If you want to know how messed up the visa processing system is about to get in the next couple of months…well, buckle up.

Y’all may remember that when Minister Marc Miller announced caps on student visas, he indicated that each province would be responsible for allocating visas among its own institutions. All provinces will be required to provide students with a letter or certificate attached to their applications, indicating the institution that the student is to attend. This already occurs in Quebec; in effect, what the Minister was saying that all provinces would need to adopt the Quebec system.

In practice, here’s what that means:

	Old System	Quebec (i.e. New) System
Step 1	Student applies to as many institutions as they want	Student applies to as many institutions as they want
Step 2	Institutions issue acceptances	Institutions issue acceptances
Step 3	Students choose the institution they want to attend	Students choose the institution they want to attend
Step 4	Students apply for Canada student visa using the letter of acceptance from their chosen institution	Students apply for provincial attestation using the letter of acceptance from their chosen institution
Step 5	IRCC processes application	Province processes application
Step 6	Student gets visa	Student gets letter of attestation
Step 7	Student comes to Canada for study	Students apply for Canada student visa using the letter of acceptance from their chosen institution and their provincial letter of attestation
Step 8		IRCC processes application
Step 9		Student gets visa
Step 10		Student comes to Canada for study

Got that? What the feds are actually asking for is for each province to set up their own application/approval system, and to make students to go through three separate processes (institutional, provincial, federal) instead of just two (institutional, federal) in order to make it to Canada.

Now, switching from one process to another isn’t impossible. Quebec does this already, so we know it is perfectly do-able. That’s not really the issue. The issue is that the federal government is pausing all application processing (step 5 in the old system, step 8 in the new) until each province adopts the new system. The question, therefore, is how quickly provinces can put in place something to receive and process applications, and issue letters of attestation (steps 4, 5, and 6).

There’s a technical dimension to this problem: someone has to build the web portal for each province to accept applications. My understanding is that ApplyBoard has stepped forward to build this this for provinces, effectively free of charge for the first two years, and is promising to complete the system within a month. In am emergency, it’s a great offer (though it’s not 100% clear to me that all provinces’ procurement rules will allow for this). But the problem is that the technical issue is only part of the problem.

From a policy perspective, each province has to create policies around the question “which attestations do we approve?” Right now, provinces are floating all kinds of stuff about this: both BC and Ontario, for instance, are talking about linking approvals to local labour market needs. Again, not impossible in theory to design this kind of thing; but working out how to target such measures is complicated, not easily done when the clock is ticking, and every moment of delay is collectively costing institutions millions of dollars. And then once you have determined your policy, you have to design a set of rules and a process that public servants can actually follow in order to say “yea” or “nay.”

But it’s not just a matter of technology and policy. It is also, to a very substantial degree, one of communications. Again, over the long term, communication is not a big deal: it’s not substantially more difficult to explain a ten-step process than a seven-step process. But in the short term, with tens of thousands of visas caught frozen in the middle of processing, what happens to all the visas which are currently caught in the net? How do you get in touch with everyone who is in the middle of a seven-step process that they are soon to be in a ten-step process that they have to re-start half-way through when 1) you don’t know whether said student has actually chosen your institution for the purpose of visa approval and 2) there is as of now no clear date when they can re-start the process?

Even if you get all these three things right, there is still another major issue to be dealt with. The feds are allocating approvals: that is, they are saying they will only process a certain number of visas for each province. But institutions in practice are going to be allocated acceptances: that is, they can only say “yes” to a given number of students. But of course, yield rates are a thing: many students get multiple acceptances and they will need to choose one in order to get their letter of attestation. So who is going to tell institutions that have declined acceptances that they can actually accept more students because their spots are going unused. Again, privacy regulations are going to play a role here.

(Also, all of the above assumes the student only applies to institutions in the same province….what if a student applies to both McGill and UBC? The student would then apply for attestation letters in two provinces. Who will be responsible for telling the province and institution which the student chooses not to attend that they have an extra acceptance that they can use on someone else? In theory the feds could do so, but as I understand there is no actual protocol for doing so at the moment. “We’re working closely with the provinces” is the unconvincing mantra you get when talking to the feds about this.)

Anyways, you get the idea: what the feds are asking of the provinces is not impossible or irrational given a long enough timeline. But for this year, the admissions pause and the addition of new entrance criteria are likely to cause enormous disruptions. It’s not obvious that provinces can put together new processes in an expedited manner, and it’s equally unobvious that applicants who are caught in the moratorium and will be required to re-start their applications will be willing to follow new guidance. The upshot? Tens of thousands of applicants will simply melt away.

To be clear: none of this is to say that what the feds are asking of provinces is wrong. It is, however, to say that the feds are asking provinces to re-build an airplane while it is in flight. And that the main casualty here will be hundreds of millions—if not billions—of international student tuition dollars that are going to go up in smoke.