 September 2020). “The State of Postsecondary Education in
Canada, 2020”. Higher Education Strategy Associates. Figure 1, Available:
36 International Education. “Building on Success: International Education
Strategy (2019-2024)”. Government of Canada. Available: <https://www.
37 Emmanuel Kamariankis, Director General of investment, Innovation &
Education (Global Affairs Canada) (7 November 2021). Post, LinkedIn.
38 Statistics Canada (25 November 2020). “International Students Accounted
for all of the Growth in Postsecondary Enrolments in 2018/2019”. The Daily.
39 Retrieved through Access to Information Request number A 2019-0157/
CRR, released on 9 June 2021. The contents of this release can be accessed
publicly, here: <https://drive.google.com/file/d/1fs9ZtGJvnvxoyyODcUt0A
40 Sternlicht, Alexandra (15 June 2021). “Study Abroad EdTech ApplyBoard
Triples Valuation to $3.2 Billion with $300 Million Fundraise”. Forbes.
41 Meti Basiri (21 July 2021). “ApplyInsights: ApplyBoard Students More Likely
to Receive Canadian Student Visa Approval”. ApplyBoard. Available:
Consultants of Canada Regulatory Council (2019). RCIC Code of Professional
Ethics, section 2.2.9 “Professional Misconduct”, which states that
“professional misconduct” means conduct in the Member’s practice that is
inconsistent with this Code, including:
(v) offering, promising, stating or implying that the Member will
influence any government agency or official to make a positive
decision in any immigration matter;
(vi) offering, promising, stating or implying that using or continuing
to use the services of the Member will result in a favourable
exercise of discretion by IRCC.
42 Sophie Hogan (10 January 2022). “Leverage Edu Launches financial
services”. The Pie News. Available: <https://thepienews.com/news/
43 Emmanuel Kamariankis, Director General of investment, Innovation &
Education (Global Affairs Canada) (7 November 2021). Post, LinkedIn.
44 Carlo Handy Chales and Veronica Overlid (3 July 2020). “Tuition Hikes
Exacerbating Existing Challenges for International Students”. Policy
Options. Available: <https://policyoptions.irpp.org/magazines/july-2020/
Statistics Canada (21 September 2020). “Tuition fees for degree
programs increase in 2020/2021”. The Daily. Available: <https://www150.
45 For example: See increase of demand for immigration related support
services at Fanshawe College (2019-2020) while number of staff licensed to
provide that support has not increased. Jen Hiles and Dayan Boyce (10 March
2021). “Informal Request for Information”. Interpersonal Communication.
46 The influx of international students has produced a well document hike in
rental prices, especially in major urban cetnres. See: Jennifer La Grassa (23
September 2021). “Post-Secondary school students in Canada face ’perfect
storm’ that’s hit their housing budgets”. CBC News. Available:
1.6185655>; Douglas Todd (15 February 2018). “Douglas Todd: Vancouver’s
rental and housing markets pressed by ’temporary’ residents”. Vancouver
Sun. Available: <https://vancouversun.com/opinion/
47 Youjin Choi, Eden Crossman, and Feng Hou (23 June 2021). “International
Students as a Source of Labour Supply: Transition to Permanent Residency”.
Statistics Canada. Available: <https://www150.statcan.gc.ca/n1/pub/36-