Effective January 22, 2024, the majority of students seeking a study permit for Canada are required to submit an attestation letter.
You must provide an attestation letter if you are applying for a post-graduate program, unless its a master’s degree, doctoral degree or you are already in Canada (some conditions apply).
Previously, there was some confusion as to whether or not post-graduate programs were exempt from the requirement to provide attestation letters.
Now, it’s clear that every student applying for a study permit, including those enrolling in post-graduate programs at colleges, must provide a provincial attestation letter (PAL). There are some exemptions, but this applies to master’s degrees and doctoral degrees, minors and individuals already in Canada.
On January 22, 2024, IRCC’s announcement created ambiguity by exempting students in “Masters, PhD, or other post-graduate programs.” IRCC did not clearly define what constituted “other post-graduate programs.”
This led to confusion, specifically regarding post-graduate college programs. Many speculated that college graduate programs were exempted.
On January 31, 2024, IRCC quietly removed all references to an exemption for “other post-graduate programs” in relation to provincial attestation letters on their website.
On February 2, 2024, IRCC released the Ministerial Instructions. There was no mention of any exemptions for post-graduate programs.
On February 5, 2024, IRCC released additional information about the international student program reforms, and once again confirmed that all international students must provide an attestation letter, unless exempt.
We will keep providing updates on the process of applying for a provincial attestation letter both here and in our newsletter.
Be the first to know about attestation letters
Get an email as soon as attestation letters are available.
Are you required to obtain a provincial attestation letter for your study permit application for a college post-graduate program?
Yes. Every student must provide a provincial attestation letter (PAL) with their study permit application, unless they are inside Canada (some conditions), a minor, or attending a master’s degree or doctoral degree. We dive into the requirement and exemptions in this blog.
Previously, we delved into definitions, announcements, semantics, and operational instructions provided to immigration officers. Our initial conclusion was that college-level post-graduate programs were unlikely to be included under this exemption due to the reasons outlined. This was confirmed on January 31, 2024.
IRCC glossary – postgraduate is university level
IRCC uses a glossary of terms to provide an explanation for different words that they use online. These are not legal definitions, but they help understand what terms IRCC uses. There is no legal definition of postgraduate in the law (IRPA) or regulation (IRPR).
Postgraduate is found under the definition of “level of study” and used to describe degrees granted by universities. There is no mention of postgraduate under the definition of college, or any other level of study:
Universities: Offer degree-granting programs at the undergraduate (bachelor’s) graduate (master’s), and postgraduate (doctoral, post-doctoral) levels, and may also offer programs leading to certificates or diplomas in various academic disciplines.
Colleges: Offer academic or professional training programs leading to diplomas or certificates (includes CEGEPs in Quebec, which is generally mandatory before attending university).”
While a school may use the term post-graduate for their certificate or diplomas since it involves previous studies or an undergraduate degree, IRCC uses the term “postgraduate” within the definition of university degree-granting programs, as per their glossary. In any event, as of January 31, 2024, IRCC removed the mention of “other post-graduate programs” from their list of exemptions.
The Minister’s announcement does not mention an exemption for “other post-graduate programs” or college programs
The purpose of the attestation letters was to provide greater control on the admission of international students to Canada following a surge in international students and private schools.
The Minister of Citizenship and Immigration, Marc Miller, acknowledged the following when announcing the new policy:
the cap [and the requirement to provide an attestation letter] will not apply to students and graduate levels of studies including Masters and Doctoral students – those are the people we are looking for – study permit applications at the elementary and secondary school level will also be exempted
he Minister’s announcement does not mention that post-graduate programs at colleges will be exempt from the provincial attestation letter.
However, when speaking about Post-Graduate Work Permits, the Minister clearly mentions that programs like Masters, PhD and other professional programs would remain eligible, but college level programs would not in the coming weeks, we’ll be announcing that open work permits will only be allowed and be available to spouses of international students enrolled in Masters and doctoral programs as well as professional programs such as medicine and law – spouses of international students in other levels of study including undergraduate and college programs will no longer be eligible.
he Minister’s announcement clearly mentions that professional programs will benefit from the PGWP, while college programs will not.
IRCC’s announcement does not the mention an exemption for “other post-graduate programs” or college programs
In regard to the cap of international students, IRCC stated the following: “Those pursuing master’s and doctoral degrees, and elementary and secondary education are not included in the cap.” Source.
Of note, there is no mention of other post-graduate programs, post-graduate diplomas or post-graduate certificate programs, or college programs being exempted in the official announcement.
While immigration officers will take their instructions from regulations and operational instructions and guidelines, none of these have been updated in regards to attestation letters as of January 25, 2024. It usually takes a few days or weeks for IRCC to update the operational instructions and guidelines.
ImmInspect.com uses an algorithm to review your study permit application – free until February 14, 2024.
Ontario Colleges asking for an exemption like universities
Ontario Colleges, a group that represents 24 colleges, asked that they be treated the same as public universities as it relates to post-graduate programs” “IMMEDIATE ASK: Ontario’s public colleges are calling for the federal government to treat the post-graduate credentials at public colleges the same way it treats the post-graduate credentials at universities and to exempt them from the cap.” Source.
Although not conclusive, it is evident that colleges commonly interpret the exemption as being applicable solely to post-graduate programs at universities. Again, this was confirmed on January 31, 2024 when IRCC removed the mention of “other post-graduate diplomas” from the list of exemptions, and also confirmed when the Ministerial Instructions were published.
Post-graduate programs” vs “Masters, PhD and other post-graduate programs”
Is there a difference in semantics between stating an exemption for “post-graduate programs” and an exemption for “Master, PhD, and other post-graduate programs”? The context of the sentence, in addition to the announcements above, must be considered.
This is a broad term that refers to any educational program undertaken after completing an undergraduate degree. It includes a wide range of programs. For example, it can encompass Master’s and Doctoral (PhD) degrees, but also post-graduate diplomas, certificates, professional training, and fellowships. The term is more inclusive and can refer to any form of education after the undergraduate level, regardless of the field, duration, or structure.
This term is more specific. The sentence explicitly mentions two major types of post-graduate academic degrees – Master’s and PhDs – and then adds a broader category with “other post-graduate programs”. This term suggests a focus on traditional academic pathways (Masters and PhD degrees) while still acknowledging the existence of other forms of similar programs that may not be called a Masters or PhD. For example, post-graduate programs could include professional programs like medicine, dentistry or law, and even post-graduate doctoral programs.
In any event, as noted above, the term “postgraduate” is used by IRCC’s glossary under the degree-granting programs at a university.
What happens if your application is returned as incomplete?
IRCC has stated that, if you need an attestation letter and you apply without it, your application will be returned as incomplete: “We’ll return any application received on or after January 22, 2024, without an attestation letter, unless you’re exempt.” Source
The Operational Instructions and Guidelines indicate that “officers will return the application and documents to the client with a written request for the missing information.”
This seems forgiving. Why not submit the application and, if it gets returned due to the missing attestation letter, resubmit it later?
We know that IRCC uses a program called Chinook and other computer programs to review and triage cases into various groups, such as applicants that are applying for the first time, applicants with red flags like criminality and applicants who have been previously refused or had their applications rejected.
While the idea of applying and seeing what happens may seem compelling, a previously returned or rejected application can have a negative impact on future applications.