Regulations Amending the Canada Student Financial Assistance Regulations: SOR/2026-153

Canada Gazette, Part II, Volume 160, Number 13

Registration
SOR/2026-153 June 22, 2026

CANADA STUDENT FINANCIAL ASSISTANCE ACT

P.C. 2026-643 June 22, 2026

Her Excellency the Governor General in Council, on the recommendation of the Minister of Employment and Social Development, makes the annexed Regulations Amending the Canada Student Financial Assistance Regulations under paragraphs 15(1)(p)footnote a, (q) and (r) and subsection 15(1.1)footnote b of the Canada Student Financial Assistance Act footnote c.

Regulations Amending the Canada Student Financial Assistance Regulations

Amendments

1 Subsection 18(1) of the Canada Student Financial Assistance Regulations footnote 1 is replaced by the following:

18 (1) For the purposes of section 13 of the Act, the aggregate amount of outstanding student loans may not exceed 40 billion dollars.

2 (1) Subsection 40.02(1) of the Regulations is amended by adding the following after paragraph (a):

(2) Section 40.02 of the Regulations is amended by adding the following after subsection (1):

(1.1) For the loan year commencing on August 1, 2026, a qualifying student who is qualified for enrolment or is enrolled as a full-time student in a program of studies that is offered at a private, for-profit designated educational institution, with the exception of a qualifying student who is issued, or in respect of whom is issued, a certificate of eligibility by an appropriate authority for British Columbia or Manitoba, is exempt from the condition in paragraph (1)(a.1) if that institution offers a program of studies of at least two years’ duration that leads to a degree, certificate or diploma not beyond the undergraduate level and that is intended to lead to one of the following occupations:

(1.2) For the loan year commencing on August 1, 2026, a qualifying student who is qualified for enrolment or is enrolled as a full-time student in a program of studies that is offered at a private, for-profit designated educational institution and who is issued, or in respect of whom is issued, a certificate of eligibility by an appropriate authority for British Columbia or Manitoba and that is intended to lead to one of the following occupations is exempt from the condition in paragraph (1)(a.1):

(1.3) For the loan year commencing on August 1, 2027 and for each subsequent loan year, a private, for-profit designated educational institution or a participating province may submit to the Minister — on or before October 15 of the loan year preceding the loan year for which the request is made — a request for an exemption from the condition in paragraph (1)(a.1) for a specific program of studies that is offered by a specific private, for-profit designated educational institution.

(1.4) The Minister must grant the exemption if at least two of the following conditions are met:

(1.5) For the loan year beginning on August 1, 2027 and for each subsequent loan year, a qualifying student who is qualified for enrolment or who is enrolled as a full-time student in a program of studies that is offered at a private, for-profit designated educational institution is exempt from the condition in paragraph (1)(a.1) if the Minister grants, for the applicable loan year, an exemption to the condition for that program of studies offered by that designated institution.

Coming into Force

3 These Regulations come into force on August 1, 2026, but if they are registered after that day, they come into force on the day on which they are registered.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issues: The Canada Student Financial Assistance Program (the Program) plays an important role in facilitating access to post-secondary education — providing opportunities for Canadians to learn new skills and earn new qualifications. Ensuring that it is used as intended is essential to control costs and to provide a fair chance to students who rely on this support.

To help ensure that the Government of Canada is well positioned to continue to provide financial assistance supports to students, the regulatory limit on the maximum total amount of outstanding Canada Student Loans, known as the portfolio loan limit, must be increased. If the current limit is reached, the Minister will no longer have legal authority to disburse additional student loans to qualifying students.

Furthermore, as announced in Budget 2025, to continue operating the Program as intended, the Government of Canada is limiting access to the Canada Student Grant for Full-Time Students (full-time grant) to students attending public institutions and not-for-profit private institutions.

Description: Amendments to the Canada Student Financial Assistance Regulations (the Regulations) will increase the current portfolio loan limit from $34 billion to $40 billion and will restrict the eligibility of the full-time grant to students attending public institutions and not-for-profit private institutions in Canada, with exemptions.

Rationale: These amendments will result in a net positive impact. The monetized benefits of the portfolio measure will be approximately $2,995.0 million (present value) and the costs are projected to be $464.2 million (present value) for a net positive impact of $2,530.8 million (present value).

For the full-time grant eligibility restriction measure, benefits are expected to be $1,627.1 million (present value) and the costs $1,171.6 million (present value) for a net positive impact of $455.6 million (present value).

The total monetized benefit of both these measures is estimated at $4,622.2 million (present value) over 10 years, while total costs are estimated at $1,635.8 million (present value) over the same period. This results in a total net benefit of $2,986.4 million (present value).

Issues

The Canada Student Financial Assistance Program (the Program) plays an important role in facilitating access to post-secondary education by providing financial assistance to qualifying students. The legal authority to disburse Canada Student Loans (loans) is contained in the Canada Student Financial Assistance Act (the Act), and the Canada Student Financial Assistance Regulations (the Regulations) set out the maximum total amount of loans that can be outstanding (not yet repaid), known as the portfolio loan limit. The Office of the Chief Actuary’s most recent public projection estimates that the portfolio loan limit will be reached in the 2028–2029 academic year. An alternative scenario indicated that the recent repayment patterns attributed to the elimination of interest would likely continue to slow and as a result, the portfolio loan limit could be reached during the 2026–2027 academic year.footnote 2 When the limit is reached, the Minister will no longer have the legal authority to disburse new loans to qualifying students.

The Government of Canada committed in Budget 2025 to managing the financial risk to the Government of Canada and to addressing integrity issues related to for-profit private institutions by limiting access to the Canada Student Grant for Full-Time Students (the full-time grant) to students attending public institutions and not-for-profit private institutions.

Background

Canada Student Financial Assistance Program

The Program has the mandate to improve the affordability and accessibility of post-secondary education by offering non-repayable grants and interest-free loans to eligible students from low- and middle-income families. These include targeted supports for students with dependants, students with disabilities, repayment assistance to borrowers facing financial difficulty after their studies, and, in some cases, loan forgiveness.

The Program is delivered in partnership with 10 participating provinces/territories: Newfoundland and Labrador, New Brunswick, Prince Edward Island, Nova Scotia, Ontario, Manitoba, Saskatchewan, Alberta, British Columbia and Yukon. Participation means these provinces and territories receive financial assistance applications, assess eligibility, and determine grant and loan amounts to be provided from both the federal and provincial/territorial governments. The Government of Canada pays administrative fees to the participating provinces/territories for these services. Quebec, the Northwest Territories, and Nunavut do not participate in the Program and receive alternative payments from the Government of Canada to administer their own financial assistance programs.

Applicantsfootnote 3 in post-secondary education who have been assessed and need financial assistance are eligible for federal grants and loans and for funding from participating provinces and territories if they attend a designated educational institution, which includes public universities, public colleges and private institutions.

Grants were introduced in 2009 to help students afford post-secondary education by providing upfront financial support without increasing their debt burden. The grants are provided based on a student’s financial needs. They target students from low- and middle-income backgrounds, those with disabilities, and those with dependants for whom affordability and debt aversion are significant barriers to post-secondary education participation. Students who are assessed to have financial need receive grants first and then loans, up to defined maximums.

Loans became available to students starting in 1964. From 2000 onwards, the Government of Canada issued loans directly to students, meaning it bears the entire risk of non-repayment. Loans provide students with liquidity to pay for tuition and living expenses, without dramatically increasing the cost to the Government of Canada. They are designed with the understanding that a post-secondary education credential (e.g. an undergraduate degree or diploma) will position students for success in the labour market, yielding benefits for Canada and students. The intent is that graduates are well positioned to pay back their loans, which helps mitigate costs to taxpayers and ensures program sustainability.

Portfolio loan limit

To help ensure financial oversight of the loan portfolio, the Regulations set a portfolio loan limit. If this portfolio loan limit is reached, the Minister will no longer have legal authority to disburse new loans to qualifying students. The portfolio loan limit is not intended to prevent qualifying students from receiving financial assistance; rather, it is intended to be a fiscal oversight mechanism in that it requires the Minister of Employment and Social Development Canada (ESDC), with the concurrence of the Minister of Finance, to seek the Governor in Council approval should an increase in the portfolio loan limit be necessary.

Since the Program’s establishment in 1964, the portfolio loan limit has been increased three times:

Recent enhancements to the Program announced in Budgets 2022, 2023, and 2024 and in a ministerial announcement in March 2026 have meant that more Canadians are receiving additional financial assistance. Students are taking longer to repay their loans, which, combined with the elimination of interest on federal loans, has accelerated the growth of the loan portfolio. The annual growth of the loan portfolio for 2023–2024 was about 9.2%, more than four times the average annual growth of 2.2% from 2019–2020 to 2022–2023.

In the “Actuarial Report on the Canada Student Financial Assistance Program as at July 2024,”footnote 4, which was published in September 2025 and uses data from the 2023–2024 academic year, the Office of the Chief Actuary’s median portfolio projection showed that the limit could be reached during the 2028–2029 academic year. An alternative scenario prepared for the Program by the Office of the Chief Actuary indicated that the recently observed repayment patterns due to the elimination of interest would likely continue to slow instead of reverting back to historical trends. Under this scenario, the projections suggest that the portfolio loan limit would be reached during the 2026–2027 academic year.

Full-time grant and private institutions

The full-time grant is the Program’s largest grant, targeted at low- and middle-income students with financial need. It is only available to students enrolled in programs of at least two years (60 weeks) in length. The full-time grant value is temporarily up to a maximum of $4,200 per eight-month academic year or $525 per month of study for the 2026–2027 academic year (up from its permanent amount of up to $3,000 per eight-month academic year or $375 per month of study).

Historically, most students who received the full-time grant attended public institutions, which typically offered programs that were longer than the two-year program length requirement. In contrast, private institutions predominately offered programs that were under two years in duration, meaning students in those programs were not eligible for the full-time grant. However, since 2019–2020, Program administrative data indicates the number of students pursuing two-year or longer programs at private institutions has increased by approximately 150%, from 30 000 in 2019–2020 to 75 000 in 2023–2024. Notably, the vast majority (88%) of the 75 000 students were enrolled in for-profit private institutions in the 2023–2024 academic year.footnote 5

As a result, the amount disbursed to students at private institutions (both for-profit and not-for-profit) for full-time grants increased by 320% between 2019–2020 and 2023–2024, from $68.7 million to $288.5 million. Of the latter amount, 92% was disbursed to students attending for-profit private institutions in the 2023–2024 academic year.footnote 5 Over the same period, disbursements of the full-time grant to students at public institutions only increased by 37% — from $1.1 billion to $1.5 billion. An internal scan of for-profit private institutions did not reveal compelling evidence that this increase can be fully explained by trends in student or labour market demands or gaps in public institution programming. Combined with data indicating that employment outcomesfootnote 6 and default ratesfootnote 7 are generally worse for students from for-profit private institutions compared to those for students from public institutions, the significant increase in the full-time grant uptake by students attending private institutions has raised questions about the value for money of continuing to provide the full-time grant to students attending for-profit private institutions.

Beyond Program data, publicly available data and domestic and international research indicate that public institutions and not-for-profit private institutions show stronger outcomes in completion, post-graduation employment, and earnings, along with lower student loan repayment default and better repayment rates.footnote 8 Additionally, internal Program research has shown that, for certain programs of study available in both the public and private sectors, tuition rates at for-profit private institutions tend to be considerably higher compared with a public institution because they are not publicly subsidized. This means that students who attend these for-profit private institutions may not be receiving the same value for money for the same program of study. Internal analysis using a sample of tuition fees for high priority programs at for-profit private institutions indicated they were on average 63% more expensive than the fees at public institutions. Given the higher costs, it is in students’ best interest to pursue equivalent but more affordable public programs. Limiting the full-time grant to students studying at public institutions and not-for-profit institutions provides a way for the Government of Canada to control costs while providing financial assistance.

Full-time grant eligibility restriction exemption process

To minimize negative impacts on students attending programs of study intended to lead to occupations demonstrating labour market demand, the Regulations will establish a process for exempting certain programs of study at specific for-profit private institutions. Some programs of study offered at for-profit private institutions are intended to lead to occupations that are in labour market demand and during consultations, provinces and territories noted the importance of allowing exemptions to ensure an adequate supply of individuals trained to work in these occupations.

To be exempt from the full-time grant restriction, an annual application must be submitted to the Minister to determine whether the program of study is intended to lead to an occupation that meets at least two of three conditions. If a program of study is exempted, students in that program are eligible to receive the full-time grant for one year. The conditions include: (1) the Minister determines that there is a labour market need for the intended occupation of the program of studies for which the request was made; (2) the intended occupation of the program of study is regulated by the province/territory in which the designated educational institution offering the program of study is located; and (3) the province/territory in which the designated educational institution is located does not oppose the exemption. The first two conditions, namely labour market need and the regulatory status of occupations, can be verified against readily available information. The third condition ensures that provinces and territories that are most knowledgeable of the post-secondary institution landscape have an opportunity to provide input on programs of study at specific for-profit private institutions. The annual application process is intended to allow for responsiveness to changing labour market needs and provincial/territorial concerns.

For the 2026–2027 academic year, since there is not sufficient time for an application process before implementation of the amendments, programs of study leading to one of four occupations (nurse, dental hygienist, early childhood educator, and paramedic) will be exempt. These four occupations were chosen because they meet at least two of the three conditions and, in this case, they meet all three regulatory conditions. All four occupations were also identified during consultations with provinces and territories.

Objective

The objectives are to help ensure

  1. qualifying students can continue to receive financial assistance; and
  2. financial risk is managed by addressing integrity concerns with for-profit private institutions.

Description

The regulatory amendments will

1. Increase the portfolio loan limit from $34 billion to $40 billion;

2. Limit the full-time grant to students attending public institutions and not-for-profit private institutions as of the 2026–2027 academic year;

3. Despite the above, create an exemption for the 2026–2027 academic year to permit any eligible full-time student receiving financial assistance from Alberta, Saskatchewan, Ontario, New Brunswick, Nova Scotia, Prince Edward Island and Newfoundland and Labrador and Yukon, and studying in any program of study at a for-profit private institution to access the full-time grant provided that:

As a result of the Regulations providing these exemptions for the 2026–2027 academic year, no applications are required.

4. Create an exemption for the 2026–2027 academic year to permit any eligible full-time student who receives financial assistance from British Columbia or Manitoba and is studying in a program of study intended to lead to one of the following occupations at a for-profit private institution access to the full-time grant:

As a result of the Regulations providing these exemptions for the 2026–2027 academic year, no applications are required.

5. Establish that, for the 2027–2028 academic year and onwards, a for-profit private institution and/or a province or territory may request an exemption from the full-time grant restriction for a specific program of study at a specific for-profit private institution by submitting an application to the Minister by October 15 of the academic year preceding the academic year for which the request is made.

6. Establish that, for the 2027–2028 academic year and onwards, at least two of the three following conditions must be met for the Minister to grant an exemption:

7. Establish that, for the 2027–2028 academic year and onwards, an eligible full-time student may access the full-time grant if the Minister grants an exemption to the restriction for the applicable academic year.

Regulatory development

Consultation

The Program regularly engages with provincial/territorial partners through the Intergovernmental Consultative Committee on Student Financial Assistance (Intergovernmental Committee), a federal-provincial/territorial body that includes representation from all participating jurisdictions and observers from non-participating jurisdictions. The Program also regularly engages with non-governmental stakeholder associations representing the interests of post-secondary students, students with disabilities, financial aid administrators, post-secondary institutions (universities, colleges and institutes, career colleges), and university teachers through the National Advisory Group on Student Financial Assistance (Advisory Group).

Portfolio loan limit increase

The regulatory amendment to increase the portfolio loan limit does not directly impact stakeholders or provincial/territorial partners, as it simply ensures continued legal authority for the Program to disburse loans. This regulatory amendment will not change financial assistance policies or Program design, meaning there are no implications on the process to determine eligibility for financial assistance or the level of assistance students receive.

Historically, stakeholders and provincial/territorial governments were supportive when the portfolio loan limit was raised, as the increase ensures students with financial needs can continue to receive federal student loans.

November 2025: The Intergovernmental Committee met to discuss the slowdown in student loan repayment, which is occurring due to recent enhancements, such as making loans interest free and improvements to the repayment assistance plan. In the context of discussing how to address affordability pressures for students, the Program indicated that it would need to increase the portfolio loan limit sooner than expected should these repayment trends continue. The Intergovernmental Committee expressed support for an increase to the portfolio loan limit to prevent disruptions for students with financial need.

Full-time grant eligibility restriction

Consultations prior to Budget 2025

November 2023: The Intergovernmental Committee met to discuss shared fraud and integrity issues with certain for-profit private institutions. Members discussed the merits of various administrative approaches and best practices to resolve these problems.

March to June 2024: The Intergovernmental Committee met in person to discuss objectives and priorities to support the development of its 2024–2027 Strategic Plan, which it subsequently approved at a June 2024 meeting. The plan includes the objective of strengthening the integrity of financial assistance by identifying and addressing fraudulent activities occurring at certain private institutions.

November 2024: The Intergovernmental Committee met to discuss quality assurance challenges for certain programs offered by select private institutions. The Intergovernmental Committee was interested in understanding the rapid private institution sector growth, agreeing to inform future policy work and further explore shared concerns.

June 2025: The Intergovernmental Committee met to review highlights of the 2024–2025 Supplementary Survey on Student Experiences with Private Career Colleges. This survey had 6 412 respondents (59% of respondents attending private institutions and 41% of respondents attending public institutions) and compared the experiences of students attending private institutions versus public institutions. The Intergovernmental Committee was concerned with the rise in student enrollment and financial assistance applications, concurrent with trends of non-compliant activity and augmenting long-term default rates in the private institution sector. The Intergovernmental Committee discussed a proposal to limit the full-time grant to those attending select institutions.

September 2025: The Intergovernmental Committee received updates from the Program on its work to enhance integrity at private institutions and discussed exploring further engagement opportunities in 2025 for focused consultations on issues associated with certain private institutions.

October 2025: During an Advisory Group meeting, the National Association of Career Colleges (NACC) raised that it was working with institutions to address challenges in the policy design and compliance of online learning programs, emphasizing the importance of institutional integrity.

Consultations following Budget 2025

November 2025: Following the Budget 2025 announcement, the Program held ad hoc meetings with the Intergovernmental Committee and the Advisory Group to discuss the measures announced relating to financial assistance. The Intergovernmental Committee raised concerns that certain private institutions may be negatively perceived if they are not exempt from the full-time grant restriction measure. Following this meeting, the Program shared a draft Budget 2025 policy design paper with the Intergovernmental Committee for their review and feedback. At the time, Advisory Group stakeholders had no comments on the measure to restrict eligibility for the full-time grant to students attending public institutions and not-for-profit private institutions.

Following the Advisory Group meeting, the Program conducted additional bilateral meetings with the following Advisory Group members: Canadian Alliance of Student Associations (CASA), Colleges and Institutes Canada (CICan) and NACC. Both CASA and CICan sought clarification on the measure but did not express concerns, as CASA represents the interests of student associations tied to public institutions, and CICan represents the interests of public institutions and not-for-profit private institutions, both of which will generally be unaffected by this measure. NACC, however, warned that removing access to federal financial assistance may force vulnerable students to seek alternative sources of funding to pursue education and could cause them to experience worse outcomes than their peers attending public and not-for-profit private institutions. NACC expressed that the measure would result in affected students taking on more loans and going into more debt, making them less prepared to achieve success and more likely to default on the repayment of their loans.

December 2025: The Program met bilaterally with the Canadian Federation of Independent Business (CFIB) and the following Advisory Group members: NACC and the Canadian Association of Student Financial Aid Administrators (CASFAA). All organizations sought further clarifications on Budget 2025 measures. CFIB wanted to understand which types of programs of study would be most impacted and how the full-time grant restriction would affect students, while NACC wanted to know how its member institutions would be impacted. CASFAA conveyed their support for the measure, raising questions about how online programs will be regulated, since rules and parameters vary across jurisdictions.

January 2026: The Intergovernmental Committee met to discuss the design paper and members provided additional feedback on implementation, the exemption process, and the impacts on students. Following this meeting, the final Budget 2025 policy design paper was shared with the Intergovernmental Committee members, along with a draft exemption policy paper for their review and feedback. Members raised concerns that students and institutions impacted by this measure may not receive sufficient notification that they are affected.

February 2026: The Intergovernmental Committee met twice, first to obtain sector insights from NACC and clarify policy design and implementation procedures, and then again to further discuss exemption criteria.

During its presentation of sector insights, NACC indicated that students affected by these regulatory changes may switch institutions and create artificial waitlists for colleges or universities offering similar programs. NACC acknowledged the trend of increasing student financial assistance disbursements to students studying at private institutions and explained that this is in part due to how institutions pair program information with student aid funding opportunities. NACC shared that they have been working with their members to mitigate fraudulent recruitment practices in the sector and indicated that the problem lies with institutions that are not associated with NACC.

During the first meeting, an Intergovernmental Committee member indicated they were facing pressure from institutions seeking to know what to expect, and from individuals trying to make decisions for the upcoming school year.

During the second meeting, the Intergovernmental Committee reviewed the exemption policy design paper, discussing exemption criteria and the application process, as well as common policy standards and approaches to resolve implementation challenges and integrity concerns.

April 2026: The Program met bilaterally with NACC to discuss the proposed full-time grant restriction measure. NACC informed the Program that it had shared the link to the notice of consultation, published for public consultation, with the private institution sector and had encouraged its members to advocate for additional professionals to be exempted. NACC reported that it was generally pleased with the proposed list of occupations for which programs of study would be exempted for the 2026–2027 academic year, although they suggested additional high-demand occupations — skilled trades, cybersecurity and dental assisting — for exemption. The Program clarified that skilled trades are generally not eligible for student financial assistance and thus are not impacted by this measure.

Regarding the above-noted notice of consultation, it was published on Canada.ca and outlined the Budget 2025 measure to limit access to the full-time grant to students studying at public institutions and not-for-profit private institutions, with exemptions. The consultation was open for public comment for seven days, from April 23 to 29, 2026, and was advertised to current and potential post-secondary students via a banner on the National Student Loans Service Centre website. Furthermore, the Program notified the Intergovernmental Committee and Advisory Group stakeholders of the consultation directly by email and encouraged them to inform their networks.

The consultation provided a chance for interested parties to comment on the proposal to limit the full-time grant to students studying at public institutions and not-for-profit private institutions, the conditions for exemption and the approach for the first year of implementation and for the second year and onwards. The consultation requested that participants provide their name, email, and how they would best describe themselves (e.g. students, student associations, educational institutions [public, not-for-profit private, for-profit private], members of the general public, or other).

The Program received a total of 258 responses from the following stakeholder categories:

In reviewing the responses received, it seemed evident that for-profit private institutions and associations representing the interests of for-profit private institutions coordinated their feedback. Many submissions used the same wording to express the same message. This duplication was observed when feedback was sorted by institution or by association. Submissions often included more than one element of feedback such as supporting the first-year exemptions while also proposing other programs of study to be added. The data breakdown below indicates the number of submissions that raised each theme, meaning one submission could be represented across more than one theme.

Consultation feedback on overall measure

Of the 258 comments received, 238 respondents emphasized that receiving Canada Student Grant funding has a major impact on whether students can afford their cost of living while undertaking their education program. A vast majority of them identified a negative impact on students if their financial assistance is reduced. For example, feedback highlighted that students make decisions to pursue post-secondary education with the assumption that they will be eligible for the full-time grant and losing this support will increase the cost of education for them. Other feedback conveyed that restricting eligibility for the full-time grant could discourage potential students from entering post-secondary education, or that this measure’s impact on the finances, family, and employment situations of students could cause those students to prolong, defer, or outright quit their studies. Increased complexity for institutions and students to plan their finances was also raised as a concern. Furthermore, a few graduates of for-profit post-secondary programs shared that they would not have been able to complete their studies without accessing grant funding. Other commenters requested grandfathering for currently enrolled and admitted students.

Concerns about the affordability of post-secondary education for students are valid. While this measure limits full-time grant eligibility to students in programs of study at public institutions or not-for-profit private institutions to manage financial risk to the Government of Canada, there are provisions to grant exemptions in certain circumstances. No other changes have been made to the Regulations to maintain the policy intent of this measure.

Other submissions raised concerns for adult learners and newcomers, indicating that these student sub-populations rely heavily on financial assistance to pursue post-secondary education. These respondents further indicated that grants make post-secondary education financially viable for students, and restricting eligibility may cause them to abandon post-secondary education entirely. While the Program has considered these concerns, the measure is designed to restrict one grant, not all financial assistance offered by the Program. A proportion of students attending for-profit private institutions qualify for more targeted grants, such as the Canada Student Grant for Full-Time Students with Dependants.

Other respondents criticized the measure as unjustly targeting the tax status of institutions, since the full-time grant restriction applies only to for-profit private institutions. For example, a commenter warned that the approach creates operational uncertainty and was worried about how political influence and favouritism may affect the exemption process. While the Program has considered these concerns, the measure is intended to manage financial risk to the Government of Canada and encourage students to seek the best value for money by attending public institutions and not-for-profit private institutions.

Furthermore, 32 submissions asked the Program to revise its approach to affirm students’ right to choose within Canada’s regulated post-secondary education system, maintain equitable access to financial support, and recognize the role that for-profit private institutions have in addressing urgent and localized labour market gaps. While this measure will result in students having to consider the change in full-time grant eligibility, they will still have a choice of where they study. Lastly, the exemption process outlined in these regulatory amendments is intended to ensure that there is an opportunity for for-profit private institutions to continue to contribute to addressing urgent and localized labour market gaps.

Consultation feedback on implementation

Feedback relating to the implementation of the measure was limited. Ten commenters directly associated with for-profit private institutions requested additional consultations before the measure is implemented to help define and operationalize the exemption process. Other commenters requested that a national working group be established to review labour market needs annually and that the proposed changes be delayed to allow institutions to adjust their program delivery/funding models and students to adjust their plans accordingly. The notice of consultation outlined the policy and not the full details of the Regulations. Therefore, concerns raised have been addressed via the Regulations, which detail the exemption process for year one of implementation (i.e. the 2026–2027 academic year), and year two and onwards. Furthermore, as Employment and Social Development Canada leads Canadian labour market assessments for the Government of Canada, it already has established avenues to review annual labour market needs and engage stakeholders on this topic.

Consultation feedback on exemption conditions and process

The Program received 63 comments supporting the proposed exempted programs for year one.

Feedback received requested clarity on the exemption process as soon as possible (18 comments). Specifically, commenters were concerned that eligible programs might not receive exemptions due to administrative delays and that clarity was needed to help institutions manage the additional administrative burden associated with this measure, to help mitigate disruption for institutions and students, and to provide institutions time to align with workforce priorities. In response, the Regulations explicitly exempt some programs for year one of implementation (i.e. the 2026–2027 academic year) and provide details about the exemption process for years two and onwards.

Some commenters (25) asked for outcome-based exemption criteria to respond to labour shortages or labour market demand. While the exemption criteria are not outcome based, one condition does consider labour market need.

A total of 252 submissions suggested additional programs of study be considered for exemption. The programs of study suggested for exemption related to health or dental care occupations, most notably massage therapists (95 comments); information technology occupations, such as cybersecurity (14 comments); community or support services like mental health or addiction support (8 comments); and other miscellaneous programs, including accounting, legal assistant/paralegal, business administration, and more.

The Program reviewed all suggested exemptions; however, the notice of consultation was not intended to be an avenue to make such requests and, moreover, no exemption requests are being accepted for the first year of implementation of this measure. For the 2026–2027 academic year, exemptions have already been determined by the Minister and have been outlined in this document and in the regulatory amendments. For the 2027–2028 academic year and onwards, exemptions will be considered by the Minister upon receipt of an application.

Additionally, there were submissions that suggested including the following skilled trades for the program of study exemption: welding, industrial electrician, heating, ventilation and air conditioning and home renovation. These programs of study do not meet the full-time grant eligibility requirement of being 60 weeks long and therefore, they are not eligible for the full-time grant and would not be considered for an exemption from the eligibility restriction.

The Program received three late submissions after the consultation period had closed. The first was from a student who requested that medical programs be included in the list of exemptions and for protections to be provided to already enrolled students. The second was also from a student who requested that trade programs such as heating, ventilation and air conditioning, industrial electricians, and welding be prioritized for exemptions. The third submission was from an association that suggested that programs of study leading to the following occupations should also be exempted from the full-time grant restriction: medical laboratory assistants/technicians, dental assistants, and personal support workers. They also recommended that exemptions be applied at the institutional level, and that students attending accredited institutions remain eligible for the full-time grant.

As noted above, the notice of consultation was not an avenue to make exemption requests — a province, territory, or a for-profit private institution can apply for an exemption for a program that meets the 60-week duration requirement and at least two of the three exemption conditions for the 2027–2028 academic year and onwards. However, some of the occupations mentioned (i.e. trade programs) do not meet the full-time grant eligibility requirement of being 60 weeks long and have never been eligible for the full-time grant. By extension, they would not be considered for an exemption from the full-time grant eligibility restriction.

Feedback outcome

The submissions received did not result in any changes to the Regulations for the full-time grant restriction, the exemption conditions or the exemption process. However, as noted above, additional details on implementation are included in the Regulations.

Indigenous engagement, consultation and modern treaty obligations

As required by the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an assessment of modern treaty implications was conducted for the regulatory amendments. No adverse impacts on potential or established Indigenous or treaty rights, which are recognized and affirmed in section 35 of the Constitution Act, 1982, were identified.

Instrument choice

The Actfootnote 9 provides the authority for the operation of grant programs, with the detailed conditions to be prescribed in the Regulations. Regulatory amendments are required to increase the portfolio loan limit, as the amount is set out in the Regulations. Similarly, regulatory amendments are required to restrict eligibility for the full-time grant, as the full-time grant eligibility is outlined in the Regulations.

Regulatory analysis

Benefits and costs

A cost-benefit analysis was conducted to assess the incremental impacts on stakeholders of increasing the portfolio limit from $34 billion to $40 billion and to limit access to the full-time grant to students attending public institutions and not-for-profit private institutions. The complete cost-benefit analysis is available upon request to the following email address: DSC.DGA.PCAFE.MCPP-SEC.CSFAP.LB.ESDC@hrsdc-rhdcc.gc.ca.

The stakeholders most directly affected by these regulatory amendments are recipients of financial assistance, the Government of Canada, and for-profit private institutions. The Government of Canada regularly consults with its stakeholders and undertook additional targeted consultations on the full-time grant restriction measure, as detailed in the “Consultation” section. Therefore, no additional consultations were conducted in the development of the cost-benefit analysis.

For both measures, future growth of the Program is assumed to align with the projections from the Office of the Chief Actuary in their 2024 report on the Program.footnote 4 This includes the number of students and real wage growth. Only students and institutions in the 10 provinces and territories that participate in the Program are directly impacted by these regulatory changes. Non-participating provinces and territories receive alternative payments from the Government of Canada to administer their own assistance program.

Portfolio loan limit
Additional funding for students

The increase to the portfolio limit will result in an additional $9.5 billion in loans over 10 years. Total additional loan disbursements will exceed the $6 billion increase to the portfolio because as loans are repaid, more loans can be issued. In 2027–2028, approximately 346 000 students will receive loans because of this amendment. The value of these loan disbursements is not treated as a monetized impact for the purpose of the cost-benefit analysis because students will repay the money to the Government of Canada. The only cost considered in the monetized impacts is the value of loans expected to not be repaid by students due to defaults.

Repayment assistance for students

When the Government of Canada issues loans to students, it is expected that a portion will be repaid by the government rather than by students via the Repayment Assistance Plan. This plan allows borrowers whose income falls below a predefined annual income threshold ($45,456 for a single borrower in the 2025–2026 academic year) to make no payment on their loan. The threshold is adjusted upwards for larger family sizes, and it increases with inflation each year. Borrowers above the threshold can also be eligible for a reduced payment. The money provided under these conditions represents a transfer; thus it is not treated as a monetized impact for cost-benefit analysis purposes. Overall, the Government expects to repay $550 million in additional loans disbursed to students (5.8%footnote 10) over the next 10 years under this plan.

Benefits
Higher future earnings for students who complete post-secondary education

By increasing the portfolio loan limit, the Government of Canada will provide continued funding to students, allowing them to complete their post-secondary education and earn higher incomes over their working lifetime. Based on Census 2021 findings, higher education generates an earnings premium when comparing the incomes of high school graduates and post-secondary school attendees. Bachelor’s degree holders report a median income that is 38% higher than high-school graduates, while those with college diplomas report a median income 14% higher than high-school graduates. Those with degrees higher than a bachelor’s degree report a median income 50% higher than high-school graduates.

Future earnings potential is monetized for 13% of students in the final year of study who would have dropped out of post-secondary studies in the absence of the portfolio loan limit increase. Income is also expected to increase year-over-year based on the real-wage assumption developed by the Office of the Chief Actuary in their 2024 report on the Program.footnote 4

It is estimated that 175 students will remain in post-secondary education and complete their studies in the 2026–2027 academic year as a result of the increase to the portfolio loan limit, increasing to approximately 14 000 students the following year. The number of students impacted in the first year is relatively small, as only a small portion of loans is expected to not be disbursed compared to subsequent years, when the portion is much higher. The new portfolio loan limit of $40 billion is expected to be reached in the 2029–2030 academic year, as projected by the Office of the Chief Actuary in their alternate scenario prepared for the Program, at which point, the number of students expected to be able to complete their post-secondary education because of the portfolio loan limit increase decreases to an average of about 2 500 per year. Over the 10-year period, approximately 54 000 students are expected to complete their post-secondary education, and earn, on average, approximately $11,700 more annually, including the real wage growth. The amount of loans the Government of Canada can disburse when the limit is reached becomes the amount by which the portfolio decreases each year because of loans being repaid or written off.

Over the 10-year period, an estimated $2,995.0 million in income gains (present value) is expected to accrue to students due to the portfolio loan limit measure.

Costs
Cost to the Government of Canada due to students not repaying loans

The cost of continuing to disburse loans to students under the regulatory amendment includes a risk provision for defaults (6.0%). This provision rate was developed by the Office of the Chief Actuary in their 2023–2024 report on the Program. The default cost to the Government is assessed in the year loans are issued. It should be noted that this is a simplifying assumption, as defaults vary by student based on the year of graduation and financial circumstances. Applying this risk provision to the expected additional amount of loans to be disbursed (approximately $9.5 billion) generates a total present value cost of $462.4 million.

Administrative costs for the Government of Canada to process increased financial assistance applications

The continued funding provided will encourage 54 000 students to remain in post-secondary education instead of dropping out for financial reasons. As a result, there will be additional administrative costs under the regulatory amendments to process an increased number of financial assistance applications and to disburse the funds. It is estimated that the additional students applying for financial assistance each year and receiving funding will each generate administrative costs of $41 per application. This results in a total present value cost of $1.8 million over 10 years.

Full-time grant eligibility restriction

For the full-time grant eligibility restriction, students who continue to study in programs that are exempted from this measure are assumed to be unaffected, as their situation remains the same between the baseline scenario and the regulatory scenario. Therefore, the projected volumes presented below account for those students who will continue to get the grant because their program at a for-private institution qualified for an exemption.

More loans for students due to the full-time grant restriction

A portion of the full-time grant funding that students attending a for-profit private institution will no longer receive will be automatically replaced by loans for those who have not yet received the maximum available for the year. It is expected that this measure will result in an additional $50.7 million in loans provided to students over 10 years. As stated, under the portfolio measure, the value of these loan disbursements is not included in the monetized analysis because the money will be paid back to the government by students. The only cost considered in the monetized impacts is the value of loans expected to not be repaid by students due to defaults.

Repayment assistance to students

As in the portfolio loan limit measure, the Repayment Assistance Plan is available for students whose income falls below a predefined annual income threshold ($45,456 for a single borrower in the 2025–2026 academic year) after they finish their studies. As previously stated, the money provided under these conditions represents a transfer; thus it is not treated as a monetized impact for cost-benefit analysis purposes. Overall, the Government expects to repay 5.8%footnote 10) of the additional $50.7 million in loans disbursed to students remaining at for-profit private institutions ($3 million) over the next 10 years under this plan.

Benefits
Higher future earnings for students who switch to public institutions or not-for-profit private institutions

Students transferring from a for-profit private institution to a public institution or a not-for-profit private institution are expected to benefit from better labour market outcomes in the form of higher earnings. The estimated earning premium for public college graduates compared to for-profit private college graduates is 11%.footnote 11

To estimate the behavioural response of students to the full-time grant restriction measure, survey results from the Evaluation of the Canada Student Loans Program (2021) were used as a proxy,footnote 12 along with assumptions to translate qualifying words into quantitative values. The survey asked students what they would do if they received only half of their total government student financial assistance. A total of 46% stated that they would have continued to attend post-secondary education, while 41% stated that they would have delayed their studies and 13% stated that they would have dropped out of post-secondary education.

Under the full-time grant restriction measure, students are expected to lose much smaller amounts of funding and the lost funding in grants may be replaced by loans for those students who have not already reached the loan limit. Furthermore, there is the option that they can continue to receive 100% of the funding by switching to a public or a not-for-profit institution. Therefore, the analysis is based on the 46% of students who would continue to attend post-secondary education. Of these students, 29% said that they were very likely to enrol in the same program, while 33% said that they were somewhat likely and 25% said that they were not very likely to enrol in the same program. It was assumed that 100% of the 29% would make no change, along with 50% of the 33% and 15% of the 25% would also make no change, resulting in 49% of respondents displaying no behavioural changes and thus assumed to remain at their current institution. The other 51% of respondents were expected to change their behaviour by switching institutions. Therefore, if students were to lose 50% of their funding and it was assumed that no student dropped out of school, the survey findings would suggest that 49% of students would continue to study at their current institution and 51% would change their behaviour and switch to a public school.

Under the full-time grant restriction, students are not going to see a 50% reduction in funding. Rather it is expected they will see a 14% reduction in total government student financial assistance. Extrapolating from the analysis above translates into 14% of students changing their behaviour and switching their studies to a public institution or a not-for-profit institution, and 86% of students would continue to study at their for-profit private institutions. Students are expected to start switching institutions in the first year of implementation, as the funding restriction was announced with sufficient lead time for them to adjust their behaviour. To note, this assumes students would not drop out of post-secondary education as a result of losing grant funding.

Future earnings potential is monetized in the final year of study for students who transfer to a public or not-for-profit private institution. The measure to restrict eligibility for the full-time grant is expected to reduce grants for approximately 46 000 students in the first year of implementation, with about 39 000 of them remaining at a for-profit private institution and 7 000 of them transferring to a public institution or a not-for-profit private institution with comparable programs. In subsequent years, the number of students impacted is expected to increase to approximately 48 000 per year; of those, 41 000 are expected to remain at for-profit private institutions, while 7 000 are expected to transfer to a public institution or a not-for-profit private institution. This increase is attributable to the difference between how the exemptions are implemented in year one vs. year two and onwards. Half of the students attending a public institution or a not-for-profit private institution (3 500) are expected to graduate each year and begin earning a wage premium of $5,000 per year, or 11%, more than for-profit private graduates. This will generate a total present value benefit of $537.0 million over the next 10 years. This benefit is net of taxes.

Savings to the Government of Canada from disbursing fewer grants

The Government of Canada will incur a savings benefit by no longer providing the full-time grant to students at for-profit private institutions. This eligibility restriction will result in an annual average of $2,800 less in full-time grants per student. According to the 2023–2024 Program statistical review ,footnote 13 approximately 66 000 students received the full-time grant while attending a private institution. When subtracting those who study internationally, at not-for-profit private institutions and at institutions that are exempted from the measure, along with those expected to switch to a public or not-for-profit private institution, and projecting these numbers to 2026–2027, approximately 39 000 students are identified as ineligible for the full-time grant in the first year of implementation, increasing to 41 000 by the end of the projection period. The Government will also generate savings by lowering the amount of alternative payments for students in jurisdictions that do not participate in the Program and operate their own student financial assistance programs instead. The savings for the Government are estimated at $1,090.2 million in present value over the next 10 years.

Costs
Loss of grant funding to students who remain at for-profit private institutions

Students who choose to remain at for-profit private institutions will incur a cost by receiving less grant funding. There are approximately 39 000 students expected to lose eligibility for the full-time grant in the first year of implementation because they are expected to continue to study at for-profit institutions, increasing to 41 000 by the end of the projection period. The cost for students is estimated at $1,090.2 million in present value over the next 10 years.

Reduced profits to for-profit private institutions due to students switching to public institutions or not-for-profit private institutions

As discussed above, under the estimated higher earnings benefit, approximately 7 000 students per year are expected to switch their studies to a public institution or a not-for-profit private institution. This will lead to a loss in profits at for-profit private institutions. In the 2026–2027 academic year, the expected average tuition for a student attending a for-profit private institution is $13,000. The median industry profit margin for private institutions is 10.5%.footnote 14 For-profit private institutions are therefore expected to lose approximately $1,400 in profits per year (it is assumed that the average student is enrolled in a two-year program) for every student that switches to a public institution or not-for-profit private institution from a for-profit private institution.

The present value loss in profits for for-profit private institutions is expected to be $78.9 million over the next 10 years.

Administrative costs to for-profit private institutions to apply for exemptions

There are 92 programs across 50 institutions that will be eligible for exemption in the first year of implementation. Institutions are not required to apply for an exemption the first year. After the first year of implementation, these 50 institutions are expected to apply each year to exempt each eligible program of study to retain full-time grant eligibility for their students, with the number of institutions growing over time. Each institution would submit fewer than two applications on average, annually, although many will have only one qualifying program and some will have multiple. It is assumed that the time to fill in the application is about 36 minutes. Institutions are therefore expected to incur a cost due to the application process.

The present value of the administrative costs related to applying for an exemption to the full-time grant restriction is expected to be $29,812 over the next 10 years.

Cost to the Government of Canada from students not repaying loans

Students opting to remain at a for-profit institution are expected to receive more loans to offset their loss of grants. These students are the same as those impacted by the loss of grants, but only those that are not at the weekly loan limit can receive more loans. Approximately 2 500 students are expected to receive more loans in the first year of implementation, increasing to 2 800 by the end of the projection period. Like the loan costing for the portfolio loan limit measure, only defaults are considered as a monetized cost for the purposes of the cost-benefit analysis. As mentioned, the default cost to the government is assessed in the year loans are issued. It should be noted that this is a simplifying assumption, as defaults vary by student based on the year of graduation and financial circumstances. Applying this risk provision for 6% to the expected additional amount of loans to be disbursed (approximately $50.7 million) generates a total present value cost of $2.3 million over the next 10 years.

Processing costs for the Government of Canada to review exemption applications

The Government of Canada is expected to receive and assess exemption applications once a year, prepare exemption recommendations to the Minister, and communicate and consult with the provinces and territories. This is expected to require a total of 60.5 hours of work for a senior analyst. Additionally, it is assumed that the Minister will require 3 hours to review and approve exemptions. The present value of the processing costs for the Government of Canada to review exemption applications is expected to be $56,154 over the next 10 years.

Processing costs for participating provinces and territories for exemptions

Provinces and territories will be required to review the programs of study that have applied for exemption and verify that they are at designated institutions, that their students are eligible for the full-time grant, and that they are not aware of any reason why this program should not be approved for an exemption. They will then have to participate in a consultation process with the Program to discuss the proposed exemptions and confirm in writing that they do not object. The costing assumptions are that each of the 10 provinces/territory will require 10 hours per year for an executive director equivalent to complete this process. The present value of the processing costs for the provinces/territories to review exemption applications is expected to be $79,422 over the next 10 years.

Total package

The total monetized benefits for these regulatory amendments are estimated at $4,622.2 million (present value), while costs are estimated at $1,635.8 million (present value) over the next 10 years. This results in a net monetized benefit of $2,986.4 million (present value) over the next 10 years, for a benefit-to-cost ratio of 2.9:1.

Cost-benefit statement

PORTFOLIO LOAN LIMIT

Table 1: Monetized benefits (in millions of dollars)
Impacted stakeholder Description of benefit Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Students Higher future earnings for students who complete post-secondary education $0.7 $159.5 $486.3 $655.9 $2,995.0 $426.4
All
stakeholders		 Total benefit $0.7 $159.5 $486.3 $655.9 $2,995.0 $426.4
Table 2: Monetized costs (in millions of dollars)
Impacted stakeholder Description of cost Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Government of Canada Loan defaults due to additional disbursements under the portfolio measure $1.8 $141.6 $24.6 $29.0 $462.4 $65.8
Administrative costs to process increased financial assistance applications $0.0 table b2 note * $0.6 $0.1 $0.1 $1.8 $0.3
All
stakeholders		 Total cost $1.8 $142.1 $24.7 $29.1 $464.2 $66.1

Table b2 note(s)

Table b2 note *

Costs are greater than zero but less than $50,000.

Return to table b2 note * referrer
Table 3: Summary of monetized costs and benefits for portfolio loan limit (in millions of dollars)
Impacts Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Total benefits $0.7 $159.5 $486.3 $655.9 $2,995.0 $426.4
Total costs $1.8 $142.1 $24.7 $29.1 $464.2 $66.1
Net benefit -$1.1 $17.4 $461.7 $626.9 $2,530.8 $360.3

FULL-TIME GRANT ELIGIBILITY RESTRICTION

Table 4: Monetized benefits (in millions of dollars)
Impacted stakeholder Description of benefit Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Students Higher future earnings for students who switch to public institutions or not-for-profit private institutions $0.0 $5.7 $72.6 $170.2 $537.0 $76.5
Government of Canada Savings from disbursing less grants $139.3 $145.3 $145.2 $147.8 $1,090.2 $155.2
All stakeholders Total benefit $139.3 $151.0 $217.8 $318.0 $1,627.1 $231.7
Table 5: Monetized costs (in millions of dollars)
Impacted stakeholder Description of cost Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Students Loss of grant funding to students who remain at for-profit private institutions $139.3 $145.3 $145.2 $147.8 $1,090.2 $155.2
For-profit private institution Reduced profits due to students switching to public institutions or not-for-profit private institutions $9.4 $10.1 $10.5 $11.5 $78.9 $11.2
Administrative costs to apply for exemptions $0.0 $0.0 table b5 note * $0.0 table b5 note * $0.0 table b5 note * $0.0 table b5 note * $0.0 table b5 note *
Government of Canada Loan defaults due to additional disbursements under the full-time grant restriction measure $0.3 $0.3 $0.3 $0.3 $2.3 $0.3
Processing costs to review exemption applications $0.0 $0.0 table b5 note * $0.0 table b5 note * $0.0 table b5 note * $0.1 $0.0 table b5 note *
Participating provincial and territorial jurisdictions Processing costs for the participating provinces and territories for exemptions $0.0 $0.0 table b5 note * $0.0 table b5 note * $0.0 table b5 note * $0.1 $0.0 table b5 note *
All stakeholders Total cost $149.0 $155.7 $156.1 $159.7 $1,171.6 $166.8

Table b5 note(s)

Table b5 note *

Costs are greater than zero but less than $50,000.

Return to table b5 note * referrer
Table 6: Summary of monetized costs and benefits from full-time grant eligibility restriction (in millions of dollars)
Impacts Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Total
benefits		 $139.3 $151.0 $217.8 $318.0 $1,627.1 $231.7
Total costs $149.0 $155.7 $156.1 $159.7 $1,171.6 $166.8
Net benefit -$9.7 -$4.7 $61.7 $158.3 $455.6 $64.9

TOTAL IMPACT OF AMENDMENTS

Table 7: Monetized benefits (in millions of dollars)
Impacted stakeholder Description of benefit Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Students Higher future earnings for students who complete post-secondary education $0.7 $159.5 $486.3 $655.9 $2,995.0 $426.4
Higher future earnings for students who switch to studying in public institutions or not-for-profit private institutions $0.0 $5.7 $72.6 $170.2 $537.0 $76.5
Government of Canada Savings to Government from disbursing less grants $139.3 $145.3 $145.2 $147.8 $1,090.2 $155.2
All stakeholders Total benefit $140.0 $310.5 $704.2 $974.0 $4,622.2 $658.1
Table 8: Monetized costs (in millions of dollars)
Impacted stakeholder Description of cost Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Students Loss of grant funding to students who remain at for-profit private institutions $139.3 $145.3 $145.2 $147.8 $1,090.2 $155.2
For-profit private institution Reduced profits to for-profit private institutions due to students switching to public institutions or not-for-profit private institutions $9.4 $10.1 $10.5 $11.5 $78.9 $11.2
Administrative costs to for-profit private institutions to apply for exemptions $0.0 $0.0 table b8 note * $0.0 table b8 note * $0.0 table b8 note * $0.0 table b8 note * $0.0 table b8 note *
Government of Canada Loan defaults due to additional disbursements under the portfolio measure $1.8 $141.6 $24.6 $29.0 $462.4 $65.8
Loan defaults due to additional disbursements under the full-time grant restriction measure $0.3 $0.3 $0.3 $0.3 $2.3 $0.3
Administrative costs for the Government of Canada to process increased financial assistance applications $0.0 table b8 note * $0.6 $0.1 $0.1 $1.8 $0.3
Processing costs for the Government of Canada to review exemption applications $0.0 $0.0 table b8 note * $0.0 table b8 note * $0.0 table b8 note * $0.1 $0.0 table b8 note *
Participating provincial and territorial jurisdictions Processing costs for the participating provinces and territories for exemptions $0.0 $0.0 table b8 note * $0.0 table b8 note * $0.0 table b8 note * $0.1 $0.0 table b8 note *
All stakeholders Total cost $150.8 $297.8 $180.7 $188.8 $1,635.8 $232.9

Table b8 note(s)

Table b8 note *

Costs are greater than zero but less than $50,000.

Return to table b8 note * referrer
Table 9: Summary of total monetized costs and benefits (in millions of dollars)
Impacts Base year: 2026–2027 Second year: 2027–2028 Fifth year: 2030–2031 Final year: 2035–2036 Total present value Annualized value
Total benefits $140.0 $310.5 $704.2 $974.0 $4,622.2 $658.1
Total costs $150.8 $297.8 $180.7 $188.8 $1,635.8 $232.9
Net benefit -$10.8 $12.7 $523.4 $785.2 $2,986.4 $425.2
Quantified (non-monetized) and qualitative impacts

Portfolio Loan Limit Increase

Positive impacts

Benefits to students

Increased employment opportunities for those who complete post-secondary education due to continued funding

Research indicates that enabling Canadians to afford entering or completing post-secondary education leads to lower unemployment rates and shorter unemployment periods.footnote 15 It is expected that students who graduate due to the regulatory amendment to increase the portfolio loan limit will have increased employment opportunities compared to those without post-secondary education during current and future periods of economic vulnerability.

Enhanced health and longevity

The regulatory amendment to increase the portfolio loan limit is expected to enable more students to access and complete post-secondary education, and literature has consistently associated higher levels of educational attainment with enhanced health outcomes.footnote 16,footnote 17 The connection between education and health is multi-factorial. For example, higher levels of education create greater awareness of health risks, enable access to resources that promote healthier lifestyles, and facilitate access to careers with safer working conditions. footnote 17

Intergenerational effects of parental education on children

The regulatory amendment to increase the portfolio loan limit is not only expected to have positive impacts on direct beneficiaries, but also on children of those who are newly able to obtain post-secondary education. footnote 18 Studies have found that higher educational attainment creates indirect positive benefits for future generations. For example, children of post-secondary education graduates are more likely to attend post-secondary education institutions themselves. footnote 19

Benefits to Canadian society and businesses

Increased availability of skilled workers

Increasing the portfolio loan limit is expected to contribute to the availability of workers with post-secondary education by continuing to support students at risk of dropping out for financial reasons to complete their studies. According to 2025 Employment and Social Development Canada estimates from the Canadian Occupational Projection System, 75% of new jobs created by economic expansion are projected to be in occupations generally requiring post-secondary education, or in management occupations.footnote 20 Occupations requiring a university degree, or a college or apprenticeship diploma are expected to experience a labour shortage between 2024 and 2033.footnote 20

Reduced income inequality

Increasing the portfolio loan limit is expected to contribute to the reduction of income inequality, as low- and middle-income Canadians are the main beneficiaries of the Program. Investments in financial assistance support post-secondary education completion, resulting in graduates paying higher income taxes due to Canada’s progressive tax system, which eventually increases social mobility.footnote 21 Additionally, increases in educational attainment will help offset recently increasing income inequality driven by technological advancements and automation in Canada.footnote 21

Greater productivity to businesses and society due to more people gaining PSE credentials

Skilled workers are not only more productive, they also increase business production through human capital spillovers by enhancing the productivity of less educated colleagues who learn from them. Additionally, evidence suggests that people with higher education are more likely to engage in entrepreneurship and contribute innovative ideas in the workplace, which has a direct positive effect on economic welfare by contributing to science and technological development in Canada.footnote 22

Full-time grant eligibility restriction
Positive impacts

Benefits to public institutions and not-for-profit private institutions

Increased number of students attending public institutions or not-for-profit private institutions

The regulatory amendments to limit full-time grant eligibility are expected to increase the number of students at public institutions and not-for-profit private institutions. It is expected that approximately 7 000 students will choose a public institution or not-for-profit private institution to remain eligible for the full-time grant.

Negative impacts

The regulatory amendments to restrict full-time grant eligibility will have the following negative impacts.

Increased stress and uncertainty for students to shift to public institutions or not-for-profit private institutions

These regulatory amendments are expected to result in some students not being able to study at for-profit private institutions, which may have been their first choice. Students may need to change plans, identify new programs and apply to new institutions. This may be stressful and create uncertainty.

Increased strain on students attending an exempted program of study that does not receive an exemption the following year

Exemptions from the full-time grant eligibility restriction will be granted on an annual basis, leading to funding uncertainty for students. Students may be negatively impacted because they may not be able to afford their chosen program of study without the full-time grant after investing a year or more in that program. Therefore, they may have to switch midway through their program to public institutions or not-for-profit private institutions. These changes and uncertainty may be stressful for some students.

Decreased student enrollment for for-profit private institutions whose students will no longer receive the full-time grant

These regulatory amendments are expected to result in some for-profit private institutions experiencing decreased student enrollment, which may lead to program closures.

Small business lens

The Policy on Limiting Regulatory Burden on Businessesfootnote 23 defines a small business as any business, including its affiliates, that has fewer than 100 employees or less than $5 million in annual gross revenue. It is estimated that approximately 50 businesses will incur administrative burden as a result of these Regulations. These include for-profit private institutions that are eligible for student financial assistance, offer programs that meet the full-time grant eligibility criteria of being at least two years in length, and have programs that lead to occupations known to be in high labour market demand and are professionally regulated that may apply for an exemption. There is very little publicly available information about the employee count or gross revenue of these businesses, but Canadian Industry Statisticsfootnote 24 for Educational Services (NAICS code 61) classifies 93% of employers as small businesses, Technical and Trade Schools (NAICS code 6115) classifies 96% as small businesses, and Business Schools and Computer and Management Training (NAICS code 6114) classifies 99% as small businesses. Given the high proportion of small employers in this sector and the lack of information about the impacted businesses, all 50 businesses expected to incur a regulatory burden have been considered small businesses.

For-profit private institutions will have the ability to apply to have a program of study exempt from the restriction of the full-time grant if it meets at least two of the exemption conditions. There are 92 programs across 50 institutions currently eligible for exemption. These 50 institutions, growing to 63 institutions by the end of the analysis, are expected to apply for exemptions annually (except for the first year) so that eligible programs retain full-time grant eligibility for their students. Small businesses are therefore expected to incur a cost due to the application process.

Small business lens summary
Table 10: Costs
Administrative or compliance Description of cost Present value Annualized value
Administrative Complete exemption application forms. $29,812 $4,245
Total Total costs $29,812 $4,245
Average net impact on each impacted small business -$533 -$76

One-for-one rule

The one-for-one rule applies, since there is an incremental increase in administrative burden on some for-profit private institutions. The measure is considered burden “in” under the rule, and no regulatory titles are repealed or introduced. The amendments will result in an annualized administrative total cost of $658.

As per the Red Tape Reduction Regulations, the assessment of administrative impacts was conducted for a period of 10 years, commencing from registration. All values listed in this section are presented in 2012 dollars, discounted to 2012 at a rate of 7%.

The amendments related to applying for an exemption represent an annualized total cost of $658. At the beginning of the 10-year period, the number of affected institutions is around 50, increasing to around 63 businesses as time progresses. It is estimated that each business will spend 36 minutes per application for an exemption once per academic year. The information required should be readily available to the applicant, as it would include basic information on the institution and program (e.g. institution and program name, contact information, credentials offered, most common occupations associated with the program of study and regulatory status of occupation). The average wage, including overhead, of the employee tasked with applying is estimated to be $31.04.

Regulatory cooperation and alignment

These regulatory amendments are not related to any commitment under a formal regulatory cooperation forum. The Intergovernmental Committee is a federal/provincial-territorial body for financial assistance in Canada, but this committee does not focus on regulatory cooperation.

Effects on the environment

In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA), a preliminary scan concluded that a strategic environmental and economic assessment is not required.

Gender-based analysis plus

The regulatory amendment to increase the portfolio loan limit is expected to benefit certain groups, including low- and middle-income individuals, women, persons with disabilities, students with dependants, and students who self-identified as Indigenous pursuing post-secondary education. The restriction on the full-time grant for students at for-profit private institutions is also expected to have negative impacts on some groups, including low-income students and women.

The Program targets low- and middle-income students, and therefore the regulatory amendment to increase the portfolio loan limit is expected to significantly benefit students from the low-and middle-income categories. According to 2023–2024 Program data, low- and middle-income students made up 88% of loan recipients. Research indicates that students from lower income families are less likely to pursue post-secondary education than their peers from high-income families. The continued provision of interest-free loans, resulting from an increase to the portfolio loan limit, will encourage their post-secondary education enrollment and persistence.footnote 25,footnote 26

According to the 2023–2024 Program data, 58% of loan recipients were women, suggesting that the portfolio loan limit measure is likely to benefit more women than men. Loan recipients who are parents are also expected to benefit. The 2023–2024 data shows that most students with dependants who received loans had a low income (78%). As per the 2023–2024 Program data, although only 11% of financial assistance beneficiaries had a disability and only approximately 5% self-identified as Indigenous, 77% and 87% of them, respectively, received loans.

According to the 2023–2024 Program data, 61% of financial assistance beneficiaries were under the age of 25 and 90% of them received loans. Although borrowers over 25 years old constituted only 39% of beneficiaries, 88% of them received loans, suggesting that all Program beneficiaries, regardless of age, will benefit from the increase in the portfolio loan limit from $34 to $40 billion.

The restriction on the full-time grant for students at for-profit private institutions is expected to have a negative impact on some students. Based on 2023–2024 Program data, those individuals attending for-profit private institutions who are currently eligible for the full-time grant and who will no longer be eligible as a result of the restriction are more likely to be low-income individuals (81%), women (57%) and have a dependent child (46%), meaning a child under 12 years of age or a child over 12 years of age with a disability. Furthermore, according to 2023–2024 Program data, a majority of students (92%) who attended private institutions and received the full-time grant were students from Alberta (44%) and Ontario (39%), followed by British Columbia (9%). The programs attended by students at for-profit private institutions are concentrated in the following sectors: health; applied sciences; business, finance and administration; and arts, culture, recreation and sports. Based on an internal analysis of programs of study at for-profit private institutions, the top five programs of study that could be impacted by the restriction of the full-time grant are massage therapy/therapeutic massage; computer and information systems; security, auditing, information assurance; web page, digital/multimedia and information resources design; business administration and management; and game and interactive media design.

Implementation, compliance and enforcement, and service standards

Implementation

The regulatory amendments will come into force on August 1, 2026.

Exemptions for the 2026–2027 academic year

For the 2026–2027 academic year, all participating provinces/territories, except for British Columbia and Manitoba, will implement exemptions at the institution level, due to operational requirements preventing program-level implementation. As a result, full-time students studying in any program of study at a for-profit private institution offering a program of study of at least two years in duration that leads to a degree, certificate or diploma not beyond the undergraduate level and is intended to lead to an occupation from the list below, will be eligible for the full-time grant:

For the 2026–2027 academic year, British Columbia and Manitoba will implement exemptions at the program level, as the policy intends. As a result, full-time students who receive financial assistance from British Columbia or Manitoba and who are studying in a program of study at a for-profit private institution intended to lead to an occupation from the list below, will be eligible for the full-time grant:

These exemptions will be in place only for the 2026–2027 academic year, following which, the full-time grant will be limited to students attending public institutions and not-for-profit private institutions. For-profit private institutions and/or their associated province/territory will have to apply to have a program of study considered for exemption.

Process for determining exemptions for the 2027–2028 academic year and ongoing

For a program of study at a for-profit private institution to be considered for exemption from the full-time grant restriction, the for-profit private institution or a province/territory must apply to the Minister of Employment and Social Development by October 15 for an exemption for the following academic year. The application will need to identify a specific program of study at a specific for-profit private institution to be reviewed for exemption by the Minister. Following receipt of an application, the Minister will assess whether the program of study meets at least two of the established conditions in the Regulations. If the Minister’s assessment finds that a requested program of study meets at least two of the conditions, the Minister will then grant an exemption for that program of study and students studying in that program of studies at that specific for-profit private institution will be exempt from the full-time grant restriction.

The exemption of a program of study at a specific for-profit private institution will be limited to a specific program of study at a specific for-profit private institution. Programs of study exemptions will be determined on a case-by-case basis.

Exemptions will be in place for one academic year (i.e. in effect from August 1 through July 31). For-profit private institutions and/or provinces/territories will have to reapply by October 15 of each academic year to allow exemption decisions to be implemented in time for the following academic year and to reflect changing labour market needs and integrity concerns.

There will be no appeals for exemption decisions.

Assessment of grant eligibility

Students are expected to follow the regular financial assistance application process through their province or territory of residence. Students may be eligible for more than one type of grant. When they apply with their province or territory, their eligibility for grants will be assessed.

While the regulatory amendments will limit the full-time grant to students attending public institutions and not-for-profit private institutions, students at for-profit private institutions will continue to have access to the following Program supports should they be eligible:

Compliance and enforcement

The Act requires that an actuarial report about the Program be tabled in Parliament at least every three years. This report provides an estimate of Program costs and revenues, a 25-year forecast of future Program costs and revenues, and an explanation of the methodology and actuarial and economic assumptions used to produce the figures presented in the report. The Act also requires an annual report on the Program to be tabled in Parliament. The annual report provides detailed Program statistics (including the value of the portfolio) and outlines key objectives, initiatives, and accomplishments achieved over a given academic year, and integrity policies.footnote 27

The Act provides authority for the Program to ensure that federal grants and loans are not provided to ineligible students. Subsection 17(1) of this act provides for a fine of up to $1,000 for students who knowingly provide false or misleading information, including by omission, in an application or other document. Also, subsection 17.1(1) of the Act allows for any such student to be denied additional federal financial assistance as well as certain other Program benefits, such as repayment assistance.

Contact

Erin Hetherington
Director
Program Policy
Canada Student Financial Assistance Program
Employment and Social Development Canada
Email: EDSC.DGA.PCAFE.MCPP-SEC.CSFAP.LB.ESDC@hrsdc-rhdcc.gc.ca