Canada Tightens LMIA-Exempt Work Permits

Ottawa has just changed the eligibility criteria for the work permit issued under the C20 exemption, which normally exempts employers from obtaining a Labour Market Impact Assessment (LMIA).

On July 29, 2026, the immigration department published new guidelines for officers responsible for processing these applications. The most significant change: a foreign worker can now only receive this type of permit if they are already employed by the company abroad at the time of application. In other words, it’s no longer possible to obtain this permit for a job that would only begin upon arrival in Canada.

This restriction was not present in the previous version of the guidelines. According to the new text, starting a job only after arriving in the country would not allow for a genuine transfer of knowledge or experience between the worker and the Canadian employer, which runs counter to the very spirit of the program.

A shift in philosophy in the assessment

The previous version of the guidelines placed heavy emphasis on the notion of neutral labour market impact, a criterion highlighted right at the start of the document and revisited later in the section on assessing reciprocity. This notion has been entirely removed from the new text, signaling a shift in how Ottawa approaches these applications.

What to do if the C20 exemption doesn’t apply?

A foreign worker who doesn’t qualify for any exemption under the International Mobility Program must go through the Temporary Foreign Worker Program. This means the employer must obtain an LMIA, a process that demonstrates no qualified Canadian citizen or permanent resident is available to fill the position.

This process results in additional delays and costs for the employer. Also worth noting: employers currently cannot apply for an LMIA for positions paying less than 120% of the regional median wage in regions where the unemployment rate is 6% or higher.

What impact will this have on workers already in Quebec?

In the short to medium term, this could be positive for workers already in Quebec. Less competition while demand remains strong. In the medium term, it could increase their bargaining power and put upward pressure on wages and working conditions. In the long term (and this is purely speculative), less profitable companies will have to adapt (through productivity improvements, automation, price increases, or specialization) or could struggle to survive.