Student Loan Definitions and Disability Options

Summary#

This is a proposed change to the Canada Student Loans Regulations published on December 18, 2021. It would change how “full‑time” and “part‑time” students are defined and add new disability-related definitions and options. Interested people had 60 days from publication to comment.

What it does#

• Replaces the definitions of full‑time student, part‑time student and permanent disability with clearer, activity‑based wording.
  • A full‑time student would be someone enrolled in courses that are at least 60% of a full course load, whose main activity is their studies, and who meets other program requirements.
  • A part‑time student would be someone enrolled in at least 20% but less than 60% of a full course load.
• Adds a new definition, persistent or prolonged disability, for impairments that have lasted or are expected to last at least 12 months.
• Lets a person with a permanent disability or a persistent or prolonged disability who is enrolled in at least 40% but less than 60% of a full course load elect to be treated as a full‑time student.
• Replaces the definition of severe permanent disability to align it with the Canada Pension Plan concept of “substantially gainful” work and to require that the disability be expected to last for the person’s life.
• States the changes would come into force on August 1, 2022 (if adopted).

Note: the text in the Gazette is a proposal, not final law.

Who's affected#

• Students applying for or receiving federal student loans under the Canada Student Loans Regulations, especially those with disabilities.
• Post‑secondary institutions that determine and report what counts as a full course load.
• People who seek loan relief or different treatment because of a disability (for example, those asserting a severe permanent disability).

It is not fully clear from the notice how provincial or territorial student‑loan administrators (who often deliver the loans) will apply the changes.

Why it matters#

• Students with disabilities who take lighter course loads (between 40% and 60%) could choose to be treated as full‑time. That can affect their access to loan amounts, program rules, and supports tied to full‑time status.
• Changing the definition of severe disability to match the Canada Pension Plan may change who qualifies for disability‑related loan relief.
• The proposed effective date (August 1, 2022) gives students and schools time to prepare, but the change only happens if the proposal is finalized.