The public files are in many respects an under-appreciated resource, because they provide detailed guidance about the rules and compliance requirements for Canada’s various immigration streams. They also provide a window into how, over time, that guidance can be expanded, clarified, or otherwise changed.

The larger context here is that many students gather information about compliance or the fine points of their visa status from peers, through online message boards, and from other unofficial sources. Many, too, file their own applications for visas or renewals without assistance from an authorised advisor or lawyer – and they may or may not be aware of the latest official guidance.

A number of changes have been published in recent weeks to the reference files for study permit and post-graduate work permit (PGWP) compliance. Not all of these are rule changes. Rather, many take the form of useful clarifications of established policy or practice. That said, keeping track of those changes can be tricky as they may not be publicly announced or otherwise highlighted in the published files.

In broad terms, the revisions made in the second half of June point to greater scrutiny of the enrolment status and academic progress of continuing students, students transferring between programmes and institutions, and students’ absence or leave from studies. They also introduce important updates to PGWP eligibility, and they mark the end of an exception for temporary residents to pursue studies in Canada without a study permit.

Actively pursuing studies

The current version (as of 18 June 2026) of the IRCC file “” expands on the department’s expectations for the active pursuit of studies and academic progression with additional detail on when the programme of studies is considered to be completed.

Specifically, it stipulates that:

“Studies are considered officially completed on the date the DLI first notifies the student by any of the following:

• Completion letter
• Transcript
• Degree or diploma

The date stated on the document will be considered the date of notification unless the applicant and/or DLI can provide proof of a different date.”

The significance of that mechanism is underscored by a related note in the study permit guidance, which specifies that the student’s study permit “will become invalid … 90 days after the day the study permit holder completed their studies.”

Changing DLIs or programmes of study

The include considerable expansion of the rules around transferring between institutions.

This guidance is based on a rule change, effective 8 November 2024, which stipulates that “study permit holders in Canada, whose permit names a DLI [Designated Learning Institution], must apply for a new study permit if they wish to change designated learning institutions (DLIs).”

The updated file expands on this point by specifying that “study permit holders must adhere to the condition that they remain enrolled at the DLI named on their study permit until they complete their studies … their study permit becomes invalid on the day that they are no longer enrolled at the DLI named on their study permit, other than as a result of completing their studies.”

“Therefore, if a student whose study permit names a DLI has changed DLIs without applying for a new study permit, their previous study permit is rendered invalid and the student is considered to be studying without authorization at the new DLI.”

The updated guidance also addresses the scenario where a student may have a study permit that does not specify a DLI: “If a post-secondary student holds a study permit issued prior to November 8, 2024,that does not name a DLI, they should apply for a new study permit when changing DLIs. Once that study permit with no DLI is expired, they must apply for a new study permit which will be issued with the name of the DLI they are attending.”

The bottom line is that students cannot change institutions before they obtain a new study permit that specifies the new DLI.

The exception to this pertains to students who transfer to a different programme of study within the same DLI: “Students engaging in post-secondary studies in Canada are authorized to change programs of study within the same DLI at the same level of study, provided they are not limited from doing so by conditions imposed on their study permit.”

Finally, the expanded guidance in this area also provides some clear provisions for secondary students transitioning to post-secondary education:

“Students must apply for a new study permit with the DLI’s name on it when they transition to post-secondary studies to avoid any non-compliance issues.”

And:

“If a student is attending a secondary school while on a visitor record, they must wait for their study permit application to be approved before beginning studies at the post-secondary level.”

Leave from studies

remains consistent from past versions in that, “Students may be required or may wish to take leave from their studies while in Canada. For the purpose of assessing if a student is actively pursuing their studies, any leave taken from a program of studies in Canada should not exceed 150 days from the date the leave commenced and must be authorized by their DLI.”

However, the 18 June updates expand on multiple leave periods and work rights during a leave from studies.

The point regarding multiple leave periods is in keeping with an overall pattern towards greater scrutiny of student progress: “In cases where a student has taken multiple periods of authorized leave in Canada during their program of study, the officer should consider the student’s reasons for the various periods of leave. If the multiple periods of leave do not appear to support the expectation that the student is making reasonable progress toward the completion of their course or program of study in the time allotted by the course or program of study, the officer may determine that the study permit holder has not fulfilled the condition to actively pursue their course or program of study.”

And on the question of working during a leave from studies, the updated document sets out plainly that, “If a study permit holder is not attending class full time, they are not eligible to work as per the condition listed on their study permit … During any leave from studies, including DLI closures, a study permit holder cannot work on or off campus.”

PGWP and non-credit programmes

IRCC also updated its guidance for on 24 June 2026. The notable change here occurs in the section “Who’s not eligible for a PGWP” which has been changed to specify that students are not eligible if they have “completed a non-credit program of study (except for a flight school program).”

The significance of such updates is underscored by the high-profile case of a large number of PGWP application rejections this month for graduates from the Canadian Institute of Osteopathic Therapy (CIOT) in Calgary. CIOT delivers programmes in partnership with , and students in such public-private partnerships (P3) are no longer eligible for PGWPs following a rule change that came into effect on 15 May 2024.

However, many of the CIOT students who have had their PGWP applications refused began their studies prior to that May 2024 effective date, and therefore should be grandfathered under the previous policy that allowed students in P3 programmes to be eligible for post-study work.

, an independent news outlet, reports that, “The students immediately inquired about this with [IRCC], which said the mass rejections were due to recent policy changes, including that non-credit courses were no longer eligible for work permits …. This modification was made on June 24, years after the students initially started their programs and 18 to 21 months after they submitted their work permit applications.”

In a written response to Livewire Calgary, IRCC explained that “There have been no changes to the eligibility criteria. We updated our PGWP webpage in June 2026 to clarify the existing eligibility requirements related to non-credit programs of study.”

The inference from that reporting is that (i) the policy around non-credit study may have been clear within IRCC but may not have been commonly understood otherwise; (ii) IRCC appears to have determined that there was some ambiguity in this area, thus the 24 June update; and (iii) because this does not represent, in the apparent view of IRCC, a rule change (but rather a clarification), students may not be automatically grandfathered.

���Ϲ��� Monitor understands that many of the affected students are appealing their PGWP refusals and that the published guidance in this area may be further tested as a result.

Study for work permit holders

Finally, IRCC has also closed out that allowed some work permit holders to study in Canada without a study permit.

This policy had been in place from 27 June 2023, and it officially expired on 27 June 2026.

For additional background, please see:

• “OECD: International students may be underinformed about job prospects in top destinations“
• “New data provides early signals that Canada’s popularity as a study destination is on the rise“
• “New international student permit approvals for Canada fell below COVID levels in 2025“
• “Canada’s foreign enrolment has fallen by nearly 300,000 students over the last two years“

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The scrutiny is coming from more than one direction. Admissions offices are tightening their own checks on the authenticity and consistency of English-language evidence, in response to well-documented fraud vulnerabilities and inconsistent evidence standards across the sector.

At the same time, UK Visas and Immigration (UKVI) now runs an annual Basic Compliance Assessment (BCA) for every institution holding a student sponsor licence, scoring them on visa refusal rates, enrolment rates, and course completion rates. Falling short on any one of those metrics can strip an institution of the right to self-assess a student’s English ability altogether, forcing a shift to mandatory secure testing across the board. Further, a new Agent Quality Framework is being extended so institutions can no longer treat agent-sourced evidence as somebody else’s responsibility. In short: the English-language evidence an agent helps assemble now feeds directly into a compliance metric that determines whether an institution can keep recruiting internationally at all.

That’s the backdrop and it’s also the opportunity. Agents who understand this chain of evidence, and can speak to it confidently, become more valuable partners to the institutions they work with, and better advisers to the students who trust them.

Academic readiness is the cornerstone of student success

Academic readiness is the strongest predictor of first-year performance, progression, retention, and completion. When students arrive without sufficient English proficiency, the impact is immediate: difficulty engaging in seminars and group work, falling behind in reading-intensive modules, rising stress, and a higher likelihood of assessment failure or withdrawal.

Meeting a minimum entry requirement isn’t the same as being ready to perform at it. A student who scrapes the headline overall score with a weak reading or writing subscore is often the one who struggles most in postgraduate, research-intensive programmes, where extended reading and academic writing carry most of the assessment weight.

In practice, that means: looking with the student beyond the single overall band to the subscore breakdown; recommending a margin above the minimum particularly in speaking and writing wherever a programme is writing- or seminar-heavy; and encouraging an early retake where subscores are borderline, rather than waiting until an offer is at risk. Agents who steer students toward the cheapest or fastest route to a passing score to obtain a visa rather than genuine readiness, aren’t doing anyone any favours: those are the students most likely to need extra support, delay progression, or withdraw outcomes now visible to institutions through the BCA’s own completion-rate metric.

The growing scrutiny of MOI

Medium of Instruction (MOI) evidence is under sustained scrutiny, and institutions increasingly treat it as a case-by-case judgement rather than a standard alternative to testing. Practice varies widely: some institutions require MOI letters to be corroborated by transcripts, curriculum details, or interview; others have withdrawn MOI acceptance for certain markets or programmes altogether, following BCA findings that linked MOI-based admissions to weaker completion or higher visa refusal rates.

For agents, that means treating an MOI recommendation as a considered call each time, not a default and being able to talk a student through the reasoning.

Three questions are worth working through together: First, does the receiving institution’s current policy actually support MOI for this student’s country, subject, and level of study? Policies here shift often, so this is worth checking fresh for each application rather than assumed from a previous case. Second, was the student’s prior study substantively delivered and assessed in English not just described as such on paper in a way that plausibly matches the demands of postgraduate or research-intensive study in the UK? Third, is an MOI-based application more likely to trigger additional verification, delay an offer, or be queried at visa stage for this particular market?

Where any of these three is uncertain, recommending secure testing alongside or instead of MOI is the safer, more defensible choice for the student’s academic readiness, and for the agent’s credibility with the institutions they work with.

Secure testing as a strategic enabler

Secure English language testing is worth repositioning, in conversations with students, as more than an entry hurdle. It supports identity validation, demonstrates genuine academic readiness, reduces institutional exposure, and gives students greater confidence going into study. Viewing testing as an unnecessary cost is short-sighted: the real cost is poor preparation academic, financial, and emotional. Framing testing as an investment in a student’s own success, rather than a bureaucratic step, tends to land better with students and parents alike and it happens to be true.

BCA reviews are raising the bar

The Basic Compliance Assessment is an annual Home Office review of how well a sponsoring institution is managing its international student population against three metrics: visa refusal rates, enrolment rates, and course completion rates. Institutions rated amber or red face restrictions including, in some cases, losing the right to self-assess English-language ability, which pushes their entire cohort toward mandatory secure testing. As English-language evidence sits upstream of all three metrics a student who was never really ready for the course is more likely to be refused a visa, to under-enrol, or to withdraw, institutions are having to demonstrate, more rigorously than before, how that evidence was gathered, verified, and judged sufficient at the point of offer, both to their own compliance teams and to UKVI itself.

Agent-sourced evidence is now squarely inside that chain of justification. As regulatory attention on institutions increases, so does attention on the English-language guidance and evidence that agents provide upstream of the admissions decision. Weak guidance creates a vulnerability that traces all the way back to an agent’s file; strong guidance protects the student, the institution’s compliance record, and the agent’s own standing with institutional partners.

Defining practice that works for students and agents

A forward-looking standard is emerging, and it rewards informed, student-centred practice, which includes:

• Recommending the right test for the destination and programme, factoring in university acceptance, subject demands, security requirements, and timing
• Where subscores are borderline, especially speaking and writing for postgraduate, research-intensive courses, advising testing to a margin above the stated minimum, and supporting an early retake rather than a late one
• Treating MOI as a case-by-case judgement using the three questions above, not a standard substitute for testing
• Communicating secure testing to students as an investment in their own progression, not a hurdle to clear
• Keeping documentation authentic, consistent, and aligned with each institution’s current expectations, since these shift
• Engaging admissions teams early to confirm current requirements and reduce delays

These aren’t extra burdens layered on top of an agent’s advising role they’re the parts of that role now most visible to institutions, most consequential for students, and most likely to distinguish the agents that institutions want to keep working with.

The role of agents in a changing landscape

Agents are often a student’s first trusted adviser. Their guidance shapes not just admission outcomes but a student’s confidence, performance, and ultimately their success once they arrive. Getting the English-language piece right is one of the clearest, most immediate ways an agent can add value to that relationship and one of the clearest ways to build a track record that institutions notice.

How ELSAA supports the sector

ELSAA is the English Language Standard Advisory Authority [link to https://englishlsa.com]. Our mission is to strengthen standards, improve transparency, and support risk-aware decision-making across the English-language ecosystem. We work with agents and institutions to:

• Interpret emerging regulatory and compliance expectations
• Identify appropriate English-language pathways
• Reduce institutional and agent risk
• Improve student progression and retention
• Build trusted, future-ready recruitment practices

Agents who build this expertise put students at the centre of every decision and in doing so, strengthen their own standing with the institutions they work with. Strong English-language guidance isn’t an extra step; it’s the advantage.

The English Language Standard Advisory Authority (ELSAA) is an independent organisation dedicated to improving transparency, understanding, and informed decision-making in high-stakes English language testing. Through independent test reviews, comparative analysis, training, and advisory services, ELSAA supports universities, professional bodies, employers, and policymakers in evaluating and using English language assessments with confidence.

For additional background, please see:

• “Study highlights gaps between English standards set by test developers and those used by universities and professional bodies“
• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“

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As expected by US international education experts, the Department of Homeland Security (DHS) has made only minor revisions to its August 2025 proposal to end Duration of Status (D/S) for F and J students and their dependants despite vigorous lobbying across scientific, business, and higher education sectors. The government published , and it will go into effect on 15 September 2026.

Duration of Status will be replaced with fixed periods of stay for F and J students – four years – unless students are in language programmes, the admission duration for which will be maxed at 24 months. (For detailed background on the policy, please refer to our earlier reporting.)

To stay in the US for longer than the end date marked on their I-94 form, international students need to apply and be approved for an extension by US Citizenship and Immigration Services (USCIS). If they do not receive that extension, they will have to leave the US or be identified as unlawful and subject to a three-to-ten-year ban on re-entering the US.

There is no grace period for four-year F and J students after an extension of status denial at the end of the initial admission period: students and any dependents who may have come to the US with them are required to depart immediately. If not, the next day marks the official beginning of their unlawful presence in the US.

Commenting on the new rule, NAFSA Executive Director and CEO Dr Fanta Aw said:

“DHS’s decision to end Duration of Status is a misguided and unnecessary policy shift that injects uncertainty, bureaucracy, and fear into a system that has long worked effectively. It is a solution in search of a problem. International students and exchange visitors are already the most monitored nonimmigrant populations in the United States. SEVIS and the partnership between institutions and the federal government already provide a rigorous and highly effective system of oversight, compliance, and accountability.

“This rule introduces unnecessary government intrusion into academic decision-making. Requiring students and scholars to seek approval to extend their academic program, change majors, or pursue the next level of study places life-changing educational decisions in the hands of an already overburdened immigration system rather than educators and institutions.

“At a time when global competition for talent is intensifying, this policy sends exactly the wrong message. It tells the world’s brightest students and scholars that the United States is becoming less welcoming, less predictable, and less committed. This is not just bad for higher education, it is bad for American innovation, economic growth, workforce development, and global leadership.”

What will the new rule mean for universities, agents, and students?

Universities and agents: The incoming rule will raise many questions for educators and agents who will be pressed to advise students properly. NAFSA explains:

“There are��transition provisions��for F and J nonimmigrants who were admitted for D/S on their Form I-94 and are inside the United States on September 15, 2026, the final rule effective date. These individuals will not have to immediately apply for a date-certain I-94, but they must still apply for an extension of stay in order to remain in status beyond the program end date on their current Form I-20 or DS-2019, or four years from the final rule effective date, whichever is shorter, and will also be subject to the new academic restrictions in varied ways. If someone in this transition group exits the United States and reenters on or after September 15, 2026, CBP will readmit them with a Form I-94 with a date-specific AUD.”

New international students who had planned to begin programmes this fall may now decide not to. Two segments are at particular risk of reconsidering their decision to study in the US:

• Those for whom the opportunity to pursue Optional Practical training (OPT) after their studies was central to their decision to choose the US as a destination. They now know that the maximum period of admission on an F or J visa is about to be four years, which means they would need to apply for an extension to go on to OPT – an extension that might be rejected.
• Graduate-level students, who will realise that four years may not even cover the length of their programme, let alone OPT.

The OPT and STEM OPT post-study work streams are vital to US institutions’ ability to compete for international students (especially those in STEM and at the graduate level). A 2025 survey conducted by NAFSA and the Institute for Progress found that 54% of current international students would not have chosen the US if there was no OPT option.

Current international students: Current F and J students will live in a climate of uncertainty: many will be required to apply for a visa extension before graduation, knowing that they could be denied that extension. This would mean that their studies in the US would be over the day after they were refused an extension. They would not be able to finish their degree in the US.

Additional components of the new rule bar F and J students from changing academic programmes, and graduates who complete one academic programme will only be able to enrol in a new one if it is at a higher educational level.

What is the context for the introduction of fixed admission periods?

At present, USCIS’s processing of immigration requests has never been more backlogged. Adding international students’ requests for extensions to the backlog will only worsen the situation. Many students will face a long wait to see if their extension is approved. 


��
The granting of extensions will be in the hands of immigration officials at a time when the US government is eager to reduce the flow of foreigners into the country.

How best to advise students and brief student advisors?

The immediate priorities for many US institutions and stakeholders leading up to the September effective date will include:

• Retraining staff on the rule’s key concepts and new terminology (e.g., “admit until date” [AUD])
• Reviewing all programme types for better understand how the new rule will impact each (e.g., pathway programmes, dual degrees, certificates, two-plus-two arrangements, intensive English programmes, undeclared majors)
• Communicating with current students and scholars, especially those approaching their program end dates

Stakeholder groups have already produced a number of explainers and background docs on the new rule, and this process of analysing the details of the rule and developing clear and effective guidance for students and advisors will no doubt continue for some time.

NAFSA, for example, has prepared a detailed set of on its duration of status page (login required). And a number of detailed background docs are already available, including the following:

• 
  ��
  For additional background, please see:

• “US to end ‘Duration of Status’ for F, J, and I visas and limit the time international students can study in the US”

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It has set the National Planning Level (NPL), its system for controlling the flow of foreign students into universities and vocational (VET) education providers, at 295,000 new student spaces distributed across those institutions. This is the same number as last year, and the government considers this a continuation of a managed growth approach that “has been effective in returning student numbers to a more sustainable level in 2025, and so far in 2026.”

For background, the NPL system dictates that visa applications are processed normally for an institution that fills up to 80% of their allotted new student spaces. Beyond that 80% threshold, visa processing slows for that institution relative to others that stay within the threshold. The system aims to curtail over-aggressive international recruitment.

The NPL, however, is not the only way in which the government is constraining growth. On top of visa processing controls, a range of other recent policies make it more difficult for international students to choose Australia as a study destination. These include:

• Visa application fees that have risen repeatedly over the past couple of years and which now stand at AU$2,500 for a study visa and AU$5,750 for a post-study work visa. These are the highest in the world, and they are non-refundable for students who end up being rejected.

• High visa rejection rates, especially for Indians, Bangladeshis, and Nepalis.

The government’s satisfaction with how the National Planning Level is working obscures the fact that higher fees and rejection rates are causing international student demand to fall well below what might be considered “sustainable.” Some Australia institutions are not able to reach their allocation levels due to declining volumes of applications and enrolments.

The following chart shows trends in commencements (new student arrivals) over time, and it illustrates the sharp decreases from 2023–2025.

What is the real target?

from minister of education Jason Clare, assistant minister for international education Julian Hill, and skills minister Andrew Giles acknowledges:

“Current tracking indicates international student commencements are on track to be below the NPL for both 2026 and 2027. Commencements in 2026 are down 8 per cent compared to the same period in 2025, and 13 per cent lower than 2019.”

So, the NPL may be set at 295,000 in 2026 and 2027 – but the fact that commencements are coming in well below that threshold appears not to be an issue for the government. This seems quite likely given the follow-up statement in the press release:

“The decision to freeze the NPL at current levels accompanies adjustments to student visa fees.”

Mr Clare, Mr Hill, and Mr Giles all issued comments about the 2027 arrangements:

• Mr Clare: “International education is an incredibly important export industry for Australia, but we need to manage it sustainably. This is about making sure international education supports students, universities and the national interest.”

• Mr Hill: “The Albanese Government inherited a mess from the Liberals in 2022, with unsustainably high growth in student numbers in the least reputable parts of the sector and student visas being misused by crooks and shonks. The Government will not back off from managing the size and the shape of the onshore international student market and ongoing moderation in student numbers towards a more sustainable sector. Australia continues to welcome genuine international students seeking a premium Australian education which is great for our unis, domestic students and research.”

• Mr Giles: “International VET strengthens outcomes for students and supports our workforce, while deepening valuable global partnerships. Today’s announcement provides certainty for the international VET sector, enabling it to continue delivering sustainable growth and high-quality skills outcomes.”

Universities Australia Chief Executive Officer Luke Sheehy issued his own statement on behalf of the sector:

“Sustainability and integrity matter, and universities support both. Keeping new overseas commencements steady gives the sector something to plan around, but it is a long way from the sustainable, managed growth the government promised two years ago.

“Today’s announcement confirms there will be no growth next year. We recognise this may be appropriate in the current context, but the bigger problem is that the policy settings behind the number are making even this steady target harder to reach.

“If the government keeps making Australia more expensive and more difficult for genuine students to choose, we’re going to fall short – and we’re already seeing that risk emerge.

“That’s bad for our sector and Australia. It means fewer skilled workers, weaker productivity and a $55 billion export sector supporting 250,000 jobs put at risk.

“Many universities, particularly in regional and outer suburban Australia, are ready, willing and able to welcome more international students.

“International education is one of Australia’s great success stories, but it’s being steadily eroded by policies that do not serve our universities, our economy or our skills needs.

“A big number on paper means little if the policies behind it make it harder to deliver in practice.
That’s the contradiction at the heart of the current approach. The government says it wants almost 300,000 new international students, while keeping in place policies that make that harder to achieve.

“Unless the broader settings change, the 2027 allocation risks being just another number – not a plan that delivers the skills, jobs and growth Australia needs.”

More details about the NPL arrangements for 2027

None of the education providers subject to the NPL will receive fewer applications in 2027 than in 2026

The following are exempted from the NPL’s allocations:

• Schools
• Students studying standalone ELICOS courses
• Higher degree by research students
• Non-award students, including short term exchange students
• Students studying at TAFE and students enrolled in VET courses at Dual Sector public universities
• Students awarded certain scholarships including from foreign governments, multilateral organisations and Australian governments
• Students that are part of certain Australian Transnational Education (TNE) arrangements in higher education or VET approved by the Department of Education or the Department of Employment and Workplace Relations
• Students from the Pacific and Timor-Leste
• Students in pilot training courses
• International students transitioning from secondary school studies in Australia to tertiary study (higher education or VET)
• Students transitioning from embedded pathway providers or TAFE institutes to affiliated publicly funded universities
• Students transferring providers as a direct result of a provider closing or otherwise being unable to continue training.

For additional background, please see:

• “Australia: Multiple data indicators signal further declines ahead for international student numbers”
• “Surprise hike in international student visa application fees ‘a direct hit to Australia’s competitiveness’”
• “Australia: Latest enrolment data challenges the government’s assertion of stability for international education this year”

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The end of duration of status?

DHS, which includes United States Citizenship and Immigration Services and United States Immigration and Customs Enforcement, says it will publish an updated rule establishing a fixed time period for international student visas in July 2026.

from immigration law specialists Fragomen explains: “This month, DHS plans to issue final regulation that will end the longstanding practice of admitting foreign students (F nonimmigrants), exchange visitors (J nonimmigrants) and media representatives (I nonimmigrants) to the United States for the duration of their program – known as ‘duration of status’ – and switch to admitting individuals in these categories with a fixed expiration date, after which they will be required to file an extension with the immigration authorities in order to remain in the United States.”

For those who would like additional background on the forthcoming rule, we have written extensively about the pending changes to duration of status. Details of DHS’ proposed rule from August 2025 are .

This rule change has been anticipated all year and has the potential to introduce significant aspects of uncertainty and disruption for foreign students in the US. As such, we might expect that it will also be subject to legal challenge on publication.

Proposals pending for practical training

The newly published agenda for 2026 carries over an item from the prior agenda pertaining to .

Details of the planned reforms are now anticipated in February 2027. For the moment, DHS says only that, “The proposed rule will better align practical training to the goals and objectives of the program while providing more clarity to the public. The proposed rule will amend existing regulations to address fraud and national security concerns, protect US workers from being displaced by foreign nationals, and enhance the Student and Exchange Visitor Program’s capacity to oversee the program.”

To the extent that those reforms affect the Optional Practical Training (OPT) programme, this could be another very consequential change in policy settings.

Of the 1,177,766 foreign students in the US in 2025, just over 294,000 (or about one in four) were in OPT. Participation in the programme was up 21% year-over-year from 2024 to 2025, continuing a multi-year programme of significant growth in programme participation.

Beyond its sheer scale, OPT is a critical aspect of the US offer to international students as it is the most widely used pathway to post-study work for foreign graduates. In a 2025 survey of current international students conducted by NAFSA and the Institute for Progress, 54% of respondents said they would not have enrolled at a US university had OPT not been available to them.

H-1B reforms

In another continuation of an item from the previous regulatory agenda, DHS say it intends to proceed with reforms to the H-1B work visa programme.

First published in , this amounts to a statement of intent to reform the programme “by revising eligibility for cap exemptions, providing greater scrutiny for employers that have violated program requirements, and increasing oversight over third party placements, among other provisions. These changes are intended to improve the integrity of the H-1B nonimmigrant program and better protect US workers’ wages and working conditions.”

There is no other detail in the agenda docs, except that the Department expects to publish its proposals for H-1B in August 2026.

For additional background, please see:

• “There are more international students in the US than ever in 2025, but commencements are declining“
• “US to end ‘Duration of Status’ for F, J, and I visas and limit the time international students can study in the US“
• “What international students need to know about study and work visas in the United States“

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All sub-sectors are affected, with – non-refundable – visa application fees rising as follows:

• Student visa application fee for higher education and vocational (VET) studies (subclass 500): AU$2,000 to AU$2,500, unless students are from ASEAN countries (AU$2,050)
• Student visa fee for English-language studies (ELICOS): AU$2,000 to AU$2,050
• Temporary Graduate Visa 485 (for post-study work): AU$4,600 to AU$5,750
• Partner visa: AU$9,365 to AU$11,710

In addition, the minimum salary threshold for employer-sponsored work visas increased from AU$76,515 to AU$79,499, and the specialist skills income threshold moved from AU$141,210 to AU$146,717.

The government’s announcement has prompted a universal response of shock and dismay across Australia’s international education sector, with many stakeholders warning that Australia’s education brand is now at a deep disadvantage compared with other major destinations.

Vicki Thomson, chief executive of The Group of Eight (representing eight of Australia’s leading research universities), said:

“This is not just a visa fee increase. It is a direct hit to Australia’s competitiveness, skills pipeline and international standing.”

Repeated fee hikes, and much more expensive

As it stands, the AU$2,500 student visa application fee for higher education and VET compares to about the following fees for equivalent visa classes:

• AU$775 for the US
• AU$935 for the UK
• AU$240 for Canada
• AU$790 for New Zealand

Australia’s visa fees have been repeatedly increased by the Labor government between 2022 and 2026 with little to no warning or consultation. If we look just at 2022 fees and 2026 fees (rather than considering several increases in between these years):

• The student visa application fee has risen by +285%
• The temporary graduate (work) application fee has risen by +148%
• The partner application fee has risen by +45%

By contrast, in Canada, there has been no increase in the study permit application fee since 2022. Nor has the US government increased the application fee for F-1/M-1/J-1 visas in that time frame. The UK has had two hikes since 2022, but the percentage change between 2022 and 2026 is only about +15%.

Comparing 2022 and 2026 is one thing, but using a shorter-term lens is at least as startling since it shows just how much international students and education providers in Australia have had to deal with in the space of one year: a +25% increase for study visas (higher education and VET) and a +25% increase for work visas.

While the visa application fee for ELICOS went up less drastically than for other sectors this time (AU$2,000 to AU$2,050), the fee was already so high at AU$2,000 that it has tanked demand for English-language studies in Australia. Ian Aird, CEO of English Australia, says:

“No announcement was made of the decision to hike these visa fees – a decision clearly reached weeks if not months ago. There was no discussion with the sector to consider the likely impacts of these changes. Having been on the phone to members much of the day, it is important to acknowledge the frustration, disappointment, even heartbreak that many of our members are feeling at this news.

“It’s notable that ELICOS has been given a $50 fee increase, not the full $500 increase. It’s a small mercy when the $2,000 fee has already demonstrably decimated the sector. By increasing the student visa application charge for ELICOS by $50, the government has signalled that it is able to differentiate the visa application charge by sector, despite having stated multiple times over the last 18 months that this was not possible, that the government’s computer systems were not able to manage it. However, it also signals that this government does not wish to address the damage done to the ELICOS sector by charging the highest visa application charge in the world, even though so many Australians have and continue to lose their jobs due to this fee increase.”

The “non-refundable” part of the story

The impact of escalating visa costs is compounded by extremely high visa refusal rates for students from a number of markets. Shorter courses – especially in ELICOS – are the most affected by both soaring visa application fees and rejection rates, since applying for an Australian study visa is now roughly as expensive as a short English-language course of 10 weeks. It is not difficult to see why visa application fee hikes over the past couple of years have led to commencements in English-language teaching programmes falling by -40% in 2025 compared with 2024. It is just too risky for many students to apply for a visa for these courses.

Mr Aird points out that the fee hikes are not just turning prospective students away, but they are also destroying the livelihoods of Australians working in ELICOS and economic sectors that benefit from international student spending:

“[The increases] come without care for the Australians who will lose their jobs or the Australian businesses it will destroy – and not just in the education sector. ELICOS students contribute significantly to international tourism, retail, hospitality. The damage done by past visa fee hikes has seen ELICOS numbers fall 60% to 20-year lows costing 1000s of Aussie’s their livelihoods. This new fee increase will drive that further.”

The effect on current international students

In the fall of 2023, IDP Education’s Emerging Futures survey found that in the span of just a few months, Australia had drawn even with Canada as the most preferred destination of the Big Four – largely as a result of the work opportunities it offered international students. So much has changed since then, but what hasn’t changed is that a huge part of Australia’s draw is its post-study work visa.

Writing on , Weihong Liang, president of the International Students Representative Council of Australia (ISRC), spoke of how current international students will be affected by the abrupt announcement of the increased cost of the Temporary Graduate visa:

“For students in their final semester, this is not an abstract policy adjustment. It is a sudden financial burden imposed at the point where they have the least room to change their plans.

“Many of these students came to Australia two or three years ago. They were told that Australia welcomed international talent. Post-study work rights were widely presented as part of Australia’s international education offer. Students made major life decisions, paid substantial tuition fees, moved countries, and built their future plans around the policy settings available at the time.

“Now, after they have already committed, the cost of that pathway has increased dramatically — twice in four months. At the same time, Australia continues to recruit international students globally.

“Governments have the right to change migration policy. But fair policy implementation requires notice, transition arrangements, and respect for those who have already made decisions in good faith.”

Also on , Kaixin Ji, a PhD student specialising in human-centered AI said:

“As an international student who has studied and lived in Australia for 12 years, I feel deeply disappointed and betrayed by this country. I completed my bachelor’s and master’s degrees in IT, and I recently obtained my PhD in Computer Science. Yet after graduation, I have struggled to find a job in either industry or academia. I am also unable to apply for permanent residency because I have not had the required “skilled work” experience for skills assessment.

“This means I have to apply for the Graduate Work (485) visa — a visa that has increased twice this year and now costs A$5,750, with no prior notice … This sudden fee increase may force me to ask my parents for financial help, which feels deeply painful and humiliating as a grown adult. Australia needs to ask whether this is a fair way to treat the people it actively encouraged to come, study, work, and contribute.”

Seeming disregard for the sector

Across the sector, stakeholders have raised concerns about the government’s approach to international education. In an email to ���Ϲ��� Monitor, International Education Association of Australia (IEAA) CEO Phil Honeywood said:

“Australia’s competitor study destination countries will be celebrating today at our market share’s expense. With no consultation and no phase-in period, all visa categories have been increased overnight by approximately 25% …

“The official excuse from our government [for the hikes] is that additional funds are required to pay for national security budget blowouts. However, our beleaguered sector is fed up with such excuses as we are increasingly being seen as just a cash cow for non-related budget issues.”

Felix Pirie, CEO of the (ITECA), said:

“As has become the norm, this was done without sector consultation or engagement as to the likely impacts. It is difficult to build trust when surprises like this have direct and damaging effects on businesses, students, and international partners.”

Universities Australia CEO Luke Sheehy wrote about :

“For years, governments encouraged universities to build this sector because they recognised it as a national asset. The same governments that encouraged universities to build this success are now dismantling it, one decision at a time.

“Today’s fee hike doesn’t stand alone. It comes on top of higher visa refusal rates, policy uncertainty and a series of decisions that have made Australia a less attractive destination.

“Australia needs a stable, competitive international education policy that recognises this sector for what it is – one of our greatest national assets.”

For additional background, please see:

• “Multiple data indicators signal further declines ahead for international student numbers”
• “Australia: Multiple data indicators signal further declines ahead for international student numbers“

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We reported last month on another important factor affecting UK student visa issuance: withdrawals. Indeed, there have been growing indications in recent months that the number of withdrawn visa applications has been rising quickly.

There appear to be a couple of factors at work. On the one hand, students may choose to withdraw in the face of lengthy processing delays or out of concern that they would have a visa refusal on their record. On the other hand, institutions may withdraw a student’s Confirmation of Acceptance for Studies (CAS) if they feel the visa application could be rejected.

This is all happening of course in the context of the heightened compliance requirements under the UK’s Basic Compliance Assessment (BCA) framework and its accompanying Red-Amber-Green (RAG) banding system. As of 1 June 2026, the RAG system obliges UK institutions to maintain a visa refusal rate of less than 5%. Universities whose refusal rates reach above that benchmark can be subject to sanctions or even to the suspension of their license to sponsor international students.

The stakes, to say the least, are high. And that underscores the growing role that withdrawn visa applications appear to be playing this year. Home Office data on the clearance outcomes for student visa applicants highlights that, for first time in decades, there were more student visa applications withdrawn in Q1 2026 than there were applications refused.

Writing in newsletter, Spencer Withrington explains:

“Why withdraw rather than be refused? Delays and incentives, on both sides. Processing ran badly behind on the January intake, hitting applicants from South Asia and parts of Africa hardest, with some students still waiting weeks after submitting their biometrics. A student facing a likely refusal, or a start date they will now miss, is often better off withdrawing than carrying a refusal on their record. Universities have the same incentive, and frequently withdraw the [CAS] themselves, because a withdrawn application does not count against their compliance rating and a refused one does.”

This has not been widely understood among students or stakeholders, but a university may withdraw a CAS at their discretion, if, for example, the student has missed important deadlines or has not paid required tuition deposits or filed any outstanding documents. An institution might also move to withdraw a CAS if they discover inconsistencies in the student’s documents or if concerns otherwise arise in internal credibility checks conducted by the university.

The CAS is withdrawn when the issuing institution cancels it with UKVI (UK Visas and Immigration). Once it has been cancelled, the CAS can no longer be used to support a student’s visa application. The university must notify UKVI in such cases; the student may or may not be notified.

A related analysis from points out that the surge in visa application withdrawals in Q1 was especially concentrated among students from South Asia, and from Pakistan in particular: “Prospective students from Pakistan shouldered 43% of all withdrawals. Additionally, only eight student populations withdrew over 50 applications,” including those indicated in the following chart.

“Pakistani students were also among the most affected by the UK government’s processing delays for the January 2026 intake,” adds ApplyBoard. “These delays were largely driven by attempts to clear an application backlog and run additional checks on students from populations considered more likely to stay in the UK beyond their allotted time or claim asylum. While the government encouraged UK institutions to extend their last day of acceptance for students still waiting on a visa decision, some institutions reported that as many as 50% of their students’ visa decisions were outstanding as admission deadlines neared.”

In a situation like that, where every visa refusal counts and where a few too many can tip an institution into an amber or red RAG band, it is easy to understand why both institutions and students would choose to trigger a withdrawal.

This is a significant development, says Mr Withrington, because “it changes recruitment behaviour directly. A CAS withdrawn before the visa decision drops out of the refusal-rate sum entirely. For a provider sitting near the 5% line, the difference between a refused application and a withdrawn one is the difference between a metric that bites and one that does not. That is an uncomfortable incentive the rules have now codified.”

For additional background, please see:

• “UK: Sponsored study visa issuances down, rejection rates up, and more“
• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“
• “What is happening to student mobility flows between the Global South and Global North?“

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It is no coincidence that the Key Five are all emerging countries in the Global South, where large proportions of students are open to emigrating, temporarily or permanently, because of limited local opportunities. This makes immigration officials tend to question whether study visa applicants are genuine students – i.e., interested in quality education, a high-skilled job, and remaining compliant with visa conditions – or individuals with little intent to study and great intent to migrate in any way they can. Unfortunately, many genuine students from the Global South are disadvantaged in their applications because of where they are from.

The impact of the visa rejection trend for students from emerging economies in Asia and Africa could be enormous across the global international education landscape – and beyond. Already, it is spurring fewer visa grants, reduced recruiting in high-risk markets, and more withdrawals from students eager to avoid a rejection on their student profile. Not surprisingly, commencements are trending down in leading study destinations, and this will pressure overall enrolments in the years ahead.

In this article, we will look at Key Five origin countries with regards to:

• Their importance to overall enrolments across the Big Four;
• Recent study visa rejection rates;
• Commencement trends (i.e., the volume of new students provided a study visa allowing them to enrol in a Big Four education institution).

Contribution to overall international student numbers

According to the most recent available enrolment data, Bangladesh, India, Nepal, Nigeria, and Pakistan compose anywhere from 30% to 40%+ of the entire international student body in Big Four destinations.

Visa rejection rates for the Key Five

Having looked at the huge presence of Key Five students in the total international student populations of the Big Four, we’ll turn to recent visa refusal trends (where official data are available).

Bangladesh: Nearly three-quarters (73%) of Bangladeshi applicants for US F-1 visas were turned away in 2025. Bangladeshi students have in recent years been very likely to receive a visa for Australia (about a 5% rejection rate in 2024/25), but in February 2026, more than half (51%) of offshore applicants from Bangladesh were refused.

India: Indian students, who represent either the #1 or #2 source market across the Big Four, are now quite likely to be refused a study visa in those destinations. Rejection rates were 61% in the US (2025), 80% in Canada (Q2 2025), and 60% in Australia (February 2026). While only 7.5% were denied a sponsored study visa in the UK in Q4 2025–Q1 2026, this this was up from less than 4% in winter 2024/25.

Nepal: More than 8 in 10 (81%) Nepali applicants were rejected for a US F-1 visa in 2025, and in February 2026, the Australian study visa rejection rate for Nepal soared to 65%. Interestingly, Nepali students were more likely to be approved for a UK sponsored study visa in winter 2025/26 than in winter 2024/25, bucking the general trend for emerging markets (see chart below).

Nigeria: Since December 2025, Nigerians have been included in an expanded travel ban announced by the US administration, along with dozens of other countries (mostly in Africa and Asia). In the UK, sponsored study rejections for Nigerian students used to be rare (less than 5%), but in winter 2025/26, 20% of Nigerian applicants were turned away. In Canada, between 70–80% were refused a study permit in in 2025.

Pakistan: More than 70% of Pakistanis were refused an F-1 visa in the US in 2026, and more than 6 in 10 offshore applicants from Pakistan were denied an Australian study visa in February 2026. Like Nigerians, Pakistani students applying for a sponsored study visa in the UK saw their rejection rate spike massively in winter 2025/26: increasing from 5.6% to 41% year-over-year.

These rejection rates for Key Five countries represent an absolutely huge number of potential students turned away.

What is happening to commencements?

Key Five commencements (new student entrants) are falling across the Big Four, with less than a handful of exceptions.
 
A striking example is F-1 visa issuances in the US in July/August of 2024 compared with July/August 2025. The percentages in the table below are based on our analysis of data from the US Department of State. It bears mentioning that in September of 2025 (not shown in the table), F-1 commencements fell further for Bangladesh (-69%), Nepal (-96%), Nigeria (-33%), and Pakistan (-9%) compared with September 2024.

In the UK, the following chart from HESA shows the dramatic drop-off in Indian (turquoise) and Nigerian (navy blue) commencements between 2023/24 and 2024/25: -13% and -33%, respectively. Over the span of two years (2022/23 to 2024/25), the declines were even more serious: -33% for India (126,580 to 94,955) and -132% for Nigeria (53,790 to 23,160).

In Canada, new student arrivals (from all nationalities) fell from 208,750 in 2024 to 115,120 in 2025. In January to April 2026 compared with the same period in 2025, arrivals were down -73% to about 200,000. There is no publicly available government information for specific markets, but the Times of India reports that between January and August 2025, Canada issued just 9,955 new study permits to Indian students.

In Australia, overall commencements fell by about -15% between 2024 and 2025, but this decline was concentrated in sectors other than higher education (the number of new international students in Australian universities edged up slightly in that time period). There was more of a mixed bag of commencement trends for the Key Five than in Canada, the UK, and US. Between 2024 and 2025, Indian and Pakistani commencements fell by -3.5% and -33%, respectively, while Nepal was up +33.5% and Bangladesh +33%.

The implications will stretch beyond international education

Our Key Five markets – Bangladesh, India, Nepal, Nigeria, and Pakistan – can be viewed as roughly representative of what is happening to mobility influences and flows between the Global South and Big Four destinations. They serve to show how immigration policies (and/or policy effects) in the Big Four are affecting demand from top non-EU markets. These policies, especially if they stretch on in time, could lead to:

• An intensification of existing challenges for the operations of hundreds of universities, colleges, and schools across the Big Four. Those institutions are often highly reliant on international student tuition amid declining domestic enrolments and/or public funding. Chinese commencements (which, for decades, were an important source of overall growth) are falling, and emerging markets in Asia and Africa have helped to mitigate the impact.

• Alternative destinations gaining a greater share of the world’s internationally mobile students (this is already happening – see From the Big Four to the Big Fourteen for background).



• A decline in the economic contribution of international education in the Big Four.



• A weakening of innovation and productivity in Big Four economies. India, in particular, contributes a large volume of STEM students and workers to Western nations.



• An erosion of the soft power of the Big Four in the Global South.

Methodological note

Data analyses are based on statistics from:

• The Australian
• (IRCC)
• The UK’s (HESA)
• The in the US

For additional information, please see:

• “UK: International student numbers fall for second year, especially in postgraduate programmes“
• “UK: Sponsored study visa issuances down, rejection rates up, and more“
• “There are more international students in the US than ever in 2025, but commencements are declining“
• “Visa rejections climb in the US for international students from key markets including India“
• “New international student permit approvals for Canada fell below COVID levels in 2025“
• “Australia: Multiple data indicators signal further declines ahead for international student numbers“
• “Australia: Latest enrolment data challenges the government’s assertion of stability for international education this year“

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