In 2024, Immigration, Refugees and Citizenship Canada (IRCC) introduced a limit on the number of study permit applications it would accept for processing. This was one of several changes introduced over the past year and a half aimed at reducing the number of temporary residents in Canada to 5% of the total population by 2027. As part of these efforts, for the first time IRCC included targets for international students and temporary foreign workers in the 2025-2027 Levels Plan.

The details relating to the number of new study permit applications to be accepted in 2025 was announced in January 24, 2025, along with a new distribution of the maximum amount of study permit applications to be processed from each province and territory. This year’s national target for study permits to be issued was set to 437,000, representing a 10% decrease from the 2024 cap.

Broadly speaking, IRCC has broken the national target down by student cohort including: (1) graduate degree students (73,282); (2) applicants exempt from submitting a PAL/TAL (120,724); and (3) remaining cohorts who are subject to submitting a PAL/TAL (242,994). Allocations to be processed by individual provinces and territories for students required to submit a PAL/TAL with their SP application are also available here.

As of last year, to implement the intake cap, most applicants must now obtain a Provincial or Territorial Attestation Letter (PAL/TAL) from their intended study location before applying for a study permit. These attestation letters serve as confirmation that the applicant occupies one of the region’s assigned slots.

There are a number of exceptions to the PAL/TAL requirement for the 2025 allocation period. Some of the categories of study permit applications that are excluded from these requirements have changed from those in the 2024 allocation period, therefore it is important to check IRCC’s guidance regularly for changes. The following are some of the study permit applicants currently exempted from the PAL/TAL requirement for the 2025 allocation period:

• Study permit holders in Canada seeking to extend their SP at the same Designated Learning Institution (DLI) and in the same level of study as that listed in their existing study permit;
• Individuals inside Canada under a removal order who cannot be removed from Canada;
• Individuals inside Canada holding a temporary resident permit (TRP) valid for at least 6 months;
• Protected persons;
• Individuals applying to study at a preschool, primary (including kindergarten) or secondary level (up to grade 12);
• Individuals applying as a visiting or exchange student under an exchange arrangement at a DLI;
• Individuals selected by their DLI to participate in the Francophone Minority Communities Student Pilot who also have a letter of acceptance from the school confirming this.

The full list of those exempted from the PAL/TAL requirement can be found here. Proof of meeting on of these exceptions always needs to be provided with study permit applications.

If an applicant does not meet one of the listed exceptions, a PAL/TAL needs to be provided with each study permit application. Even applicants applying together as a family must provide an accompanying PAL/TAL for each study permit applicant. This also applies to prerequisite courses and programs, including language courses or programs, which require a study permit application.

There are two important exceptions that have been removed for the 2025 allocation period that were in place in the 2024 allocation period. Family members of study permit or work permit holders who are already inside Canada now need a PAL/TAL to apply for a study permit. Similarly, applicants planning to pursue a graduate degree program at the master’s or doctoral level are now also required to present a PAL/TAL with their application.

In terms of PALs/TALs’ validity, unless it has an expiry date on it, a PAL/TAL issued for the 2025 allocation period is valid until December 31, 2025. A PAL/TAL that has already been issued and is within the stated validity period should remain valid, unless it has already been used to support a previous study permit application that has been processed and decided on.

Applicants who have received a PAL/TAL for the 2025 allocation period and have already applied for a study permit are only able to reapply with the same PAL/TAL if it continues to be valid and if one of two situations apply to them: (a) their study permit application was accepted for processing but they voluntarily withdrew their application before a final decision was made on their application, or (b) their application was not processed, which means they were advised about this and their fee was refunded. However, if a PAL/TAL is no longer valid or has expired, applicants will have to receive a new PAL/TAL before reapplying. A new PAL/TAL is therefore also required if a previous study permit application was either approved or refused.

Notably, DLIs along with provinces and territories, are prohibited from transferring any leftover allocation spaces or PALs/TALs from the prior cap year. In addition, if a study permit application with a corresponding PAL/TAL is refused, the DLI will lose that allocation space, preventing it from being transferred to another prospective student.

Finally, a significant new change affecting international students concerns those contemplating to transfer schools at the post-secondary level. This includes those changing DLIs, and those transitioning from one level of study to another (e.g. post-secondary to graduate level; graduate to a post-secondary level; or even post-secondary level to a secondary level).

Previously, international students in Canada could simply notify IRCC of a transfer to a new DLI through their online account, without requiring a new study permit. As of November 8, 2024, international students wishing to change schools at a post-secondary level generally now need a new study permit by applying to extend their study permit, and a new PAL/TAL before they reapply in order to address the change in DLIs. (Note that students moving from a post-secondary to a secondary level of study may be exempt from the PAL/TAL requirement, but not from submitting a new study permit). International students will therefore want to plan ahead and keep a number of things in mind before they consider changing schools.

Among the things international students will want to consider before committing to transferring involve making sure that the new school is also a DLI that is not on the suspension list. International students will also want to make sure they receive a new PAL/TAL before they submit their application to extend their SP. Students completing a co-op program who are changing to a new co-op program at a different school will also need to apply for a new co-op work permit.

Some eligible students may be able to study at the new DLI while their new application is in progress in very limited circumstances. However, students who do not meet these criteria will need to apply for and receive their new study permit for their new DLI before they finish their studies at their current school.

This post is intended to highlight some of the recent changes affecting international students in Canada, and is not meant to be exhaustive nor is it is legal advice. As usual, many of these changes are nuanced and complex. Therefore, please reach out to an immigration lawyer for guidance if you have any case-specific questions.