CIMM – Overview of the Management Response and Action Plan – April 22, 2026

Key Message

• IRCC has outlined concrete steps to address the Auditor General’s recommendations in our Management Action Plan.

Recommendation 1:

In collaboration with provinces, IRCC should tailor its analyses for determining annual study permit allocations for each province.

Departmental Response:

Agree.

Expected Outcomes:

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, and share additional data with PTs to help inform recruitment efforts.

Key Interim Milestones:

• By June 2026, IRCC will convene discussions with PTs on strategies to maximize allocation usage.
• By July 2026, IRCC will share additional data with PTs to help inform recruitment efforts.
• By October 2026, IRCC will hold follow-up discussions with PTs to take stock of progress on allocation usage and the effectiveness of attraction measures for graduate students.

If pressed:

Allocation Usage: 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.

Impact to smaller PTs: PTs currently have more allocations than they are using. IRCC sets the overall national cap, and the limit or ‘ceiling’ for each province; however, allocation usage is beyond IRCC’s direct 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.

Recommendation 2:

IRCC should follow-up on all applications flagged for potential fraud through its new verification system.

Departmental Response:

Agree.

Expected Outcomes:

IRCC is centralizing the teams responsible for pursuing potential misrepresentation related to letters of acceptance. This will result in a more consistent, efficient and accountable process.

Key Interim Milestones:

• Completed in March 2026, developed options for the centralized function, reviewed existing staff allocations and assessed capacity against operational requirements.
• By June 2026: confirm scope and roles & responsibilities of the expanded centralized function, update and finalize workflows, pilot and conduct quality assurance, and identify and allocate staffing resources based on projected annual workload.
• By September 2026: Update standard operating procedures, implement centralized verification function, and monitor results.

If pressed:

Centralized function will be responsible for issuing procedural fairness letters in cases where LoA results are "no match", which may result in a refusal for misrepresentation. This new process flow is intended to mitigate fraud and improve follow-ups where concerns exist, as recommended in the OAG report.

Recommendation 3:

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.

Departmental Response:

Agree.

Expected Outcomes:

IRCC will review the cases presented in the report and create info-alerts on the respective files, where applicable.

IRCC will develop and implement a strategy to increase visibility and take action on non-compliance in the student stream, and will work with the CBSA to determine appropriate enforcement action. In the future, when IRCC’s processes identify misrepresentation / fraud, IRCC will conduct case reviews and add info alerts to file.

Key Interim Milestones:

Review of cases identified in the report:

• Underway: 1,274 info-alerts entered to date, case reviews underway.
• By September 2026, case reviews complete.

Review and revise the procedures related to misrepresentation:

• By September 2026, develop and publish new Program Delivery Instructions on misrepresentation.

Develop a new approach to addressing post-arrival fraud and misrepresentation cases:

• By May 2026: working with CBSA, map current and proposed new process; identify required authorities for implementation
• By December 2026: New strategy developed and implemented.

If pressed on:

Alerts: 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.

Recommendation 4:

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.

Departmental Response:

Agree.

Expected Outcomes:

IRCC will establish a risk-based triage system for processing study permit extension applications. This will ensure higher risk study permit extension applications are reviewed by an officer assigned to process higher risk / more complex applications.

Conduct investigations on study permit extension applications that are identified as higher risk with an initial study permit application processed under the Student Direct Stream.

Key Interim Milestones:

Implement a risk-based triage system:

• Completed: advanced analytics model initially launched in November 2025
• By Summer 2026, make updates to the model to further optimize
• By Fall 2026, undertake a quality assurance exercise to validate outcomes

Conduct compliance investigations on higher risk cases with a initial permit issued under the Student Direct Stream:

• By June 2026, identify volume and scope of investigations and required resources.
• By September 2026, launch investigations.

If pressed:

Student Direct Stream: this stream was cancelled in November 2024, as a result of integrity concerns and its impact on the diversification of the program.

Advanced Analytics Model: was initially launched 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.

Recommendation 5:

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.

Departmental Response:

Agree.

Expected Outcomes:

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.

IRCC will manage student visas as a population to be validated and confirm the departure of those without new or renewed status, and will work with the CBSA to determine appropriate enforcement action.

Key Interim Milestones:

• By May 2026: identify current state process and authorities.
• By December 2026: new approach developed and implemented.

Recommendation 6:

IRCC should set goals and indicators to track outcomes when implementing diversification initiatives.

Departmental Response:

Partially Agree.

IRCC supports its partners in reducing overreliance on a single market and drawing talent to Canada from broader pool. However, IRPA is country/region-agnostic by design. Given the fundamental principles of IRPA, IRCC does not set country or region-specific targets for the International Student Program.

Recruitment and admission decisions are the purview of learning institutions operating under provincial and territorial jurisdiction. IRCC does not and should not direct the selection decisions of learning institutions.

Expected Outcomes:

To support diversification, IRCC set specific goals including:

• decommissioning the Student Direct Stream to ensure prospective students are applying on an equal basis regardless of source country, and
• launching a pilot program that would improve equitable access for students coming from countries with historically low approval rates.

To inform the recruitment strategies and diversification efforts of learning institutions and provinces and territories, IRCC will track and report on regional volumes and trends across the program.

Key Interim Milestones:

Cancel the Student Direct Stream:

• Completed in November 2024: Decommissioned the Student Direct Stream.

Launch equitable access pilot:

• Completed in August 2024: Launched the Francophone Minority Student Pilot (FMSCP).
• Completed in December 2025: finalized a logic model with expected outcomes and specific indicators to track results for the Francophone Minority Communities Student Pilot.

Enhance data-sharing with PTs and stakeholders:

• By July 2026: issue data report on regional volumes to stakeholders and provinces and territories.

If pressed:

Diversification Efforts: As noted in the audit report, 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. IRCC will continue to monitor and report on trends.

SDS: 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. The SDS was also shut down because of problematic integrity outcomes.

FMCSP: 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. So far, the pilot is showing positive results.