CIMM – Management Action Plan – April 22, 2026
IRCC Detailed Management Action Plan
OAG Audit of International Student Program Reforms Available Report: International Student Program Reforms - Canada.ca
| Report Ref. No. | OAG Recommendation | Departmental Response (to be included in the report) | Description of Final Expected Outcome/Result (to be developed) |
Expected Final Completion Date (to be developed) |
Key Interim Milestones (Description of action items /Dates) (to be developed) |
Responsible Organization/ Point of Contact (Name, Position, Tel #) |
|---|---|---|---|---|---|---|
| Para. 29 | In collaboration with provinces, IRCC should tailor its models for determining annual study permit allocations for each province. |
Agreed. IRCC’s allocation analysis is tailored based on Statistics Canada data on population share by province and territory and jurisdiction-specific approval rates to account for regional differences. In 2025, provinces used less than half of their allocation spaces. IRCC is working with provinces to support their effective usage of allocation spaces. This includes new talent attraction measures for graduate students. IRCC sets the overall national cap, and the limit or "ceiling" for each province; however, allocation usage is outside of IRCC’s control. Provinces decide which learning institutions receive spaces and how many each learning institution receives, while institutions are responsible for student recruitment and admission decisions. |
IRCC will continue to account for regional differences by tailoring PT
allocations based on population share by province and territory and by
using jurisdiction-specific study permit approval rates.
IRCC will support provinces and territories in their efforts to increase their allocation usage year-over-year. |
Annually |
Completed: Since the implementation of the 2025 cap on January 22, 2025, the allocation model has been determined using PT-specific approval rates in addition to population share. Going forward: |
Leading Sector: Economic Programs Leading Branch: Temporary Residents Points of Contact: Director General Bronwyn May Senior Director Julie Spattz |
| June 2026 | By June 1, 2026, IRCC will convene discussions with PTs, via the established FPT Working Group on the International Student Program, on strategies to maximize allocation usage. | |||||
| July 2026 | By July 2026, IRCC will share PT-specific data such as study permit approval rates, top source countries, and asylum claims, to help inform recruitment efforts. | |||||
| October 2026 | By October 2026, IRCC will hold follow-up discussion with PTs via the established Working Group to take stock of progress on allocation usage and discuss the effectiveness of attraction measures for graduate students. | |||||
| Para. 37 | IRCC should follow-up on all applications flagged for potential fraud through its new verification system. |
Agreed. IRCC will ensure follow-up is conducted when potential fraud is detected through the Letter of Acceptance Verification system. To ensure greater consistency, IRCC is currently centralizing functions responsible for pursuing potential misrepresentation related to letters of acceptance. |
Potential fraud involving letters of acceptance is centrally reviewed and actioned, resulting in more consistent, efficient, and accountable processes. | Centralized Team implementation: by September 30, 2026. |
Completed (March 2026): Developed options for the centralized function and conducted initial consultations with internal stakeholders (IOB and IPB) Reviewed existing staff allocations and assessed capacity against operational requirements By June 15, 2026: Consult with internal stakeholders to confirm the scope and roles & responsibilities of the expanded centralized function. Update and finalize workflows Pilot centralized function and conduct QA Identify and allocate staffing resources based on projected annual workload. By September 30, 2026: Update standard operating procedures (SOPs). Implement expanded verification function. Monitor and leverage existing feedback loops. |
Leading Sector: Service Delivery Leading Branch: Immigration Operations Branch
Points of Contact:
Director:
Assistant Director Supporting: International Platform Branch Director, International Program Delivery: Christina Lucia Director, Operations Planning and Performance: Symone Shaw |
| Para. 49 | IRCC should determine how and when it will use mechanisms available to respond to cases in which the use of fraudulent documentation or misrepresentation is found by the department's processes after permits are approved. |
Agreed. IRCC will review the cases presented in the report and create info-alerts on the respective files, where applicable. These alerts flag persons of concern in the event of subsequent applications and will ensure the awareness of partner agencies such as the CBSA as the enforcement authority. IRCC will continue to work with enforcement partners to review and improve internal processes to keep strengthening program integrity. |
When IRCC’s processes identify misrepresentation / fraud, IRCC Service Delivery will conduct the case reviews, add info alerts to file, where applicable. To strengthen the integrity of its student visa program, IRCC will develop and implement a strategy to increase visibility and take action on non compliance in the student stream for those files mentioned in the report and ongoing. IRCC will also work with the CBSA to determine appropriate enforcement action. | 1. Misrepresentation PDI published by September 2026. | 1. Develop and publish new Program Delivery Instructions on Misrepresentation which will include the details on the dissemination and implementation to address identified cases of fraud by September 2026. |
Leading Sector: Migration Integrity Leading Branch: Integrity Policy and Programs Branch Points of Contact: Director General: Tara Lang Director: Sean McNair Supporting: Director General, Integrity Operations: Michelle Greenshields |
| 2. Where applicable, Info-Alerts added to cases identified in the report by September 30, 2026 | Completed (March 27, 2026): 1,274 info- alerts entered Case reviews begin by April 07, 2026 Case reviews completed by September 30, 2026 |
Leading Sector: Service Delivery Leading Branch: Immigration Operations Branch Points of Contact: Director General: Emina Tudakovic Director: Thomas Metzger Supporting: International Platform Branch Director: Christina Lucia |
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| 3. New strategy developed and implemented. | Current state process and authorities are identified by May 2026. Implementation of new approach by December 2026. |
Leading Sector: Migration Integrity Leading Branch: Integrity Policy and Programs Branch Points of Contact: Director General: Tara Lang Director: Sean McNair Supporting: Director General, Integrity Operations: Michelle Greenshields CBSA Leading Branch: Intelligence and Enforcement Branch Points of Contact: Director General: Carl Desmarais Directors: Jing Zhao, Removals Véronique Desjardins, Hearings Zrinka Barisic, Investigations (policy on A44 reports and MDR, Warrants and Investigations) | ||||
| Para. 57 | IRCC should strengthen its controls for study permit extensions by reviewing and adjusting its risk assessment for applicants originally approved under the Student Direct Stream. |
Agreed. IRCC will assess extension applications from former Student Direct Stream applicants with a renewed risk lens, and ensure assessment based on study permit requirements. IRCC launched an advanced analytics model in November 2025 to triage extension applications based on risk and complexity in order to assign them for review to officers with the corresponding level of expertise for review and decision. IRCC will continue to proactively review and strengthen controls as risks are identified. |
1. IRCC will optimize the Study Permit Extension Advanced Analytics model to ensure higher risk study permit extension applications are reviewed by an officer assigned to process higher risk/ complex applications. | 1. Fall 2026 and ongoing thereafter. |
Model Updates implemented Summer 2026.
Undertake QA exercise to validate model outcomes Fall 2026. |
Leading Sector: Service Delivery Leading Branch: Operational Planning and Performance Branch Points of Contact: Director General: Peter Mielke Director: Vicky Hou |
| 2. Complete compliance investigations on study permit extension applications that are identified as higher risk with an initial study permit application processed under the Student Direct Stream. | 2. October 2026 | By June 2026: Identify volume and scope of investigations and resources Summer 2026 By September 2026: Launch SP compliance investigations Fall 2026 |
Leading Sector: Service Delivery Leading Branch: Immigration Operations Branch Points of Contact: Director General: Emina Tudakovic Director: Thomas Metzer Supporting: MIOB, Director General: Michelle Greenshields Director: Karine Ouellet/Jefferson Brun |
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| Para. 64 |
IRCC should: accurately identify how many students with expired permits have not applied for other types of immigration status; provide that list of students to CBSA so that CBSA can reconcile this list of students with entry/exit data |
Agreed. IRCC will provide CBSA annually with a list of individuals with expired permits, who have not applied for or received an extension, or applied for or transitioned to permanent residence, or otherwise maintained valid immigration status |
To strengthen the integrity of its student visa program, IRCC will develop and implement a strategy to increase visibility and take action on non compliance in the student stream for those files mentioned in the report and ongoing. IRCC will also work with the CBSA to determine appropriate enforcement action. | December 2026 and ongoing annually thereafter. |
Current state process and authorities are identified by May 2026. Implementation of new approach December 2026. |
Leading Coordinator: Migration Integrity Leading Branch: Integrity Policy and Programs Director General: Tara Lang Director: Sean McNair Lead Development of List for IRCC: Data Branch Director General: Vik Srivastava
Director: Sébastien Fleurant;
Info Alerts / Examinations Lead: Director General: Emina Tudakovic Director: Thomas Metzger Supporting: Leading Branch: Intelligence and Enforcement Branch Points of Contact: Director General: Carl Desmarais
Directors: |
| Para. 72 | IRCC should set goals and indicators to track outcomes when implementing diversification initiatives. |
Partially agree. IRPA is country-agnostic by design. Given the fundamental principles of IRPA, IRCC does not set country or region-specific targets for the International Student Program. Moreover, Designated Learning Institutions are fully responsible for the recruitment and selection of students for admission to their programs. IRCC does not and should not direct the selection decisions of learning institutions. IRCC supports the objective of reducing overreliance on a single market and drawing talent to Canada from broader pool. IRCC is therefore tracking regional volumes for information purposes. The cancellation of the Student Direct Stream was part of IRCC’s plan to support diversification, by removing preferential systems based on source country, and ensuring prospective students apply on an equal footing. Data shows early signs of growth in certain regions and reduced reliance on a small number of source countries. More time is needed to see longer term trends. Another key initiative under the diversification pillar of the reform process is the newly launched Francophone Minority Community Student Pilot. This pilot is designed to reduce barriers for underrepresented cohorts, specifically related to the concerns around approval rates and financial requirements. The pilot has a specific set of goals and indicators to track outcomes. |
To support diversification, IRCC has set goals including: decommissioning the Student Direct Stream and launching a pilot that would improve equitable access for students coming from countries with historically low approval rates. |
Completed | Completed Decommissioned the Student Direct Stream in November 2024. Launched the Francophone Minority Student Pilot in August 2024. IRCC finalized a logic model in December 2025, with expected outcomes and specific indicators to track results for the Francophone Minority Communities Student Pilot. Going forward: Issue data report on regional volumes to stakeholders and provinces and territories by July 2026. |
Leading Sector: Economic Programs
Leading Branch: Temporary Residents Point of Contact: Director General Bronwyn May Senior Director Julie Spattz |
| IRCC is tracking and reporting on regional volumes across the program, to inform the recruitment strategies and diversification efforts of learning institutions and provinces and territories. | July 2026 |