Key Issues in the Levels Plan: Temporary Residence Admissions Levels

Key Issues

Two weeks ago, AAISA released a summary of the key changes made in the 2025 – 27 Levels Plan.  Now, we explore the implications of the plan further through an in-depth analysis. AAISA is releasing several Insights articles about:

• Permanent residence admissions numbers
• Temporary residence admissions numbers
• Refugees, refugee claimants, and family reunification
• Racism and anti-immigrant rhetoric

As the series concludes, AAISA members will receive these articles in a report format, to share with colleagues within and outside the sector. We encourage members who have responses to this analysis, corrections, or additions, to contact mcunningham@aaisa.ca.

Table of Contents:

• Overview: Temporary Residents
• Inflow
• The Case of the Canada-Ukraine Authorization for Emergency Travel
• Outflow

Overview: Temporary Residents

This year, for the first time, the Levels Plan included targets for temporary residents.

Prior to 2024, rather than setting specific targets in the Levels Plan, IRCC tracked the number of study permits and work permits awarded in each quarter separately. They also reported the total number of individuals with a given permit at a point in time in the annual Report to Parliament.

The annual Report to Parliament provides more detail than the Levels Plan does about current admissions and levels projections. This report tends to be targeted toward the government’s policy professionals as opposed to the general public.

The new targets accord with IRCC’s stated intention to bring temporary resident levels down to 5% of the total Canadian population. This percentage will include refugee claimants (although they are not included in the Levels Plan targets). This is an especially disappointing component of the calculation for many reasons. The cases of refugees, refugee claimants, and other humanitarian admissions will be discussed together in the next article in this Insights series.

IRCC has set targets for both inflow and outflow of temporary residents. However, outflow targets are communicated only in the Report to Parliament, where they have been less reported by the media.

The inflow numbers are complex and require us to do some finicky arithmetic to understand the government’s plan. The outflow numbers, on the other hand, are quite simple, but their simplicity is somewhat alarming.

Inflow

In this first year of target-setting, the new Levels Plan aims to admit almost 675,000 new temporary residents – 45% international students, 12% with work visas from the Temporary Foreign Worker program, and 42% with work visas from the International Mobility Program. These are specifically new admissions, not permit extensions. The International Mobility Program comprises all the work permits for which no Labour Market Impact Assessment is required.

Interestingly enough, in the 2024 Report to Parliament on Immigration, IRCC states that it has also allowed for 143,250 further arrivals in a “contingency reserve” which the Levels Plan does not mention. This number goes up to almost 350,000 arrivals in 2027.

Comparing the 2025 targets to previous years’ temporary resident admissions requires us to disambiguate multiple sources of data. We are pleased to share our data calculations in more detail on request.

The new Levels Plan treats its three categories of temporary residents differently. Temporary Foreign Worker admissions and student admissions are cut, but they remain stable across all three years. Only numbers for the International Mobility Program change to manipulate the overall number.

Plans for policies that cut the number of student admissions and Temporary Foreign Worker admissions have already been announced:

• International students: The cap on study permits, at new low levels for 2025 – 27.
• Workers in the Temporary Foreign Worker program: The new reduction in the temporary foreign worker program, as administered by Employment and Social Development Canada.
  • Note that, as opposed to the case for international students, while the TFW program has been altered in a number of ways, no official cap has been imposed. Rather, the government must have modelled that the changes that have been made will restrict Canadian businesses from hiring through the Temporary Foreign Worker program to such an extent that about 100,000 positions will no longer be staffed by people on the Temporary Foreign Worker visa, and will instead either be taken up by Canadian workers or will remain empty.

However, the International Mobility Program is actually much larger than the Temporary Foreign Worker Program. There are only about 190,000 people living in Canada on the Temporary Foreign Worker Program, whereas there are around a million people on the International Mobility Program. What’s more, the International Mobility Program has more than thirty sub-programs. Which of these programs will see policy changes that might contribute to the cut in levels?

While spouses of undergraduate students will no longer receive open work permits under the International Mobility Program, and the government must be expecting the number of Post-Graduation Work Permits and open work permits for temporary worker spouses to decline as the programs contract in the coming years, IRCC’s data doesn’t suggest that this decline will approach 500,000 people in 2025, which is their target number. Our analysis suggests that, although the government has not said so outright, a significant portion of the decline will hinge on the Canada-Ukraine Authorization for Emergency Travel (CUAET).

The Case of the Canada-Ukraine Authorization for Emergency Travel

The International Mobility Program includes beneficiaries of many different free trade and exchange agreements, intra-company transfers, visiting scholars, and even specialists required for emergency repairs. However, there are relatively few people entering the Program in each of these categories.

IRCC’s statistics suggest that, across all of Canada, a rising percentage of permits between 2021 and 2024 came through the “Other IMP Participants” category. Between 2021 and our 2024 estimates, this category rose from 9% to 27%, rivalling the rates of Post-Graduation Work Permits. What programs could have contributed to this change in trends?

As it turns out, it’s holders of the Canada-Ukraine Authorization for Emergency Travel visa, or CUAET visa, who likely constitute the majority of the increase in this category. When CUAET visa holders applied for work permits, this was the category their permits were recorded under (see this Government of Manitoba publication, for example).

What’s more, for Alberta specifically, almost half of the IMP work permits issued in 2023/24 fall into the “Other IMP Participants” category.

The CUAET program has now ceased enrollment. In the Levels Plan, no specifics are given for which subprograms of the International Mobility Program IRCC plans to cut to obtain the new numbers. However, we can assume that the 2025 – 27 numbers must incorporate the fact that no new CUAET visa work permits will be issued.

It’s worth noting that many more CUAET visas were issued than were acted on. Although the government issued ~960,000 CUAET visas during the program’s lifetime, they estimated that on April 1, which was supposedly the cut-off date to come to Canada using the CUAET visa, only about 300,000 Ukrainian evacuees actually arrived.

Then again, despite the statistics reported on the above page, the government actually extended this initial cut-off date out to December 31 of 2024 for those whose visas were approved in the last eight weeks before March 2024. AAISA members have communicated to us a number of cases of Ukrainians who have continued to arrive. Since IRCC no longer updates the official statistics, it’s impossible to say how many.

Yet cutting the program off does not change the fact that something like 300,000 Ukrainians are currently here in Canada, fleeing a conflict that has extended well beyond the Canadian government’s initial, optimistic policy plan.

Since the latest possible renewal of a CUAET visa will occur in March 2025, and the visa is effective for three years, CUAET visas will expire on a rolling basis up until March 2028. AAISA’s Humanitarian Crisis Specialist has indicated that the end of 2025 and into 2026 will likely be a period in which many work permits associated with the CUAET visa will expire, leaving Ukrainian evacuees without permission to work.

At that time, people who hold CUAET visas will be left with a choice. Some will voluntarily return to the conflict in Ukraine—to a country which the government itself warns Canadians against visiting. Some will stop working and will have to rely on family, savings, or various types of government financial support. Some will continue working without legal status, opening them up to exploitation by employers.

The government recognizes the situation of danger in Ukraine by including it on the list of countries for which an Administrative Deferral of Removals applies. That is, like countries including Syria, Venezuela, Haiti, and Sudan, even if a person has a removal order served against them, they cannot be deported to Ukraine. Canada’s non-refoulement principles under international law apply regardless of a person’s legal status. Nevertheless, the precarious status and fear that will characterize the coming CUAET gap cannot be overstated.

Up until now, we have only discussed the lowered targets for arrivals, the “inflow”, which will not affect immigrants already living in Canada. However, the situation of the CUAET visa demonstrates powerfully that immigrants already living in Canada are taking hits from the many policy decisions issued by IRCC over the course of the last months to accommodate a contracted Levels Plan and their “5% of the population” target.

In fact, AAISA’s analysis suggests that the “outflow” numbers anticipated by IRCC may be the more worrying component of the plan.

Outflow

Another component of the government’s temporary residence numbers, which is reported only in the 2024 Report to Parliament on Immigration and not in the Levels Plan, is temporary resident outflow (here, “non-permanent resident” outflow).

In 2024, before any new policy intervention from the government, 588,409 temporary residents left the country—for example, because their permits expired, their job ended, they left school, they were told to leave when they committed a crime or a family member did, or they simply chose to return to their home country or go somewhere else.

However, in 2025, the expectation is that 1,262,801 people will leave the country. That means an increase in outflow of approximately 675,000 people. This pattern increases over the subsequent years. The outflow targets are not reported by status.

One suggestion will be that, if the numbers of admissions have been going up for the past few years, naturally, the number of people leaving will also go up. Now, exact numbers are extremely difficult to estimate because of the differences between programs. However, a sudden increase that more than doubles outflow in 2025 just doesn’t seem to align with the steady pattern that characterizes the increase in inflow over the past five or six years.

For example, the number of international students in Canada has risen at a fairly steady rate over the course of the past ten years. International students also stay and work for varying periods of time – as short as 16 months for an 8-month college program, or as long as 15 years for a student going through a masters’ and doctoral program and receiving a three-year Post-Graduate Work Permit.  It doesn’t make sense that the number of international students leaving the country would suddenly double in a single year under this type of analysis, which also applies to other temporary residence streams.

Therefore, we must presume that IRCC expects to actively increase the rate at which people leave Canada—and they will have to increase it drastically.

A few policies that have already been announced might affect how long people currently in Canada will remain in the “temporary resident” category. However, none of them contribute significant amounts to this increase in outflow.

• Temporary Foreign Workers: Among the changes to the TFW Low-Wage stream was a change that made the term of stay one year as opposed to two years. Because there are only ~190,000 people in the TFW program in Canada at present, this change in policy probably will not make up a large number of people leaving the country above and beyond the 2024 numbers, certainly <190,000 in 2025.
• TR-to-PR: It isn’t clear whether the government includes their new proposed TR-to-PR category in their calculation of outflow. They propose that temporary residents will make up 40% of the permanent residency numbers next year: that is, about 158,000 people in 2025, much lower than the proposed increase in outflow.
• International students: The government announced in September that a CLB test—Level 7 for university graduates, Level 5 for college graduates—would be required to obtain a Post-Graduation Work Permit moving forward. Perhaps part of the government’s outflow calculation is related to a presumption that some number of students will fail the test and leave Canada. The government has noted the problem of scam private colleges which take advantage of international students, although this response punishes the student, not the college.

Because the government has not released whatever statistics might be available to them on how many post-secondary institutions participate in unethical practices, it’s impossible to speculate how many students they might expect will leave Canada in 2025, 2026, and 2027 as part of this initiative. However, given that there are only about a million international students overall in Canada, the number cannot be enough to produce the government’s proposed outflow numbers over the next three years.

• CUAET: The CUAET program has been twilighted, and the government’s expectation seems to be that people currently on the program will leave as their work permits begin to expire. Between renewals and other logistical factors, unless further programs are put into place, CUAET work permits will expire on a rolling basis until 2028. AAISA’s Humanitarian Crisis Specialist has indicated a likely spike of ending permits in late 2025 – early 2026.

It seems possible that the Canadian government expects that as work permits related to the CUAET visa end, as many as 300,000 CUAET holders will voluntarily return to Ukraine due to the hardships of losing their permission to work. However, this presumption would be both cruel—risking the lives of Ukrainian evacuees for a number on a strategic plan—and, quite possibly, incorrect.

In fact, AAISA’s Humanitarian Crisis Specialist has authored research outlining that as many as 92% of Ukrainians arriving in Canada intended to apply for Permanent Residency in Canada. Countless members and front-line workers have warned us that the majority of Ukrainians they have spoken with plan to stay in Canada if they can. Many will be forced to choose between seeking work out of status in a country at peace and “working” legally in a warzone.

There are a few other populations of “non-permanent residents” who could theoretically factor into this outflow number. However, imagining that they are included raises a number of further logical, logistical, and political questions.

• Refugee claimants: Up until this point, our Insights analysis has not discussed the number of refugee claimants and refugees in Canada. However, we know that refugee claimants fall under the government’s “5% of the population” target, even though they are not included in the Levels Plan. Our analysis so far suggests that none of the announced policy changes to other non-permanent resident populations seem to answer for the extreme increase in the outflow target over the coming three years.

For example, under law, IRCC could only have refugee claimants leave the country by formally adjudicating and rejecting their claims at the Immigration and Refugee Board. But the backlog of claims has grown for years to over 250,000 in September 2024 and 72% of adjudicated refugee claims ultimately award Permanent Residence–that is, IRCC would hit its cap for other Permanent Resident categories long before it would process enough unsuccessful claims to justify these outflow numbers.

• Undocumented people: Because our Insights articles have focused on the official Levels Plan, and undocumented people are of course not tracked in the Levels Plan target, we have also left this important population out of the discussion so far. But since undocumented people have never factored into the count of “non-permanent residents”, including them in the “outflow” numbers seems unlikely.

Given all these factors, it is more likely that the missing numbers will come from as-yet-unannounced changes to existing programs. It is quite possible that the targets will be changed as the government moves on to the phase of implementation.

Nevertheless, the inclusion of refugee claimants in particular in the “under 5%” target is alarming. Canada’s obligation to refugee claimants precludes their inclusion in any demographic targets of this kind. As we will discuss in the next AAISA Insights article in this series, Canada is a signatory to international conventions that mean our country must uphold the legal right of all people to seek safety in another country when they face persecution and to have their case fairly adjudicated. It is not ethical to attempt to set federal targets that would limit the number of people who can claim their international legal rights.

Lowering the levels of temporary and permanent residence is a signal from the government that its overall strategy on immigration has pivoted. However, this ambitious and puzzling outflow number may in fact be the most concerning piece of information in the reporting.  The government ought to openly communicate about this outflow number—and how they envision achieving it.

What does this mean for settlement agencies?

Temporary resident clients are facing an unusual number of rapid changes to their programs, with more possibly on the way. Settlement workers who are monitoring the news and conscious of changes to major programs will be best placed to serve their clients.

Because the federal government does not officially fund services to temporary residents, the changes in temporary resident levels shouldn’t affect federal budget calculations for service agencies.

However, several service agencies in Alberta are funded by the province to provide supports to temporary residents. It is possible that the Government of Alberta will respond to what seems like a decided change in direction by the federal government. As of yet, what form this response will take is difficult to say.

Next article

We reviewed our concerns about the government’s outflow projection and the decision to include refugee claimants in the stated “5%” target for the Canadian population. In the next AAISA Insights article, we will consider refugees and refugee claimants directly. We will explore how issues like family reunification and backlogs affect these populations with a dire ethical urgency which is exacerbated by the new Levels Plan targets and “5%” strategy.