The issue, in numbers
The pressure point was a March 2026 report from the Auditor General on the International Student Program. Auditors reviewed 549,000 individuals whose study permits expired in 2024. Most had moved to a new valid status, but about 39,500 appeared to have no valid immigration status at all. Working with the Canada Border Services Agency (CBSA), the auditors could confirm an actual departure for only 16,000 of them, roughly 40%. For the remaining 23,500, the government could not say.
The audit also found that only about 4,000 of the 153,000 study permits flagged for suspected non-compliance between 2023 and 2024 were ever investigated, and 800 cases involving suspected fraud or misrepresentation were not followed up on at all. Most of those individuals later applied for other immigration status while in Canada, and more than half of those applications were approved, including 105 grants of permanent residence.
Underneath these figures is a structural data problem. CBSA’s own 2025 evaluation of the Entry/Exit Program found a 95% match rate between exit and entry records for 2023 to 2024 travel, excluding first-time travellers. Across roughly 112.6 million air and land passages, the unmatched 5% still came to about 5.6 million border crossings that could not be confidently reconciled, enough to hide tens of thousands of unresolved cases.
What Ottawa is building
On May 4, 2026, Deputy Immigration Minister Ted Gallivan told a House of Commons committee that Immigration, Refugees and Citizenship Canada (IRCC) would launch a pilot in June 2026 to contact international students with expiring visas, and that it is working toward a profile-level indicator showing whether a visa holder is still in the country. Gallivan called it a “paradigm shift” for a department that had not previously taken responsibility for managing departures with CBSA.
Immigration Minister Lena Diab confirmed the effort will extend beyond students to the full temporary resident population, targeting a working system by the end of 2026. IRCC’s action plan sets a December 2026 implementation date, after which it will give CBSA an annual list of people whose permits expired without an extension, a move to permanent residence, or other valid status.
How the risk shifts from the individual to the institution
For now, Canada’s compliance regimes only watch the front door. Since November 2024, DLIs have had to report their study permit holders’ enrollment twice a year, and those that fail to do so can be barred from accepting international students for up to a year. Employment and Social Development Canada and CBSA likewise inspect employers and bar those that violate hiring conditions. Both regimes rely on entry-side confirmations, enrollment and hiring, that institutions and employers largely self-report.
An exit system adds the other half of the picture. Once departures are verified against travel data instead of assumed from an institution’s own reporting, patterns become visible at the institutional level. A school with a growing share of students who enrolled but never register an exit, or an employer whose sponsored workers repeatedly overstay, reads as an institutional-level risk.
How BorderPass helps DLIs and employers get ahead
The student pilot was set to begin in June 2026, and a December 2026 deadline extends exit tracking to the full temporary resident population. Once IRCC’s annual list is running, the department finds the gaps, and a flagged cohort will already be a problem by the time an institution hears about it.
BorderPass’s compliance management system proactively runs the same check on your own records. It tracks every permit’s status and expiry for your students and workers, flags the ones approaching expiry or missing a confirmed departure, and enables you to act: renewing a permit, confirming an exit, or documenting the file before it reaches a government list. The gap the AG audit exposed between arrival and departure is one an institution can close on its own records, with the audit trail and record of actions to show if the government asks.




