June 5, 2023

Is An Expression of Interest Program for the Canadian International Student Program the Answer?

Posted by Mario Bellissimo - Bellissimo Law Group PC

More reports of suicides in the Indian community related to the International Student Program (ISP). And further to my interview in the Toronto Star, new regulations around Designated Learning Institutions will help, but the issue goes much deeper.

Yes, there are several serious issues surrounding the scope of the program and issues relating to educational recruitment, program integrity and enrolling in learning institutes that are not designated by the government. But the ISP is also experiencing the inherent and now crushing tension between mass processing, especially with the aid of expanding technologies like artificial intelligence, and the need for officers to undertake individualized assessments to avoid stereotypes and generalizations that would deny entry and bar applicants who otherwise meet the requirements for a study permit. We have provided a proposal to the Minister’s Office and Immigration, Refugees and Citizenship Canada (IRCC) and have worked with engaged Members of Parliament like the Honourable Julie Dzerowicz and my colleague Robin Seligman. The highlights of the proposed transformation to the ISP are as follows:

New Two Stage Expression of Interest (EOI) and Invitation to Apply (ITA) Selection Program

All applicants would file an expression of interest in various categories. Points would be allocated based upon factors depending on the category, educational history, previous degrees, grades, language ability, financial sufficiency, in-demand streams, educational institution etc. ITAs would be issued to students based upon streams, caps, and other factors. All applicants would file an EOI in various categories.

Points allocated based upon factors depending on the category, educational history, previous degrees, grades, language ability, financial sufficiency, in-demand streams, educational institution etc. Applicants not selected for the school year would terminate and thus no backlog. Educational institutions would receive points based upon a few factors that might include, depending on the category, labour market outcomes, admission integrity, number of foreign students, mental health, and other supports for international students etc.

New Study Permit Streams

Consideration should be given to new streams which could include:

  • Nimble and flexible study permit pathway for in demand occupations;
  • Distinctions between College and University Streams;
  • Provincial and Municipal Study Permit Stream; and
  • Humanitarian Study permits.

Real Time Access to Study Permit Files – Relieve Burden of ATIP Requests

An applicant should be able to access their file, find out the stage of processing, or in some cases, reasons for refusal, and thereby limit the need to resort to the Access to Information and Privacy Records (ATIPS) process in ways ATIPS was not intended to be utilized. The process should become more accessible for applicants and authorized representatives. Access will allow for concerns to be earlier identified, will help preserve the individualization of the process, and function as a second set of eyes for IRCC by those equally interested in the process and the outcome – the applicants and their representatives.


A new EOI/ITA ISP program would serve to ensure proper intake, eliminate abuse where possible, and control inventory. Expanded categories for applicants reflective of the varied reasons for short and long-term study and/or permanent migration bolstered by effective public messaging of the ISP to better managing all stakeholder expectations while enhancing economic/social vibrancy and limiting discrimination are key to a new modernized and enhanced ISP program.

Thus, the possibility for a more measured, fair, nuanced, and effective ISP is within reach that can minimize exploitation. The EOI system would be transparent, and each category and educational institution would have its maximum allocation. ITAs control runaway inventory. This is possible in part because of exciting technological possibilities like artificial intelligence (AI) solutions to manage, triage and support program delivery. A national immigration and integrated ISP plan that is multi-tiered and effectively leverages technology in an innovative, transparent, and responsible fashion, employs plain language, and engages all stakeholders would be transformative.