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Canada’s immigration framework continues to evolve in response to labour shortages, housing pressures, and regional economic needs. Recent changes have had a noticeable impact on businesses - especially those that rely on foreign workers or skilled international talent.

Many of these changes were introduced as part of the 2025-2027 Immigration Levels Plan and various policy shifts, and while some were aimed at improving system integrity and aligning admissions with labour market needs, employers have seen noticeable effects on recruitment, costs, and workforce planning.

“In today’s regulatory environment, immigration is no longer merely a recruitment solution - it is a core component of workforce governance,” says Dahlia Pervez of Pervez & Pervez Law. “Employers that approach immigration strategically, with compliance embedded into operational planning, will be better positioned to navigate policy shifts and sustain long-term growth.”

The Cambridge-based general practice firm offers practice areas in immigration, corporate & commercial, employment, and wills and estates, and is licensed in both Canada and the U.S., providing Dahlia with a unique perspective.

The Chamber asked her to share some insight on Canada’s immigration framework and the impact it will have on businesses:

Q: What are the latest changes to the Temporary Foreign Worker Program (TFWP) and how might they affect employers?

Dahlia: Over the past year, the Temporary Foreign Worker Program (TFWP) has shifted toward significantly tighter oversight and policy recalibration. The federal government, through IRCC and ESDC, has focused on two parallel objectives: protecting the integrity of the labour market while addressing genuine shortages in priority sectors such as healthcare, construction, agriculture, and hospitality.

One of the most material changes for employers is heightened scrutiny of Labour Market Impact Assessments (LMIAs), particularly within the low-wage stream.

In regions experiencing higher unemployment rates, LMIA approvals have become more restrictive, and in some cases capped by sector. Employers must now demonstrate more thoroughly that a real and immediate labour shortage exists and that no Canadian citizen or permanent resident is reasonably available to fill the role.

Additionally, recruitment standards are more rigorously assessed.

Officers are examining wage levels, job duties alignment with NOC classifications, and whether the offered compensation reflects genuine market conditions rather than a nominal compliance effort.

Processing times have also fluctuated due to increased compliance reviews and enforcement initiatives. Employers should therefore anticipate longer planning cycles and implement structured documentation procedures before initiating recruitment abroad.

The TFWP remains operational and strategically important, but it is now markedly more compliance-driven and documentation-intensive than in previous years.

Q: Have there been updates to the Global Talent Stream or other priority pathways?

Dahlia: The Global Talent Stream (GTS) continues to be one of the fastest and most efficient pathways for high-skilled foreign workers, particularly within technology and innovation-related industries such as artificial intelligence, advanced engineering, and digital infrastructure.

However, eligibility standards are being applied with greater precision. Employers must clearly demonstrate that hiring under the GTS will generate broader economic benefits, including knowledge transfer, job creation for Canadians, or measurable innovation outputs. Labour Market Benefits Plans are reviewed more closely to ensure commitments are substantive and achievable.

Beyond the Global Talent Stream, priority processing pathways are increasingly tied to Canada’s long-term economic objectives. Skilled trades, healthcare professionals, construction workers, and certain STEM occupations are often prioritized due to infrastructure expansion and demographic pressures.

The broader governmental approach reflects strategic immigration planning, aligning foreign worker intake with long-term labour forecasting rather than short-term employer demand alone.

Q: Are there new compliance requirements such as higher wages or stricter LMIA standards?

Dahlia: Yes; and this is an area where employers must exercise particular diligence.

Wage compliance has become central to LMIA approvals. Employers must meet or exceed the prevailing median wage for the specific region and occupation.

Any discrepancy between wage, job description, and NOC classification can trigger refusal or future audit risk. Authorities are also scrutinizing benefit structures, working hours, overtime practices, and working conditions to ensure foreign workers are not vulnerable to differential treatment.

Recruitment efforts must be comprehensive and well-documented. Generic advertising is no longer sufficient. Employers are expected to retain evidence of recruitment timelines, platforms used, number of applicants, interview notes, and objective reasons for rejection.

Compliance inspections have expanded both proactively and randomly. As a result, employers should implement structured internal systems, including:

• Centralized payroll verification
• Immigration-specific employment contract templates
• Formal documentation retention schedules
• Manager training on TFWP obligations and prohibited conduct

Non-compliance carries significant consequences, including administrative monetary penalties, temporary or permanent bans from hiring foreign workers, publication on the public non-compliance list, and reputational damage.

Q: How do recent changes to the International Mobility Program (IMP) impact employers?

Dahlia: The International Mobility Program (IMP) remains a valuable mechanism for LMIA-exempt hiring, particularly for intra-company transferees, professionals under free trade agreements such as CUSMA, and certain categories of open work permits.

However, LMIA exemptions are being more carefully evaluated. Officers are placing greater emphasis on ensuring that exemption categories are not used to circumvent labour market testing requirements.

For example, in intra-company transfer cases, employers must clearly establish that the worker possesses specialized knowledge or occupies a senior managerial role as defined by policy guidelines. Generalized experience or standard corporate mobility is insufficient.

One positive development is the continued availability of open work permits for spouses of certain skilled workers, which supports dual-income household stability and improves long-term retention.

Overall, while the IMP remains flexible, documentation standards and genuine eligibility assessments are increasingly rigorous.

Q: Are there updates to Provincial Nominee Programs (PNPs)?

Dahlia: Provincial Nominee Programs continue to serve as critical pathways to permanent residence for foreign workers already contributing to provincial economies.

However, nomination allocations and eligibility criteria have become more strategically aligned with sector-specific shortages. In many provinces, priority occupations now include:

• Healthcare professionals
• Skilled trades and construction workers
• Early childhood educators
• Agricultural specialists
• Rural and regional workers

Conversely, certain technology, administrative, and general professional occupations have seen narrowed eligibility in some provinces due to quota limitations or shifting labour forecasts.

For employers, this means permanent residency planning must begin early. If retention is a goal, workforce planning should be co-ordinated with real-time provincial nomination criteria, rather than pursued reactively when work permits near expiry.

Q: What documentation and reporting changes should employers implement?

Dahlia: Given the increase in compliance inspections and enforcement activity, proactive governance is essential.

Employers should implement structured immigration compliance frameworks that include:

1. Comprehensive employee immigration files (work permits, LMIAs, job descriptions, payroll records, benefit documents).
2. Recruitment documentation retained for at least the statutory period.
3. Annual internal immigration compliance audits.
4. A designated immigration compliance officer or external legal advisor.
5. Clear internal policies prohibiting unilateral changes to wages, duties, or work location without proper authorization.

Enforcement tools now include administrative monetary penalties, public non-compliance listings, and program bans. The financial, operational, and reputational consequences of non-compliance often far outweigh the cost of proactive legal planning.