Mr. Chair, the CBA national immigration law section makes the five following recommendations. If I don't get through all of them, I will rely on our written material.

First, the government should prioritize creating pathways to permanent residency for students already in Canada. There are students here who have studied and worked here. They're well established, some even having arrived here in their youth. They are permanent residents but for having received the legal status. Canadians likewise have invested in them and supported them. As such, we need to implement unique pathway programs, including dedicated express entry draws targeted at filling labour shortages and aimed at ensuring positive long-term outcomes not only for our economy but also for future immigrants and their families. A broad range of stakeholders must be consulted when building these programs.

We understand that there is an in-Canada focus set out in the levels plan and the minister's mandate, but how is this going to be operationalized and how is this going to be done within the current levels plan?

Second, we should halt the systemic removal of international students with no pathway to PR until the available pathways and exemptions are made clear.

As a result of these recent changes, many students will find themselves without pathways to permanent residency, having lost status or fallen into non-compliance due to circumstances outside of their control. We must explore new ways to facilitate temporary and permanent measures for these individuals utilizing the minister's authority to consider implementing new public policies and revise existing ones. Coordinated efforts to systematically remove and refuse students must be halted until we find urgent efforts to create and clarify the availability of these pathways.

Third, federal and provincial governments must collaborate on a long-term plan for managing international student enrolment. This includes redefining the criteria for designated learning institutions and implementing measures to disincentivize exploitation, reduce opportunities for abuse and provide effective oversight of agents, recruiters and employers. We do recognize the recent positive efforts in the latest regulatory amendments.

Fourth, we should introduce legislation to deter bad actors who prey on international students. This includes harsher penalties for fraud and large-scale misrepresentations. We understand that this takes more than just a whole-of-government approach; it likely will take a whole-of-society approach.

Fifth and finally, a two-tiered system should not be adopted. International students should have the same flexibility as local students to change studies without needing to apply for a new study permit or become non-compliant while waiting. There are many bona fide reasons for students to change institutions, such as mental health, harm prevention, sexual assault and educational advancement. There needs to be at least a list of carve outs.

In our role as immigration lawyers, we work to uphold the integrity of the system while also recognizing and empathizing with the increasing traumas of our clients. Let us ensure that Canada's policies reflect that shared value. Protect international students and hold bad actors rightfully accountable.

Thank you.

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