IRCC announced its latest changes to the International Student Program on September 18, which included changes to the study permit intake cap, as well as the post-graduate work permit (PGWP) and Canada’s other work permit programs.

What jumped out to me is the new language requirement for PGWP applicants:

As part of changes to the PGWP Program, all applicants will be required to demonstrate a minimum language proficiency in French or English. This will increase their ability to transition to permanent residence and adapt to changing economic conditions. A Canadian Language Benchmark (CLB) level 7 for university graduates and CLB 5 for college graduates will be required for anyone applying for a post-graduation work permit on or after November 1, 2024.

CLB 5 is equivalent to 5.0 IELTS and CLB 7 is equivalent to 6.0 IELTS.

Sector stakeholder reactions to this have called this move “perplexing” and “absurd”, and I would tend to agree.

The justification is that this requirement “will increase [PGWP applicants’] ability to transition to permanent residence and changing economics conditions”. On the surface, given that CLB 7 and CLB 5 do align with the language requirements for many of the economic immigration streams, this might seem to make sense.

But you can’t apply for a PGWP without having been admitted to and completed a degree program. CLB 5 and 7 are much lower than the minimum admission requirements of colleges and universities in Canada (with universities almost universally requiring an IELTS 6.5 for an undergrad degree and higher for grad programs, and most public colleges requiring IELTS 6.0), it really doesn’t add up. Why put in place a requirement that’s lower than that required by the majority of postsecondary institutions?

“It’s to target the ‘bad actors’!” one might say. I supposed there could be unscrupulous institutions who have lax or non-existent language proficiency requirements for admission and/or might turn a blind eye to fraudulent test score documents. In theory, they would then be flooding the market with PGWP holders who do cannot operate at a CLB 5 or 7 level in English.

But one move to target “bad actors” has already been implemented: private colleges and public-private partnerships are no longer PGWP eligible. And as for sub-CLB 5/7 PGWP holders coming from public colleges and universities? I’m sure there are a few, but is this really a huge problem? Show me the data—I’d love to see it.

Why is IRCC making this change to seemingly target a problem that doesn’t exist? (And even if hypothetically there were huge numbers of sub-CLB 5/7 applicants to the PGWP, testing would not be the way to fix the problem.)

Whether this is another case of IRCC making changes with a hammer instead of a scalpel, implementing sweeping measures in place to target a few bad actors, or it is simply a hurdle to dissuade students from studying in Canada, it sends a negative message. To me it implies that students and institutions are committing and complicit in widespread language test fraud. And this is simply not true.

It also places a needless financial and logistic burden on international students.

Currently, most postsecondary institutions accept a longer list of academically-focused tests than that of those accepted for immigration purposes (which currently includes CELPIP, IELTS General Training, and the PTE Core). Will the list of accepted tests for the PGWP look more like the list for the Student Direct Stream (SDS), which includes academic-oriented exams? Or will students have to train for a new set of tests to those they may have previously done? And of course, with a two-year eligibility window on test scores, few students will be able to re-use the test score they may have used at admission when they apply for the PGWP. There goes hundreds of dollars out of students’ pockets straight to the big testing companies.

Not all PGWP applicants even go on to pursue PR status. And why require a certain test score when you apply for the PGWP, and then another when you apply for PR? Is IRCC going to waive the test score for PG work permit holders who apply for PR? I highly doubt it.

This new IRCC measure shows ignorance of the fact that the language development gains that someone makes while doing a college or university program in the medium of English are deep and holistic. Through writing and communications courses, taking in advanced academic content in lectures and seminars, doing in-class presentations or participating in workshops, work terms and on-campus activities, someone develops real-life language ability to live, work, research, make friends and be a productive member of a society where English is an official language.

A standardized test only tests a tiny fraction of someone’s real-life language ability. This new testing requirement devalues all of the real-life language development a student may have achieved during their degree program.

Using nonsensical language testing as a hurdle to getting a PGWP only ends up hurting students financially and logistically. It sends a message of distrust to students and institutions around language and postsecondary admissions.