• Considering a US$100,000+ fee for post-study Optional Practical Training (OPT) placements. The OPT work stream is among US universities’ top competitive strengths when recruiting talented international students, and research shows that more than half of international students would not choose the US if they could not access it.



• Applying greater scrutiny to Curricular Practical Training (CPT) placements, as articulated in two broadcast memos issued by the Immigration and Customs Enforcement department (ICE) on and . CPT allows a student (domestic or international) offered by a sponsoring employer through a co-operative agreement with the student’s school.

In the memos, ICE says that the Student and Visa Exchange Programme (SEVP) is showing an uptick in “CPT authorisations that do not meet regulatory requirements, specifically those not constituting an integral part of an established curriculum.” The insinuation here is that some institutions are promoting CPT as a general work route rather than as an essential curriculum requirement. The department warns: “If SEVP suspects that school officials are abusing CPT to create work opportunities rather than academic studies, they may be subject to additional scrutiny and action from SEVP and Homeland Security Investigations (HSI), to include potential withdrawal of the school’s SEVP certification.”

The department cautions: “In any instance where an elective course is optional, making the CPT optional, the integral and required aspects of CPT would not be met … [CPT should be authorised only] if its absence would make the attainment of a degree an impossibility.”

The power of rhetoric

The State Department has neither imposed the US$100,000 OPT fee nor amended the CPT programme through law. However, the department is clearly communicating its concern around both programmes, and this is serving a two-fold rhetorical purpose:

• To warn prospective international students that access to work in the US is far from certain for them;
• To discourage universities from linking academic programmes with work routes in their promotional or operational activities.

Most universities are pausing their authorisation of elective CPT programmes while continuing their curriculum-linked CPT. Even though the memos are, as Carnegie Mellon has called them, “extra-regulatory,” they carry enforceable actions. If a university were be seen to be abusing the CPT system, it could have its SEVP certification removed and would thus be barred from enrolling international students.

Even though the guidance will be a concern for all universities and colleges, the cautions from ICE may be especially aimed at a small group of US institutions that are colloquially known as “” universities, and where the promotion of work-integrated learning via CPT placements is . The critique that attaches to such institutions is essentially that they are over-promoting or overusing CPT, and providing a mechanism for students to bridge visa status while they remain in the US in the hopes of transitioning to an H-1B visa or otherwise preserving their ability to work in the country.

A layered approach

A potential OPT fee and CPT warnings are just two layers of the Trump administration’s mission to limit opportunities for international students in the US. On 15 September, the new rule replacing Duration of Status (D/S) with an Admit-Until-Date (AUD) system comes into force. For those needing background on the importance of this change, we have covered this extensively over the summer, including in this article.  

The imminent end of D/S has created additional uncertainty for US universities attempting to update systems and advise students, and it appears to have already dampened demand for study in the US. International enrolments declined in 2025, especially in graduate programmes.

Graduate programmes “in crisis”

In July 2026, reported on the effects of the Trump administration’s approach to immigration and to higher education and science in general:

• “Cornell University enrolled 209 fewer new grad students last year, with declines across nearly all of its schools.
• Michigan State University paused admissions to most of its advanced programs in the humanities for a year to assess them for “long-term sustainability.”
• Massachusetts Institute of Technology has been shaken by a 20% drop in the federally funded research that made its graduate programs into an innovation powerhouse.”

Bloomberg interviewed Chevelle Newsome, president of the Council of Graduate Schools, who said that graduate schools are in a “crisis response” mode that “will take decades to recover from.”

Perception influences behaviours

For most research universities, restricting CPT as per ICE’s guidance is not a big deal. At prominent institutions such as UCLA, less than a quarter of international students participate in CPT – a fraction compared with the number participating in OPT. But what is a big deal is that international students are hearing that both OPT and CPT are under greater scrutiny. The government is creating a perception that work opportunities in the US are diminishing without even having to pass laws to that effect.

There are important developments on the horizon that aim to counter that perception by curbing the government’s ability to implement more restrictive policy. For example, NAFSA and seven other educational and business organisations have filed a complaint to halt the implementation of the fixed-term admission period for international students and other visitors.

The consortium is challenging the legality of the rule and has also filed a motion for a preliminary injunction that aims to prevent the rule from coming into effect. The request for an injunction will be heard in court in early September.

In addition, the upcoming mid-term elections (3 November 2026) may provide for some further balance in the US system. Amid rapidly deteriorating approval ratings for President Trump, that the mid-terms will return control of the House of Representatives to the Democrats. This would give the House more ability to counter executive action from the White House, including those concerning education and immigration.

Key developments for the new academic year

As of this writing on 3 September 2026:

• CPT: The Department of Homeland Security says, “Nothing about [CPT] regulations has changed. However, schools and employers should consider themselves on notice: under President Trump, abuse of this generous system will no longer be tolerated.”
• OPT: A new rule on OPT was on the agenda for 2026 but is now slated for publication in February 2027. A $100,000 OPT participation fee is under discussion, but it has not transitioned to the proposal phase.
• Duration of Status: Duration of Status (D/S) will be replaced by Admit-Until-Date (AUD) on 15 September unless a preliminary injunction is delivered before then. Current international students who have not returned to the US before that date will be subject to AUD despite first enrolling under Duration of Status terms. 

For additional background, please see:

• “US Department of State issued 23% fewer study visas to international students in 2025”
• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students“
• “US coalition files lawsuit to challenge rule ending Duration of Status admissions for international students“
• “Report: US considering a $100,000 fee for Optional Practical Training” 

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A preliminary injunction is a formal request asking a court to issue a temporary order early in a lawsuit – before the case is fully decided – to require someone to do something, or, as in in this case, to stop doing something. The goal of this filing is to compel the government to halt its implementation of the rule replacing D/S with a fixed visa permission of up to four years. After the limit is reached, students and visitors must apply for an extension to US immigration authorities. The final rule is meant to come into effect on 15 September 2026.

Parties to the legal challenge are:

• NAFSA: Association of International Educators
• The Presidents’ Alliance on Higher Education and Immigration
• The Association of Independent Colleges and Universities in Massachusetts (AICUM)
• The American Federation of Teachers (AFT)
• Graduate Labor Organization, AFT Local 6516 (GLO)
• International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)
• United Auto Workers Local 2322
• The NewsGuild-CWA

“Ending Duration of Status and imposing new limits on academic decision-making is a solution in search of a problem,” said NAFSA CEO and executive director Dr Fanta Aw. “The rule will severely undermine the contributions international students make to US campuses, economies, and national security. After carefully reviewing the final rule and the sweeping harm it will cause to our national interest, it is clear that litigation is warranted and necessary.”

McDermott Will & Schulte will represent the plaintiffs in the U.S. District Court for the District of Massachusetts.

Background

The D/S system was in place for decades, and it allowed international students to stay in the US to complete their full academic programme as well as to gain three years of post-study work experience. For more background on what the end of D/S means for students, universities, and businesses, please see our comprehensive article here.

Miriam Feldblum, president and CEO of the Presidents’ Alliance on Higher Education and Immigration says:

“This rule upends the longstanding Duration of Status framework that has allowed international students and scholars to pursue their educational programs while maintaining lawful status. By placing time limits that do not align with actual program lengths or students’ educational needs and shifting crucial academic decisions from institutions to immigration officials, the rule will disrupt educational pathways, impose significant new burdens on colleges and universities, and make the United States less competitive as the premier destination for global talent. We are going to court to protect international students and scholars and to defend our member institutions’ ability to educate, train, and retain them.”

What is the basis for the challenge?

The consortium argues: “The final rule violates the Administrative Procedure Act because DHS failed to adequately assess its costs and benefits, meaningfully respond to public comments, consider less burdensome alternatives, or justify the rule based on its stated objectives. It also alleges that DHS provided an inadequate public comment period and exceeded its statutory authority.”

“The United States once again is breaking the law for its own political purposes and, in doing so, is hurting Americans and American enterprise,” argues AFT President Randi Weingarten. “And it’s using international students – who we’ve welcomed here to help us – as its pawns. America is a leader in cutting-edge research because generations of scientists from every corner of the globe have been free to pursue difficult questions, challenge conventional wisdom, collaborate openly and publish their findings – without political interference. This latest assault on knowledge by the Trump administration arbitrarily limits how long international scholars have to complete their studies and risks turning a welcoming environment for students into a hostile one. We stand united with our higher education members, international and American alike, so they can continue to make US colleges and universities the envy of the world.”

What is at stake?

The plaintiffs explain: “These changes will create significant uncertainty and administrative burdens for international students and exchange visitors and the institutions that support them. They will also interfere with academic decision-making, disrupt students’ educational and professional plans, and undermine the ability of U.S. colleges and universities to attract and retain global talent.”

Robert McCarron, president and CEO of the Association of Independent Colleges & Universities in Massachusetts, comments:

“More than 80,000 international students come to Massachusetts to pursue higher education, adding vibrancy and innovation to our campuses and often founding startups in Massachusetts. These students and researchers drive innovation, pursue life-changing research, and create more than $4 billion annually in economic impact in Massachusetts. The litigation seeks to ensure that such profound changes to the rules governing international students and others comply with applicable legal requirements and reaffirms that Massachusetts continues to welcome talented students and researchers from across the globe.”

What happens next?

Legal observers expect that the court will take up the coalition’s request for emergency relief, which, if successful, would prevent the rule from coming into effect on 15 September.

The immigration law firm Fragomen notes in its guidance that, “Prospects for the lawsuit are uncertain, and employers and foreign nationals should continue to prepare for the scheduled implementation of the new regulation on September 15 in the event the plaintiffs’ efforts to obtain an emergency stay are unsuccessful.”

For additional background, please see:

• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students”

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This is the most serious sanction that can be levelled against a licensed sponsor. Revocation of the sponsor licence means that Bloomsbury, formerly the London School of Business and Management, immediately loses the ability to sponsor international students under the UK’s Student Route.

This means that it can no longer issue Confirmation of Acceptance for Studies (CAS). Any CAS already issued also now becomes invalid, and any pending visa applications based on a Bloomsbury CAS will be refused. The Institute will also be removed from the Register of Student Sponsors.

The revocation of the Bloomsbury Institute’s sponsor licence on 5 August 2026 follows the suspension of its licence on 9 June 2026, from which point it was forced to also suspend recruitment of international students.

The Institute’s licence was in the balance this year because Bloomsbury had not maintained compliance with the Basic Compliance Assessment (BCA) requirements. As the Home Office explains: “The Basic Compliance Assessment is an annual check that all sponsors must pass, measuring visa refusal rates, course enrolment and completion.”

Those BCA thresholds tightened this year, but Bloomsbury was assessed against the earlier benchmarks, which required that all sponsors maintain a visa refusal rate of less than 10%, an enrolment rate of at least 90%, and a course completion rate of at least 85%.

“Student sponsors must meet the standards required to retain their licence,” said the Home Office. “Failure to meet these standards represents a serious breach of its duties as an international student sponsor, and as a result, [Bloomsbury’s] licence was revoked.”

Effective 1 June 2026, the BCA thresholds were further strengthened such that visa refusal rates must be maintained below 5%; the course enrolment rate must be at least 95%; and the course completion rate must be at least 85%. Perhaps unnecessarily, the Home Office notes as well that, “The Bloomsbury Institute would also have failed to meet the new, stricter standards.”

A largely international student body

For 2024/25, the most recent available reporting year, HESA data indicates that the Bloomsbury Institute enrolled a total of 1,035 students. More than 800 of those, or nearly 80%, were international students, with the lion’s share (93%) coming from Pakistan.

The revocation of the sponsor license necessarily places the study programmes of those students, and even the future of the institution, in question. The Home Office says that its priority now is to “minimise disruption for international students already enrolled” at Bloomsbury.

To that end, the Institute “will be permitted to continue teaching its current sponsored students for a short period,” the term of which is not specified. Students who cannot complete their studies within that window will be supported to transfer to another institution.

Needless to say, those provisions are an important feature of the Home Office announcement. The headline is that a UK institution has had its sponsor licence revoked. But of course, behind that headline, are the many affected staff and students who now must deal with the uncertainty that accompanies this sanction against their institution.

For additional background, please see:

• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“
• “UK universities bracing for a further decline in international enrolments“
• “England: Government ‘remains of the view’ that the International Student Levy should go ahead; implementation planned for August 2028“
• “UK: Sponsored study visa issuances down, rejection rates up, and more“

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Based on institutional responses in IIE’s , the estimate is for a 9.5% decline in overall foreign enrolment in the US in fall 2026. This could result in . In economic terms, that translates to up to US$3.4 billion in lost spending and 39,000 jobs affected.

“The projections underscore what we’ve long warned,” said Fanta Aw, Executive Director and CEO of NAFSA. “US policy and regulations affect where international students plan to invest their future—and their decisions carry significant short- and long-term consequences for US society and economy, All Americans lose when international students and scholars are driven to more welcoming countries.”

Where is this coming from?

The analysis points to three major factors behind the projected decline in enrolment for 2026/27: reduced or diverted demand; process and policy around student visas; and policy uncertainty.

There are a number of indicators of declining demand for study in the US this year, whether those students are simply deferring their study plans or choosing an alternate destination. First, recent findings from the highlight that the international pool of doctoral candidates shrunk by -21% for 2026/27, a trend that led to an overall decline in international PhD admissions of -17%. Meanwhile, says that international applications filed via its college admissions platform are down -9% for the coming academic year. And, as we reported recently, nearly two-thirds of respondents to IIE’s Spring Snapshot Survey are expecting enrolment declines for 2026/27.

Those trends are no doubt influenced by a series of underlying issues around student visa processing. An expanded ban on travel to the US affecting citizens from 39 countries, including Nigeria, has been in place since 1 January 2026. While there has not been an outright pause on visa processing this year, the State Department’s prioritisation of visa processing for FIFA World Cup ticket holders traveling to the US supplanted the historical norm of prioritising student applicants during the peak processing months over spring and summer. Making the situation even more challenging, there are widespread reports of significant processing delays and in India, China, and Europe.

Finally, both announced and anticipated rule changes are combining to create additional uncertainty for international students in the US this year. A new rule will come into effect on 15 September 2025 to replace the longstanding “Duration of Status” framework with a fixed Admit-Until-Date (AUD). The new AUD mechanism sets a maximum limit for which a student visa can be granted, and requires continuing students to apply for an extension with US immigration officials. This, says NAFSA, creates “significant planning uncertainty for prospective students, particularly those considering longer-degree programmes,” and an issue which is compounded by “the current administration’s continued warnings that it intends to reform the Optional Practical Training programme.”

The need for speed

“Forfeiting the US position as the top destination for global talent hurts students, hospitals, research laboratories, the economy – and carries the real risk that the next big invention will not happen on US soil,” adds Dr Aw. “We urge the administration and Congress to take swift action to ensure international student contributions continue to benefit American ingenuity, economic prosperity, and national security.”

In order to ease the projected decline for 2026/27, NAFSA is urging the US administration to take the following steps.

• Prioritise processing for all F and M visa applicants as well as for those pursuing a J visa for exchange in the US;
• Exempt students and exchange visitors from the current travel ban “while maintaining background checks and vetting required for visa issuance”; and
• Preserve Optional Practical Training for foreign graduates in the US.

For additional background, please see:

• “Decline in Indian demand a major factor in softer outlook for foreign enrolment in US higher education in 2026/27“
• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students“
• “US regulatory agenda for 2026 aims to end ‘duration of status and introduce Optional Practical Training and H-1B reforms“
• “US extends travel ban, Nigeria now included on ‘restricted’ list“

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The hefty fee would apply to post-study Optional Practical Training (OPT) placements. Post-study OPT is the work stream that allows students who complete a minimum four-year bachelor’s degree to gain one to three years of work experience related to their field of study, and it often serves as a bridge from F-1 student status to at least three years in a formal position with a US employer on an H-1B visa. Three-year OPT is reserved for students with STEM degrees.

More than 294,000 students participated in OPT in 2024/25 – representing about one in four international students in the US. This was a 21% increase over the previous year.

Any move to limit access to OPT will upend foreign students’ estimation of the return on investment for study in the US. A recent Chronicle of Higher Education survey found that 8 in 10 international students would not choose to study in the US if they could not access OPT.

Nothing is certain yet

A Department of Homeland Security (DHS) spokesperson confirmed that the fee is under discussion, but it stressed in a statement to the paper that “no policy should be considered final until it is formally announced.” It is not clear yet who would have to pay the $100,000 OPT fee – students, universities, or employers.

OPT under fire

For decades, international students were permitted to stay in the US for as long as their study journey required, including three years of OPT participation, under a rule called Duration of Status, or D/S.

But a 2025 administration proposal to put fixed limits on international students’ legal status in the US will become a rule in September 2026. International students will have to leave after four years unless they submit, and are approved for, an extension by immigration officials.

This makes a potential $100,000 OPT fee even more off-putting to international students. Not only will they need to submit a request to US Citizenship and Immigration Services (USCIS) to stay in the US for longer than their length of their degree – with no guarantee they will be approved – but the $100,000 fee would make it even less likely that they would (1) be hired (if the fee were levied on employers) or (2) afford to be hired (if students themselves had to pay the fee).

If at first you don’t succeed …

It is quite possible that the government views a steep OPT price tag as a satisfactory equivalent to its September 2025 proclamation requiring employers to pay a $100,000 fee to sponsor a foreign worker for an H-1B visa. That ruling was later blocked in court. The administration submitted an appeal to reverse the decision, but a federal court rejected the appeal on 24 July 2026.

If the administration were to push through the $100,000 fee for OPT submissions, it could achieve the same goal as the as-yet unsuccessful H-1B fee of blocking a huge proportion of international graduates and skilled foreign workers from employment in the US.

Brain drain from the US is already happening

The potential for brain drain is real. The WSJ notes: “Advocates contend that without OPT, most international students would be forced to leave the country immediately after graduation, pushing them to take the skills they gained at American universities to foreign markets.”

Destinations such as Germany, France – and the US’s great-power rivals China and Russia – are already benefitting from lower student demand for the US. All these countries – and several more alternative destinations – are building their foreign enrolment at the same time as new international student commencements in the US (as well as in Australia, Canada, and the UK) decline.

The impact on universities and employers

International students’ contributions are vital to STEM-based sectors and to US innovation in general. For example, a 2025 Silicon Valley Index report found that 66% of technology workers in the region are foreign born.

The potential impact on Indian and Chinese enrolments

If enough Indian and Chinese students decide to stay away from the US, it could be a devastating revenue hit for many US colleges. More than half (53%) of all international students in academic programmes or OPT in the US are Indian or Chinese.

Doctoral-degree-granting institutions would be especially affected. Consider:

• Eight in 10 Indian students studying in the US in 2025 – and nine in 10 Chinese students – are enrolled at a doctoral college.
• Of 57,800 PhDs granted to all students in the US in 2023, 19,400 (34%) were awarded to F-1 international students, nearly half of whom (44%) were Chinese or Indian.
• Chinese and Indian students received nearly one-sixth (15%) of all PhDs awarded by US institutions in 2023.

It isn’t too dramatic to say that R&D innovation in the US would be significantly affected by a major fall-off in Indian and Chinese demand.

The Indian and Chinese flow of OPT students to US employers would also be severely impacted:

• Of all Indian students in the US in 2025, 40% were in OPT. This represents a near doubling of the proportion the previous year.
• Of all Chinese students in the US in 2025, 23% were in OPT.

Change is coming

Whether or not a $100,000 OPT fee comes into being, what is certain is that the Trump administration is currently considering new rules for OPT. There are few details at present, but new OPT rules are slated for introduction in February 2027. The government has indicated only that it will “amend existing regulations to address fraud and national security concerns, protect US workers from being displaced by foreign nationals, and enhance the Student and Exchange Visitor Program’s capacity to oversee the program.”

Lawsuits highly likely

Multiple lawsuits arose to fight the H-1B fee, and the fee has been declared unlawful. As of this writing, US employers do not have to pay the fee to hire international students or foreign skilled workers.

Litigation is already in process to contest the fixed admission rule set to come into force on 15 September 2026.

As reported by Forbes, “legal consultations have left experts questioning the administration’s lawful authority to impose a $100,000 OPT fee.”

For additional background, please see:

• “US regulatory agenda for 2026 aims to end ‘duration of status’ and introduce Optional Practical Training and H-1B reforms”

The post Report: US considering a $100,000 fee for Optional Practical Training appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

Meanwhile, the opposition Coalition, and, perhaps even more strikingly, the surging One Nation Party, continue to contend for public support, in part on a strong anti-migration message. The most recent opinion polling sees One Nation edging the official Liberal-National Coalition opposition for second place, and within striking distance of the governing Labor Party under Prime Minister Anthony Albanese.

All of which means it was noteworthy this week when the Minister for Immigration and Citizenship, Tony Burke, at The National Press Club. The Minister was widely expected to use the speech to “unveil far-reaching changes to Australia’s migration settings,” but a spokesperson for Minister Burke confirmed that “it became clear that some elements of the speech would not be finalised” in time for the Press Club appearance.

The move has led to considerable speculation over the direction of migration policy. Writing in , the University of Canberra’s Michelle Grattan said, “What this week’s toing and froing also signals is that the government knows making more drastic changes to immigration to bring it under control is now a strong political imperative.”

There is some irony in those political headwinds in that migration levels in Australia have actually been declining in recent years – the key measure for which is the Net Overseas Migration figure (NOM).

The NOM is the Australian Bureau of Statistics’ official indicator of the migration contribution to population change. The methodology behind it is somewhat complex and laggy, but in short: the NOM calculates the difference between the number of people arriving to live in Australia and the number leaving to live elsewhere, regardless of citizenship or visa type (and including Australian citizens and permanent residents).

The most recent NOM calculation is for the year ending 30 June 2025, when it was reckoned at 306,000 people. That is down significantly from 429,000 the year before (-34%), and even more dramatically from the post-pandemic peak of 538,000 people in 2022/23.

The 2025 NOM nets out 568,000 arrivals for that year against 263,000 departures, with international students as the largest single arrivals group (157,000).

In its budget planning documents, the Albanese government estimates that the NOM will edge down to 295,000 in 2025/26 before arriving at a longer-term target of 225,000 by 2027/28. That 225,000 figure can be debated in many different directions but it seems clear that it will become something of a political fulcrum around which the debate about migration will revolve in the months and years ahead.

Watch for the signs

With that comment about the “political imperative” to reduce net migration numbers ringing in our ears, let’s reflect on some of the recent moves to constrain migration, and inbound student movement in particular. These are noteworthy in part because they are all a function of tightening processes and settings within government – as opposed to legislation or other formal regulatory intervention – and have generally been introduced without consultation or even any significant lead time.

For example, on 1 July 2026, the following visa application fee increases were enacted with immediate effect and without prior notice.

• Student visa application fee for higher education and vocational (VET) studies (subclass 500): AU$2,000 to AU$2,500, unless students are from ASEAN countries (AU$2,050)
• Student visa fee for English-language studies (ELICOS): AU$2,000 to AU$2,050
• Temporary Graduate Visa 485 (for post-study work): AU$4,600 to AU$5,750
• Partner visa: AU$9,365 to AU$11,710

On 1 March 2026, also for immediate implementation and without warning, the application fee for the Temporary Graduate Visa (subclass 485) doubled to AU$4,600 from AU$2,300. (Meaning that the 1 July increase for subclass 485 was the second significant increase for this visa category within four months.)

Visa approval rates have also been trending down through 2026. In February 2026 alone, one out of every three students applying to an Australian university was rejected and that monthly refusal average (32.5%) was the most significant in 21 years of tracking. The approval rate for student visa applications dipped again in March, to 59%, and the year-to-date approvals through May 2026 ran at just 72% overall (which was again a 20-year low for that January to May period).

Most recently, the Department of Home Affairs has for most eligible countries for the Work and Holiday (subclass 462) programme. The programme includes a hard cap on the number of first Work and Holiday visas that can be granted to applicants from specific countries, and it appears that that limit has already been reached for most within a month of the application window having opened for this year on 2 July.

This could be read as another restriction on inbound mobility. But it should be said that closing that application window is not unusual, and that the immigration system normally “pauses” Work and Holiday applications when those cap limits are reached.

Further, the cap limits are specific to the Work and Holiday (subclass 462). There is a related subclass 417 () which, while reporting higher-than-normal application volumes this year, remains open to eligible applicants. Taken together, there were roughly 225,900 Working Holiday Makers in Australia as of 31 December 2025 (counting visitors on both 417 and 462 visas).

For additional background, please see:

• “Australia: As visa applications from foreign students fall, the government has set the national target for new international students in 2027“
• “Surprise hike in international student visa application fees ‘a direct hit to Australia’s competitiveness’“
• “Universities urged to focus on ‘factors they can control’ as policy settings depress international student enrolments in the Big Four“
• “Australia: Multiple data indicators signal further declines ahead for international student numbers“

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The public files are in many respects an under-appreciated resource, because they provide detailed guidance about the rules and compliance requirements for Canada’s various immigration streams. They also provide a window into how, over time, that guidance can be expanded, clarified, or otherwise changed.

The larger context here is that many students gather information about compliance or the fine points of their visa status from peers, through online message boards, and from other unofficial sources. Many, too, file their own applications for visas or renewals without assistance from an authorised advisor or lawyer – and they may or may not be aware of the latest official guidance.

A number of changes have been published in recent weeks to the reference files for study permit and post-graduate work permit (PGWP) compliance. Not all of these are rule changes. Rather, many take the form of useful clarifications of established policy or practice. That said, keeping track of those changes can be tricky as they may not be publicly announced or otherwise highlighted in the published files.

In broad terms, the revisions made in the second half of June point to greater scrutiny of the enrolment status and academic progress of continuing students, students transferring between programmes and institutions, and students’ absence or leave from studies. They also introduce important updates to PGWP eligibility, and they mark the end of an exception for temporary residents to pursue studies in Canada without a study permit.

Actively pursuing studies

The current version (as of 18 June 2026) of the IRCC file “” expands on the department’s expectations for the active pursuit of studies and academic progression with additional detail on when the programme of studies is considered to be completed.

Specifically, it stipulates that:

“Studies are considered officially completed on the date the DLI first notifies the student by any of the following:

• Completion letter
• Transcript
• Degree or diploma

The date stated on the document will be considered the date of notification unless the applicant and/or DLI can provide proof of a different date.”

The significance of that mechanism is underscored by a related note in the study permit guidance, which specifies that the student’s study permit “will become invalid … 90 days after the day the study permit holder completed their studies.”

Changing DLIs or programmes of study

The include considerable expansion of the rules around transferring between institutions.

This guidance is based on a rule change, effective 8 November 2024, which stipulates that “study permit holders in Canada, whose permit names a DLI [Designated Learning Institution], must apply for a new study permit if they wish to change designated learning institutions (DLIs).”

The updated file expands on this point by specifying that “study permit holders must adhere to the condition that they remain enrolled at the DLI named on their study permit until they complete their studies … their study permit becomes invalid on the day that they are no longer enrolled at the DLI named on their study permit, other than as a result of completing their studies.”

“Therefore, if a student whose study permit names a DLI has changed DLIs without applying for a new study permit, their previous study permit is rendered invalid and the student is considered to be studying without authorization at the new DLI.”

The updated guidance also addresses the scenario where a student may have a study permit that does not specify a DLI: “If a post-secondary student holds a study permit issued prior to November 8, 2024,that does not name a DLI, they should apply for a new study permit when changing DLIs. Once that study permit with no DLI is expired, they must apply for a new study permit which will be issued with the name of the DLI they are attending.”

The bottom line is that students cannot change institutions before they obtain a new study permit that specifies the new DLI.

The exception to this pertains to students who transfer to a different programme of study within the same DLI: “Students engaging in post-secondary studies in Canada are authorized to change programs of study within the same DLI at the same level of study, provided they are not limited from doing so by conditions imposed on their study permit.”

Finally, the expanded guidance in this area also provides some clear provisions for secondary students transitioning to post-secondary education:

“Students must apply for a new study permit with the DLI’s name on it when they transition to post-secondary studies to avoid any non-compliance issues.”

And:

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

Leave from studies

remains consistent from past versions in that, “Students may be required or may wish to take leave from their studies while in Canada. For the purpose of assessing if a student is actively pursuing their studies, any leave taken from a program of studies in Canada should not exceed 150 days from the date the leave commenced and must be authorized by their DLI.”

However, the 18 June updates expand on multiple leave periods and work rights during a leave from studies.

The point regarding multiple leave periods is in keeping with an overall pattern towards greater scrutiny of student progress: “In cases where a student has taken multiple periods of authorized leave in Canada during their program of study, the officer should consider the student’s reasons for the various periods of leave. If the multiple periods of leave do not appear to support the expectation that the student is making reasonable progress toward the completion of their course or program of study in the time allotted by the course or program of study, the officer may determine that the study permit holder has not fulfilled the condition to actively pursue their course or program of study.”

And on the question of working during a leave from studies, the updated document sets out plainly that, “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.”

PGWP and non-credit programmes

IRCC also updated its guidance for on 24 June 2026. The notable change here occurs in the section “Who’s not eligible for a PGWP” which has been changed to specify that students are not eligible if they have “completed a non-credit program of study (except for a flight school program).”

The significance of such updates is underscored by the high-profile case of a large number of PGWP application rejections this month for graduates from the Canadian Institute of Osteopathic Therapy (CIOT) in Calgary. CIOT delivers programmes in partnership with , and students in such public-private partnerships (P3) are no longer eligible for PGWPs following a rule change that came into effect on 15 May 2024.

However, many of the CIOT students who have had their PGWP applications refused began their studies prior to that May 2024 effective date, and therefore should be grandfathered under the previous policy that allowed students in P3 programmes to be eligible for post-study work.

, an independent news outlet, reports that, “The students immediately inquired about this with [IRCC], which said the mass rejections were due to recent policy changes, including that non-credit courses were no longer eligible for work permits …. This modification was made on June 24, years after the students initially started their programs and 18 to 21 months after they submitted their work permit applications.”

In a written response to Livewire Calgary, IRCC explained that “There have been no changes to the eligibility criteria. We updated our PGWP webpage in June 2026 to clarify the existing eligibility requirements related to non-credit programs of study.”

The inference from that reporting is that (i) the policy around non-credit study may have been clear within IRCC but may not have been commonly understood otherwise; (ii) IRCC appears to have determined that there was some ambiguity in this area, thus the 24 June update; and (iii) because this does not represent, in the apparent view of IRCC, a rule change (but rather a clarification), students may not be automatically grandfathered.

91ɬ��Monitor understands that many of the affected students are appealing their PGWP refusals and that the published guidance in this area may be further tested as a result.

Study for work permit holders

Finally, IRCC has also closed out that allowed some work permit holders to study in Canada without a study permit.

This policy had been in place from 27 June 2023, and it officially expired on 27 June 2026.

For additional background, please see:

• “OECD: International students may be underinformed about job prospects in top destinations“
• “New data provides early signals that Canada’s popularity as a study destination is on the rise“
• “New international student permit approvals for Canada fell below COVID levels in 2025“
• “Canada’s foreign enrolment has fallen by nearly 300,000 students over the last two years“

The post Canadian immigration officials have made several updates to compliance guidance for study permits and post-graduate work permits appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

The scrutiny is coming from more than one direction. Admissions offices are tightening their own checks on the authenticity and consistency of English-language evidence, in response to well-documented fraud vulnerabilities and inconsistent evidence standards across the sector.

At the same time, UK Visas and Immigration (UKVI) now runs an annual Basic Compliance Assessment (BCA) for every institution holding a student sponsor licence, scoring them on visa refusal rates, enrolment rates, and course completion rates. Falling short on any one of those metrics can strip an institution of the right to self-assess a student’s English ability altogether, forcing a shift to mandatory secure testing across the board. Further, a new Agent Quality Framework is being extended so institutions can no longer treat agent-sourced evidence as somebody else’s responsibility. In short: the English-language evidence an agent helps assemble now feeds directly into a compliance metric that determines whether an institution can keep recruiting internationally at all.

That’s the backdrop and it’s also the opportunity. Agents who understand this chain of evidence, and can speak to it confidently, become more valuable partners to the institutions they work with, and better advisers to the students who trust them.

Academic readiness is the cornerstone of student success

Academic readiness is the strongest predictor of first-year performance, progression, retention, and completion. When students arrive without sufficient English proficiency, the impact is immediate: difficulty engaging in seminars and group work, falling behind in reading-intensive modules, rising stress, and a higher likelihood of assessment failure or withdrawal.

Meeting a minimum entry requirement isn’t the same as being ready to perform at it. A student who scrapes the headline overall score with a weak reading or writing subscore is often the one who struggles most in postgraduate, research-intensive programmes, where extended reading and academic writing carry most of the assessment weight.

In practice, that means: looking with the student beyond the single overall band to the subscore breakdown; recommending a margin above the minimum particularly in speaking and writing wherever a programme is writing- or seminar-heavy; and encouraging an early retake where subscores are borderline, rather than waiting until an offer is at risk. Agents who steer students toward the cheapest or fastest route to a passing score to obtain a visa rather than genuine readiness, aren’t doing anyone any favours: those are the students most likely to need extra support, delay progression, or withdraw outcomes now visible to institutions through the BCA’s own completion-rate metric.

The growing scrutiny of MOI

Medium of Instruction (MOI) evidence is under sustained scrutiny, and institutions increasingly treat it as a case-by-case judgement rather than a standard alternative to testing. Practice varies widely: some institutions require MOI letters to be corroborated by transcripts, curriculum details, or interview; others have withdrawn MOI acceptance for certain markets or programmes altogether, following BCA findings that linked MOI-based admissions to weaker completion or higher visa refusal rates.

For agents, that means treating an MOI recommendation as a considered call each time, not a default and being able to talk a student through the reasoning.

Three questions are worth working through together: First, does the receiving institution’s current policy actually support MOI for this student’s country, subject, and level of study? Policies here shift often, so this is worth checking fresh for each application rather than assumed from a previous case. Second, was the student’s prior study substantively delivered and assessed in English not just described as such on paper in a way that plausibly matches the demands of postgraduate or research-intensive study in the UK? Third, is an MOI-based application more likely to trigger additional verification, delay an offer, or be queried at visa stage for this particular market?

Where any of these three is uncertain, recommending secure testing alongside or instead of MOI is the safer, more defensible choice for the student’s academic readiness, and for the agent’s credibility with the institutions they work with.

Secure testing as a strategic enabler

Secure English language testing is worth repositioning, in conversations with students, as more than an entry hurdle. It supports identity validation, demonstrates genuine academic readiness, reduces institutional exposure, and gives students greater confidence going into study. Viewing testing as an unnecessary cost is short-sighted: the real cost is poor preparation academic, financial, and emotional. Framing testing as an investment in a student’s own success, rather than a bureaucratic step, tends to land better with students and parents alike and it happens to be true.

BCA reviews are raising the bar

The Basic Compliance Assessment is an annual Home Office review of how well a sponsoring institution is managing its international student population against three metrics: visa refusal rates, enrolment rates, and course completion rates. Institutions rated amber or red face restrictions including, in some cases, losing the right to self-assess English-language ability, which pushes their entire cohort toward mandatory secure testing. As English-language evidence sits upstream of all three metrics a student who was never really ready for the course is more likely to be refused a visa, to under-enrol, or to withdraw, institutions are having to demonstrate, more rigorously than before, how that evidence was gathered, verified, and judged sufficient at the point of offer, both to their own compliance teams and to UKVI itself.

Agent-sourced evidence is now squarely inside that chain of justification. As regulatory attention on institutions increases, so does attention on the English-language guidance and evidence that agents provide upstream of the admissions decision. Weak guidance creates a vulnerability that traces all the way back to an agent’s file; strong guidance protects the student, the institution’s compliance record, and the agent’s own standing with institutional partners.

Defining practice that works for students and agents

A forward-looking standard is emerging, and it rewards informed, student-centred practice, which includes:

• Recommending the right test for the destination and programme, factoring in university acceptance, subject demands, security requirements, and timing
• Where subscores are borderline, especially speaking and writing for postgraduate, research-intensive courses, advising testing to a margin above the stated minimum, and supporting an early retake rather than a late one
• Treating MOI as a case-by-case judgement using the three questions above, not a standard substitute for testing
• Communicating secure testing to students as an investment in their own progression, not a hurdle to clear
• Keeping documentation authentic, consistent, and aligned with each institution’s current expectations, since these shift
• Engaging admissions teams early to confirm current requirements and reduce delays

These aren’t extra burdens layered on top of an agent’s advising role they’re the parts of that role now most visible to institutions, most consequential for students, and most likely to distinguish the agents that institutions want to keep working with.

The role of agents in a changing landscape

Agents are often a student’s first trusted adviser. Their guidance shapes not just admission outcomes but a student’s confidence, performance, and ultimately their success once they arrive. Getting the English-language piece right is one of the clearest, most immediate ways an agent can add value to that relationship and one of the clearest ways to build a track record that institutions notice.

How ELSAA supports the sector

ELSAA is the English Language Standard Advisory Authority [link to https://englishlsa.com]. Our mission is to strengthen standards, improve transparency, and support risk-aware decision-making across the English-language ecosystem. We work with agents and institutions to:

• Interpret emerging regulatory and compliance expectations
• Identify appropriate English-language pathways
• Reduce institutional and agent risk
• Improve student progression and retention
• Build trusted, future-ready recruitment practices

Agents who build this expertise put students at the centre of every decision and in doing so, strengthen their own standing with the institutions they work with. Strong English-language guidance isn’t an extra step; it’s the advantage.

The English Language Standard Advisory Authority (ELSAA) is an independent organisation dedicated to improving transparency, understanding, and informed decision-making in high-stakes English language testing. Through independent test reviews, comparative analysis, training, and advisory services, ELSAA supports universities, professional bodies, employers, and policymakers in evaluating and using English language assessments with confidence.

For additional background, please see:

• “Study highlights gaps between English standards set by test developers and those used by universities and professional bodies“
• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“

The post Why sharper English-language guidance is becoming an agent’s sharpest tool for student success appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.