91����

Canada encouraged massive growth in the enrolment of nternational students for years. In 2023, a record number of international students were welcomed in the country, with approximately 1,040,000 primary, secondary, and post-secondary study permits issued (Government of Canada, 2024). This spike in international student (IS) enrolments brought substantial revenues to higher education institutions. However,  facing rising concerns over the quality of education and supports that international students receive as well as political backlash concerning impact on local communities and housing affordability, the federal government recently  instituted a two-year cap on new study permits. The Minister of Immigration, Refugees and Citizenship has also hinted at coming changes to rules on postgraduation work permits (PGWP)¹ as well as Designated Learning Institutions (DLIs).² The shifts in policy mean that there will be a significant reduction in the number of international student visas to be issued, which will affect Ontario more than any other province. Moreover, the predatory role of private career colleges (PCCs) has been called out. There has been debate over the role of private colleges in international education, with PCCs calling for a more evidence-based approach.

In the wake of this discussion, we recently published a report on the regulation of PCCs as part of ³. The Consortium on International Education is brings together a variety of higher education stakeholders who are conducting research on how institutions, government and communities can improve the quality, sustainability and accountability of international education. We are pleased to be a part of this effort through a program of research on PCCs including PCCs in arrangements with their public partners.

Our report, , documents how PCCs are regulated and legislated in Ontario and across Canada, and seeks to lay the foundation for future research that could inform recommendations for the sector. The report comprises the first part of a larger project that focuses on the transparency of information and support services provided to international students enrolled in PCCs and includes data from a review of PCC websites and an online survey of PCCs.

Private career colleges

There are over 1,500 registered PCCs in Canada and more than half (780) are located in Ontario, offering a range of vocationally oriented diplomas in healthcare, technology, community support, business, aesthetics, etc. These colleges, which traditionally served older, less academically prepared and from lower socioeconomic backgrounds, women, first-generation immigrants and/or students whose first language is not English/French, have recently witnessed an exponential growth in the number of IS enrolments in the last few years (Pizarro Milian & Hicks, 2014; Environics Research, 2017; OAGO, 2019). 291 of the 780 PCCs in Ontario are designated learning institutions (DLIs), a federally designated status that allows institutions to recruit international students. Since PCCs form a sizeable part of Canada’s postsecondary education, it is important to understand the regulatory landscape of PCCs in Ontario and in other provinces and territories. This understanding will aid in serving the sector’s most important stakeholder: its students. The present temporary halt in international student admissions at PCCs in Ontario till January 21 2025 provides a unique space for reflection of issues and challenges related to the private career college sector.

Registration processes

PCCs across Canada are typically privately owned and run as commercial enterprises, sans government funding (Li & Jones, 2015). They are regulated at the provincial/territorial level by specific acts. There are specific conditions required for institutions to be registered as PCCs across different jurisdictions, such as (1) the requirement of specific number of instruction hours and (2) certain amount of minimum tuition fee, in order to qualify for registering as a PCC. Once these thresholds are met, and institutes are registered as PCCs, they are governed by provincial/ territorial acts. For example, for an institution to be registered as a PCC in Ontario, it has to have a minimum tuition fee of $2,000 and instruction hours over 40.

Another commonality in the registration processes involves accountability checks for applicants which are outlined under provincial/ territorial acts. These acts require PCCs in  most jurisdictions to provide operator profiles, program registration, labour market needs assessments, program evaluations, and third-party submissions if the program is for a regulated vocation and instructor requirements. First-time applicants in Ontario (like several other jurisdictions) have to provide the Ministry of Colleges and Universities (MCU)⁴ with a specific amount as financial security in the first year of operation. Once all requirements are met and “it is in the public interest to grant the registration,” Ontario’s superintendent will register the college as a private career college (Subsection 14(2) of the Private Career College Act 2005). It is important to understand the narrow reading of “public interest” which hinges solely on the quality of programs and whether they “jeopardize the public health or safety” (O. Reg. 415/06, s. 4). This lack of oversight has led to rampant opportunistic behavior in the sector. The owner of Canada’s largest network of PCCs is one such example. He had faced repeated violations of state business code as an operator of private vocational schools in California (US) before he moved to Canada to set up schools in five provinces under his company, with four PCCs operating in Ontario alone (Olivier, 2012). This points towards an increased need of greater oversight and stringent regulation of standards pertinent to ownership and senior leadership at PCCs as part of “public interest”.

Tuition and Student Aid

In Ontario, the tuition fee information is made publicly available by the provincial government through their online database. However, students are more likely to seek such information on college websites, instead of MCU webpages (or the ALIS⁵ directory in Alberta). On the other hand, provinces such as British Columbia have mandated PCCs to publish tuition fees online.

Student aid in the form of financial assistance is available to students across most PCCs in Canada as long as certain conditions are fulfilled. For example, some of the PCCs in Ontario may indirectly receive funding through Ontario Student Assistance Program (OSAP). The eligibility for OSAP by a PCC is campus-specific and falls under a set of detailed federal–provincial criteria not governed by the PCC Act. According to a Ministry official, as of March 25 2024, nearly 24% PCCs in Ontario are approved for OSAP in Ontario. Given that student aid involves the use of public funds, greater scrutiny is important. Interestingly, Alberta will disallow the use of Alberta Student Aid funding at colleges outside of the province and outside of provincial regulation, in alignment with BC and Ontario from August 2024 (Toombs, 2024).

Advertising

Since PCCs across jurisdictions including Ontario, extensively use advertisements for recruitment of students and promotion of their program offerings, they are monitored to ensure that their advertising complies with regulations. New PCCs have to submit proposed advertising at the time of registration so that the MCU can ensure their compliance with advertising rules. The rules include, for example, not using statements that mislead or are likely to mislead the public, nor guarantee admission to or successful completion of a program, nor imply that employment is guaranteed for any students who successfully complete a vocational program at the college. Saskatchewan explicitly recommends that career colleges keep advertised job expectations realistic. This implies substantiating any claims, like “number one,” or “the leader,” with statistical evidence. To ensure transparency, at some private colleges in Nova Scotia, students must sign letters acknowledging they may have to move away to find employment, or that they don't require the course to find a job in their desired line of work. It was reported that the province even ordered one college to inform new students that job prospects were poor in the Maritimes for graduates of two of its programs. It is important to note that several post-secondary education institutions including PCCs in Canada work with recruitment agents in other countries on a commission-based model. In countries where the agents are well-entrenched in the system and there is lack of oversight, there remains a higher risk of recruiting agents who make inaccurate claims and indulge in misleading advertising tactics. Even though the definition of “advertisement” in the Act⁶ clearly transcends all geographical and language barriers, it remains difficult to monitor agent malpractices.

Compliance

Inspections are also a central part of compliance for PCCs across Canada. Some of the non-compliance issues include providing false or misleading information, providing a program completion certificate to a student the institution did not train or providing unapproved vocational programs. Ontario has a risk-based framework wherein PCCs deemed at a higher risk may be prioritized for inspections earlier. Otherwise, inspections in the province can happen at any time, or at least once over a two- to three-year cycle. This means that certain institutions are subject to more inspections than others, in contrast with provinces such as Manitoba and Newfoundland and Labrador, which have annual inspections as a part of their compliance with regulations.

Curriculum

There exists commonality in curriculum development, program design and program reviews in PCCs across jurisdictions as well. Most Canadian provinces require subject matter experts and industry input, with slight variations in format. For example, Ontario requires two assessors be enlisted by the PCC as part of the process of seeking approval, and the MCU determines whether the assessors meet the criteria, along with a labour market needs assessment, in which prospective PCCs provide evidence to the MCU that the program will translate to employment opportunities in the region. PCCs in British Columbia have a program evaluator (contracted by the institution to evaluate a specific program) and a subject matter expert (contracted by the relevant ministry branch) for program approvals. Saskatchewan additionally requires three kinds of program reviews: ministry, industry and expert third-party. These are meaningful regulations, however, there is a glaring lack of regulations when it comes to periodic program reviews. This absence of program review and re-evaluation may have a severe impact on the learning outcomes of students at PCCs.

Instructor qualifications

Faculty at PCCs are not unionized. Most Canadian provinces and territories clearly outline minimum instructor qualifications (involving prior industry experience and requisite certifications); however, some provinces mandate the registration of specific instructors at the time of registering the PCC. For example, New Brunswick requires PCCs to register all instructors in addition to any agents, salespersons or representatives of the PCC with their registration or renewal; in Nova Scotia, PCCs must list authorized instructors and instructor assistants with their application; Saskatchewan and Prince Edward Island require that instructors are registered with their respective ministries; and in Northwest Territories, before issuing or renewing the certificate, the government director must be satisfied that the qualifications required for instructors are recognized by the applicable industry. Furthermore, some jurisdictions, such as Saskatchewan, Yukon and Ontario, require additional certification such as journeyperson certification or Red Seal in the applicable trade. These detailed regulations hold little value if there is minimum oversight to ensure that minimum standards are upheld.  

Student outcomes

PCCs across certain jurisdictions (such as Alberta, Manitoba, Northwest Territories, Ontario) require submission of student graduation data. As mandated by the Act, Ontario PCCs must report on six KPIs established by the superintendent: graduation rate, graduate employment rate, graduate employment rate in the field of study, graduate satisfaction, employer satisfaction and OSAP default rate.⁷ Nevertheless, except for OSAP eligibility, program and/or registration renewals of the institution are not formalized parts of the renewal process; in contrast to the Act, they do not actually depend upon formal review of KPIs. In addition to this data, Northwest Territories collects job placement data and repayment rates annually, unlike other jurisdictions in Canada. For students to be able to make informed decisions about their future, access to such data should be easily available.

Designated Learning Institutions

Certain requirements are common to all institutions registering as PCCs as well as the institutions applying for DLI status. These common requirements include fire inspection, liability insurance, occupancy certificate, floor plan, and maximum occupancy of students. Important differences exist across provinces when it comes to conditions for applying for DLI status. These differences can be in (1) the operating time period before the PCC applies for a DLI designation and/or (2) additional requirements to be fulfilled before applying for DLI designation. For instance, PCCs in Newfoundland and Labrador, Manitoba, Alberta and Ontario must be operating continuously for three years before they apply for DLI status. However, it is a tad different for Saskatchewan and BC. PCCs must be registered for at least 18 months, have graduated at least one cohort of students and meet student loan designation requirements before applying for DLI designation in Saskatchewan. In BC, not only should a PCC be continuously operating for 12 months before it is eligible to apply for its DLI designation, a registration certificate must be held for the last two years along with the provision of an approved program in at least one of those years, as well as an additional certificate called the Education Quality Assurance (EQA), meant to maintain a minimum level of quality. Obtaining an EQA further merits the institution to be currently operating and continuously delivering at least one program for a minimum of eight months of the year.

The pioneer jurisdiction in Canada to have codified best practices for DLIs under a provincial act is Manitoba. The International Education Act works to ensure the integrity of international education programs and protect the safety and welfare of the students they host. Manitoba’s Guide to the Code of Practice and Conduct Regulation (2016) — developed in collaboration with representatives from the MB government and designated education providers — is a resource to assist institutions in interpreting and complying with the regulations. The province’s Education Institution Eligibility Policy Framework identifies minimum common standards that educational institutions must meet in order to enroll international students. In addition to complying with the code of conduct, DLIs are required to list the agents they work with on their website, and they must charge the same fees to international students as they do domestic students.

Conclusion

This report attempts to add to a research-informed understanding of how government regulations and institutional practices may adapt and evolve to ensure the sustainability and quality of the PCC sector in Canada. As a policy scan and pan-Canadian analysis of regulatory practices, it lays the foundation for future work that could provide recommendations for the PCC sector in Ontario, which is currently finding new ways to grow and adapt to changing policies. 

If you would like to learn more about our research, please contact the corresponding author at seerat.gill@utoronto.ca

About the Authors

Seerat Kaur Gill is postdoctoral researcher in Higher Education, Department of Leadership, Adult and Higher Education at 91����, University of Toronto. She also works as a part-time instructor at The Business School at Centennial College where she teaches Organizational Behavior to diploma and post-diploma students. Her research interests centre on issues of privatisation in higher education, including policies relevant to postsecondary education, international students; and access and equity to higher education.

Elizabeth Buckner is an Associate Professor of Higher Education and the Canada Research Chair in Sustainable Global Development at the 91���� (91����) at the University of Toronto

Glen A. Jones is the Ontario Research Chair in Postsecondary Education Policy and Measurement and Professor of Higher Education at the 91����, University of Toronto. He is the Director of the Centre for the Study of Canadian and International Higher Education. His research interests focus on higher education governance, policy and academic work.

¹ Postgraduation work permits are open work permits given to international students who have graduated from a Canadian Designated Learning Institution (DLI) to work for any employer anywhere in Canada.

²  Designated Learning Institutions (DLIs) is a federally-designated, provincially-regulated status. The Government of Canada will only issue international student visas to students who have been accepted for admission to a DLI-designated institution

³ HECQO is an independent agency of the Government of Ontario that conducts research and provides evidence-based recommendations to the government by employing a multifaceted research approach to inform the implementation of meaningful policies with an aim of improving the postsecondary education in Ontario, Canada and around the world.

⁴ The Ministry of Colleges and Universities provides policy and program direction and financial support to postsecondary education institutions, delivers the Ontario Student Assistance Program, and gives universities the authority to grant degrees.

⁵ ALIS website refers to Alberta careers, learning, and employment information, which provides information for career planning, post-secondary education and training, educational funding, work search, labour market trends, and workplace issues.

⁶ Advertisement is “any advertisement in any language, written or oral, distributed or transmitted by any means, including publication, radio, television or internet” (O. Reg. 415/06 – Sections 15-18 of the Act).

⁷ PCC KPIs are publicly reported through the Ministry of Colleges and Universities. At the writing of this report, the most recent data is from 2021.

References

• Environics Research. (2017). Career Colleges Ontario - Student Demographic Study Final Report. 
• Gill, S., Buckner, E. & Jones, G. A. (2024) Understanding the Regulatory Landscape of Private Career Colleges. Higher Education Quality Council of Ontario.
• Li, S. X., & Jones, G. A. (2015). The “invisible” sector: Private higher education in Canada. K. Joshi & S. Paivandi (Eds.), Private higher education: A global perspective (pp. 1–33). B. R. Publishing.
• Office of the Auditor General of Ontario . (2021). Value for Money Audit: Private Career Colleges Oversight. 
• Olivier, C. (2012, March 11). “Eminata for-profit schools: ‘I never admitted to wrongdoing.'". The Province.
• Pizarro Milian, R., & Hicks, M. (2014). Ontario private career colleges: An exploratory analysis. Toronto: Higher Education Quality Council of Ontario.
• Toombs, A. (2024, July 3). Livewire Calgary.