Standards for Work-Integrated Learning

Summary#

The final regulation, Standards for Work-Integrated Learning Activities Regulations, sets the rules for when a student placement (an internship that is part of a course or program) can be unpaid in federally regulated workplaces. It requires documentation from the school, gives students a limited set of labour‑standards protections, and requires employers to keep records for 36 months. The regulation was registered on June 26, 2020 and came into force with the related legislative changes on September 1, 2020.

What it does#

• Defines which schools count for unpaid placements:

  • post‑secondary and vocational schools listed in the Directory of Educational Institutions in Canada,
  • secondary schools that meet provincial rules,
  • federal‑administered post‑secondary schools,
  • some schools outside Canada if they meet the local law where they are located.

• Requires a student to give the employer documents from the school that say:

  • the student’s name and program,
  • the school’s name and address,
  • the employer’s name and address,
  • a description of the activities that meet program requirements,
  • start date and either an end date or total hours,
  • the contact name and details of a program administrator.

• Makes employers keep a written file (including the school documents, hours worked, dates, any leaves and related certificates) for 36 months after the placement ends.

• Applies and adapts parts of the Canada Labour Code so students in approved unpaid placements get a selected set of labour protections, including (as adapted by the regulation):

  • limits on hours (generally 8 hours/day and 40 hours/week, with some adapted rules allowing up to 10 hours/day or 48 hours/week in limited situations),
  • breaks (a break for every period of 5 hours of work and unpaid breaks for medical reasons or nursing),
  • advance notice rules (a 96‑hour schedule notice and 24‑hour notice for shift changes or additions),
  • an 8‑hour rest period between shifts,
  • entitlement to general holidays (the regulation’s text adapts how holiday pay is treated),
  • a range of protected leaves (short leaves for bereavement, medical reasons, victims of family violence, traditional Indigenous practices, and work‑related illness or injury),
  • protections against reprisals, genetic discrimination, and sexual harassment (until harassment rules are fully consolidated under other changes).

Who's affected#

• Students doing work‑integrated learning placements that are part of a high‑school, post‑secondary or vocational program, including some programs based outside Canada, when the placement is with a federally regulated employer.
• Employers in federally regulated sectors (for example: banks, telecommunications and broadcasting companies, interprovincial and international transportation, grain handling, certain mines and federal Crown corporations) who host such students.
• Educational institutions that must issue the required documents confirming that a placement meets program requirements.
• The federal Labour Program and labour inspectors, who will enforce these rules.

If it’s not clear from the paperwork that a placement is part of an educational program, the student is treated like any other worker and must be paid at least the minimum wage.

Why it matters#

• It limits unpaid internships: only placements that are formally part of an educational program and supported by school documents can be unpaid. Other interns must be paid and get full labour protections.
• It gives students in unpaid placements clearer rights on hours, breaks, short leaves and protections against harassment, reprisals and discrimination. This reduces confusion about what unpaid interns are entitled to.
• Employers must collect and keep documentation and records. The government estimated modest one‑time and ongoing administrative costs: a total present‑value cost of $471,100 (about $433,200 for employers and $37,900 for educational institutions). For affected small federally regulated businesses, the average impact was estimated at about $141 per business.
• The rules aim to make unpaid placements more accountable and educational, and to reduce exploitative unpaid work. The federal government also announced broader funding to support paid placements (Budget 2019 commitment of $631.2 million over five years), which the regulation complements.