Executive Summary

I am an international Master of Engineering student in Technology Innovation Management at Carleton University. Outside the classroom, I build AI tools such as Real Speaking, JoeSlides, an IELTS Speaking Simulator and a Literature Screening Assistant, and I share practical AI knowledge with communities in Ottawa.

I support the goal of aligning immigration with labour market needs and maintaining program integrity. However, under the “Proposed amendments to regulations under the Ontario Immigration Act, 2015 to redesign the Ontario Immigrant Nominee Program's (OINP) Streams (Proposal 25-MLITSD019)”, eliminating graduate streams without a realistic replacement and without transitional protection will weaken Ontario's competitiveness in the AI era, increase vulnerability for recent graduates and damage trust in Ontario as a destination for international students.

Key recommendations:

1. Preserve a clear, independent pathway for Ontario master's and PhD graduates that does not depend entirely on a single employer.
2. If the streams must be eliminated, provide robust transitional protection for students who enrolled under the current framework.
3. Design the Entrepreneur and Exceptional Talent streams to include early-stage builders, not only established figures.
4. Commit to transparent outcome tracking with a formal review within 2 to 3 years.

1. Graduate streams are a strategic asset in the AI era

Artificial intelligence is changing work in every sector. Ontario needs people who can turn AI and data tools into real improvements in businesses, public services and everyday workflows, not only people who work in big labs.

Ontario master’s and PhD graduates in AI, data, engineering and related fields are already doing this. Many of us work with small and medium-sized enterprises, helping them adopt AI responsibly, improve processes and raise productivity. A flexible, non-employer pathway like the Masters Graduate Stream lets us stay in Ontario and focus on building and teaching, instead of spending all our energy finding and keeping a single sponsoring employer.

Because AI-focused graduates are highly mobile, predictable and fair pathways matter. If Ontario closes its graduate streams while other places keep or strengthen theirs, many of us will simply take our skills elsewhere.

2. How different stakeholders are affected

• Province and taxpayers: Retaining Ontario-trained master’s and PhD graduates is a low-risk, high-return way to support innovation, productivity and long-term tax revenue. Closing graduate pathways now could reduce that future capacity.
• Employers (SMEs): Many smaller employers rely on short projects and part-time roles. A graduate pathway that is not tied to one employer lets graduates work with several firms and share skills more widely.
• Universities and Ontario’s reputation: Graduate streams were part of why many of us chose Ontario. Removing them without a fair transition risks damaging Ontario’s reputation as a predictable and trustworthy place to study and build a life.
• International graduates and worker protection: If immigration status depends almost entirely on one employer, graduates are less likely to leave bad jobs or negotiate fairly. An independent graduate pathway reduces this vulnerability and supports the Ministry’s worker protection goals.

3. Specific concerns with Proposal 25-MLITSD019

3.1 Consolidation into employer-driven pathways

As described, Proposal 25-MLITSD019 would consolidate the current eight OINP streams into a redesigned Employer Job Offer (EJO) stream. For non-healthcare, non-entrepreneur graduate talent, this leaves employer job offer pathways as the primary route to nomination.

This structure assumes that the best or only way for international graduates to contribute is to fit quickly into a single stable full-time job. It does not reflect the reality of how many master's and PhD graduates actually create value in early stages: through contract work, startup projects, research collaborations and community teaching that does not always map neatly onto a single employer-driven job offer.

It also increases vulnerability. When immigration options depend almost entirely on one employer, graduates become less willing to change jobs, negotiate fairly or report workplace problems. That is directly at odds with the worker protection goals behind recent OINP reforms.

3.2 Low-wage provisions for recent graduates

In the proposed Employer Job Offer TEER 0 to 3 track, recent Ontario graduates within two years may qualify with a low-wage offer. Allowing lower wages for recent Ontario graduates sends a troubling signal about the value of graduate education. It also creates clear risks:

• It encourages underemployment (brain waste) of master's and PhD graduates in roles that do not use their skills.
• It creates incentives for employers to structure low-wage positions primarily as an immigration ticket rather than as a genuine investment in talent.
• Combined with employer-dependent status, it increases the risk that graduates will feel compelled to stay in poorly paid or unsuitable roles just to preserve a pathway to nomination.

3.3 New streams do not realistically replace graduate pathways

The three proposed strategic streams are all important, but they do not provide a realistic replacement for the Masters Graduate Stream for most non-regulated graduates:

• The Priority Healthcare Stream is rightly focused on regulated health professionals.
• The Entrepreneur Stream targets individuals who already operate a business. This excludes many early-stage founders who are still validating ideas, building prototypes or working through incubators.
• The Exceptional Talent Stream targets people with major awards or patents. These criteria do not capture the early-stage builders who are running workshops, sharing practical AI knowledge with local businesses and contributing to the ecosystem before they are famous.

In practice, this means that many master's and PhD graduates in fields like AI and technology innovation would lose the only clear non-employer based pathway that recognizes their education and local contribution.

4. Misalignment with federal direction and national policy proposals

Federal policy is moving in the opposite direction. Starting January 1, 2026, master's and doctoral students at public designated learning institutions will be exempt from the national study permit cap. This exemption exists precisely because graduate students are seen as a priority group for Canada's economic growth and innovation.

At the same time, national policy discussions, such as the "Recognize Commitment to Canada in Immigration" proposal by Shopify CEO Tobi Lütke from Build Canada, argue that immigrants should be rewarded for ongoing contributions, including Canadian education.

Proposal 25-MLITSD019 cuts against both of these trends. It would remove the main provincial pathway for exactly the group that the federal government and business leaders say Canada should prioritize.

5. Breach of trust with current students and need for transitional protection

Many current students decided to study in Ontario one or two years ago with the reasonable expectation that the OINP Masters Graduate Stream would remain in place at graduation. Removing or fundamentally redesigning these streams without strong transitional measures changes the rules midway through our programs.

To protect trust and avoid unfairness, any major changes to graduate pathways should include clear and generous transitional protection, for example:

• Grandfathering master's and PhD students who started their programs before a specified date, so that they remain eligible for the existing graduate streams.
• Applying new restrictions only to students who begin their studies after a future intake, once the new rules are clearly communicated.

This is not simply a request for special treatment. It is a request that Ontario honour the expectations that were reasonably created when students committed to multi-year degrees in this province.

6. Designing Entrepreneur and Exceptional Talent streams for early-stage builders

If Ontario proceeds with the proposed Entrepreneur and Exceptional Talent streams, I urge the Ministry to design them in a way that recognizes early-stage builders.

For the Entrepreneur Stream, criteria could explicitly recognize:

• Early-stage founders who are participating in recognized incubators or accelerators.
• Evidence of real traction, such as pilots with Ontario businesses or early revenue, even at a small scale.

For the Exceptional Talent Stream, criteria should allow room for:

• Graduates who are leading meaningful projects in AI and technology, even if they do not yet have major awards.
• People who have demonstrated exceptional impact at the local or provincial level, for example by helping Ontario firms adopt AI responsibly.

7. My background and contribution

I am enrolled in a Master of Engineering in Technology Innovation Management program in Ontario. Since arriving in Ottawa in 2024, I have:

• Built practical AI tools including Real Speaking (an English speaking coach for real-world fluency), IELST Speaking Simulator (a real-time AI conversation for an English standardized test), JoeSlides (an AI-powered presentation assistant) and a Literature Screening Assistant for researchers.
• Delivered talks at Carleton University and local tech meetups on AI adoption and product management.
• Worked with small businesses to help them understand and implement AI tools in their daily workflows.
• Shared knowledge openly through my website (hubeiqiao.com) and community engagement.

This work happens across multiple organizations: startups, university labs, small businesses, community groups. It does not fit neatly into a single employer relationship.

The current Masters Graduate Stream is important for people like me because it provides enough stability to focus on building: exploring startup ideas, working with multiple clients and teaching others how to use AI, instead of immediately tying my status to a single employer and a single job description.

Conclusion and key requests

Ontario's master's and PhD graduates are a group that has already been screened for education, language and adaptability. We have invested significant time and money in this province and are often working in fields, like AI and technology, that are central to Ontario's future prosperity.

I respectfully ask that the government:

1. Preserve a clear, independent pathway to permanent residence for Ontario master's and PhD graduates, whether through maintaining a graduate stream or by ensuring that at least one of the new streams is genuinely accessible to non-regulated graduate talent.
2. If the government proceeds with eliminating the existing graduate streams, provide robust transitional protection (grandfathering) for current master’s and PhD students who began their programs under the existing OINP graduate framework.
3. Publish a detailed impact analysis and commit to transparent review of the new system within 2 to 3 years.

Ontario has an opportunity to align its immigration program with both federal priorities and its own economic goals in the AI era. I urge you to adjust Proposal 25-MLITSD019 so that it retains and supports the graduate talent that is already here and already working to build Ontario's future.

Thank you for considering these comments.