Canadian Exceptionalism? An International Immigration Comparison

Ever since President Trump announced during his State of the Union speech this year that the U.S. should move to a “merit-based” immigration system, “like Canada”, there has been a resurgence of global debate over the best immigration system. This was not the first time Trump has looked to the Canadian example; he reportedly brought up merit-based immigration in a meeting with Prime Minister Justin Trudeau in early February. But does a merit-based system really “save countless dollars, raise workers’ wages and help struggling families” as Trump claims it does? And would adopting a Canadian style system really mean “switching away from this current system of lower-skilled immigration” as Trump further claims? In the 1960s, Canada became the first country to adopt a merit-based immigration system, but it has been far from the last. The system became increasingly popular in the 2000s, adopted by, among others, the United Kingdom. So what does Canada’s system really look like, how does it compare internationally, and is it really a viable option for the U.S.?

Canadian Exceptionalism?

Canada’s immigration system, like most merit-based systems, prioritises applicants with potential to contribute to the national economy over those with family ties. Of those granted legal permanent residency in Canada, 63% are admitted for economic reasons and 24% on the basis of having family members in the country. This is reversed in the U.S., where  63% of green cards are given to immigrants with family connections, while only 13% are given for economic reasons. Applicants in Canada are graded on a 100-point scale, with those scoring a 67 or higher deemed eligible to immigrate. Categories include a 28 point maximum for language skills (English and French), 25 points maximum for education, 15 for work experience, 12 points for age (younger is better), 10 points maximum for a job offer from a Canadian employer, and a maximum of 10 points for “adaptability” which covers a variety of criteria including having visited before or having family ties. If an applicant has a Canadian citizen in their immediate family, they do not have to go through the grading system.

This type of points system is now used in several countries, including the U.K., Australia, and New Zealand. Yet Canada’s system is unique for a few other reasons not cited by President Trump. First, it is worth noting that Canada welcomes about 300,000 permanent residents annually, the equivalent of about 1% of its population of 36 million, one of the highest per capita ratios of any country in the world. About 1/5 of Canada’s population is foreign born, and the country’s low birth rate and population contributes to a sense that immigrants are a welcomed addition to the community rather than a strain on resources or an encroachment on identity. Second, and contrary to Trump’s statements, merit-based immigration in Canada does not just mean admitting highly skilled workers. True, Canada admits more highly-skilled workers than the United States (in 2016 it was one permanent skilled visa per 409 Canadian citizens), but they also admit a higher percentage of visas to caregivers, agricultural workers, and other workers in fields which require a lot of labour but would not typically be considered highly-skilled. In Canada, the immigration system is all about filling the country’s needs; this means admitting not only highly-skilled tech superstars, but also people to pick crops, those with family connections and people to care for the country’s elderly. Canada is also unusual in that it allows provinces to weigh in on the awarding of visas. And unlike the U.S., Canada adjusts its immigration targets on an annual basis, allowing it to admit more or less economic immigrants versus family immigrants or refugees depending on how many applicants there are in each category in a given year. No immigration system is perfect; sometimes, immigrants admitted on the basis of skills find these don’t translate to a job in Canada. But this system aims to ensure, as best it can, that immigrants land in an area where they will have a job and a role to play in the community, and that the government is able to react to demand for labour.

Immigration Systems: An International Comparison

No two immigration systems are exactly the same, but many share some similarities.

United Kingdom

The U.K. uses a points-based immigration system which divides visa categories into four tiers. The system, adopted in 2008, is modelled on the Australian system and replaced a complicated setup which resulted in 80 different types of visas being issued. The new system was originally introduced with five tiers, but Tier 3 (a pathway for unskilled workers) was eliminated when the government decided it didn’t need unskilled immigrants from outside the EU.

  • Tier 1 is for high-value immigrants: those with exceptional talent, wealthy investors, and others deemed world leaders in their fields. Those admitted under Tier 1 are capped at 1,000 a year, although there are few who have actually entered on a Tier 1 visa so far. Points are awarded under Tier 1 for English language ability, financial means, age and previous experience.
  • Tier 2 is for skilled workers in jobs that can’t be filled by a UK or European Economic Area (EEA) employee, and includes religious figures, sportspeople, and intracompany transfers. Intake under Tier 2 is capped at 20,700 a year (unless the applicant makes over £150,000 a year), and applicants must have a specific job to qualify. 70 points are required for acceptance. Having a job on the ‘Shortage Occupation List’ is the fastest route (CEOs, engineers, medical personnel), as it earns the applicant 50 points.
  • Tier 4 is for students.
  • Tier 5 is for temporary migrants.

Because the UK is still a member of the EU, these criteria apply only to applicants from outside the EU. Additionally, the UK requires that applicants planning to stay for longer than 6 months undergo a medical examination to ensure they don’t have any conditions which require major treatment (straining the UK’s resources), endanger the lives of UK residents, or render them unable to support themselves financially.


In 1972, the Australian government decided to replace its race and ethnicity-based immigration system and replace it with one which granted visas based on personal attributes and an applicant’s ability to contribute to Australian society. The Migration Programme has two broad categories of visas: employer-sponsored and skilled workers. Skilled worker visa applicants are graded on a points system, with a 65 point minimum for acceptance. A “skilled worker” can encompass a professional and a skilled manual labourer (like a mechanic), and applicants earn 60 points for having a specific desirable skill set. Youth workers or those with occupations deemed less essential are typically awarded 40 points. Additional points are earned for other characteristics, such as age, education, qualifications, and previous experience working abroad. Like the UK, Australia also requires a physical to be performed, including a chest X-ray and an HIV test. Applicants with medical conditions are considered on a case-by-case basis as officers evaluate the impact of their treatment on Australia, and only tuberculosis will cause a visa application to be halted while treatment is undergone (the UK has a similar policy on tuberculosis).

Australia also requires a “character test” designed to prevent criminals and other risky persons from entering the country. Applicants can be denied not only for having a criminal record or an adverse security assessment by the Australian Security Intelligence Organisation or Interpol, but also if they are deemed at risk of committing a crime or contributing to disharmony within an Australian community.

Japan and South Korea

Japan and South Korea are amongst the most stringent countries in the world when it comes to immigration. As some U.S. conservatives have recently claimed, this comes primarily from a desire to preserve their cultural homogeneity. In South Korea, acquiring citizenship without family ties requires several years of residence, a test on history, culture and customs, and an in person language test. Japan has also been historically resistant to immigration, and upholds several unusual policies. These include granting citizenship based on parental nationality rather than the country in which the child was born, which can result in several generations of a family lacking citizenship despite having lived in Japan for decades. As recently as 2010, the Japanese government offered its citizens around $3,000 USD to leave the country after the global financial crisis caused unemployment to skyrocket (the requirement was reduced from permanent departure to three years outside of Japan). While this system is in line with its cultural values, Japan has an increasingly ageing population and a lack of young workers, a problem which could be solved with a more lenient immigration policy.

The U.S. Immigration System and the Possibility of Reform 

The American system is unusual for its characteristic prioritisation of family ties; 2/3 of all residency visas are issued to applicants with a U.S. citizen family member, a higher ratio than in any other country. The U.S. also has a wider definition of family than any other country; siblings and even married adult children are eligible. This has definite advantages; according to Demetrios G. Papademetriou of the Migration Policy Institute, “you have someone here who will show you the ropes, who will take you in, that can set up employment for you. When it comes to immigrant integration, family is very important.”

So, perhaps the course of reform lies somewhere in the middle of strict merit-based grading and family immigration. If the U.S. were to adopt a points-based system, as has been proposed several times over the past few decades, it could take into account economic needs by grading applicants with job offers or essential skills and retain the cultural tradition of family-based immigration by awarding points for family connections. But the U.S. should not fully adopt Trump’s proposals; agricultural workers and healthcare workers are just as important to keeping the economy running smoothly as CEOS and tech wizards, the highly skilled people Trump claims are the solution to America’s immigration “problem”. The U.S. could also consider an adaptation of the Canadian system by letting the states have a say in immigration decisions. By creating a points system which rewards both family ties and economic contributions, the U.S. would be able to maximize the already significant contributions of immigration, while best setting up immigrants for success by ensuring they have skills, a job, or family connections when they arrive in the country. The U.S. has always prided itself on being a country of immigrants, and experts are wary of making too quick a decision on immigration reform. For Justin Gest of George Mason University, “immigration is social engineering. You’re building the population of the future.”