In a policy update published on September 22, 2026, Immigration, Refugees and Citizenship Canada (IRCC) rewrote two of the International Mobility Program’s (IMP) core program-delivery instructions: (1) “Employer-specific work permits – general processing” and (2) “Employer compliance inspections.” The guidance now mirrors the legally-binding attestation text that every Canadian employer must sign in the Employer Portal when they offer a job to a foreign national who does **not** require a Labour Market Impact Assessment (LMIA). Although IRCC describes the changes as “house-keeping,” practitioners say the new wording significantly raises the bar for corporate compliance. Employers must explicitly confirm that (a) they have entered into an employment agreement for the same occupation, wages and working conditions promised in the offer of employment; (b) they have **not** charged the $230 employer-compliance fee, directly or indirectly, to the foreign worker; and (c) any recruiter acting on their behalf has equally refrained from fee-recovery. The revised inspection chapter closes the loop. Officers are reminded that they can launch an inspection at any point “from the first day of work until six years after the work-permit end date,” and they are instructed to cross-check payroll records, job descriptions and NOC codes against the original electronic offer. Five potential triggers remain—past non-compliance, random selection, third-party allegations, ministerial orders during public-health emergencies, or evidence that a communicable disease has spread in the workplace—but the guidance emphasises that **any** discrepancy between the offer and reality can now lead to an administrative monetary penalty, a temporary ban from the Temporary Foreign Worker and IMP streams, or even work-permit revocation. For multinational companies that routinely transfer key staff to Canada under C-level free-trade provisions or intra-company transfers, the message is clear: internal mobility policies must exactly match what HR enters in the Employer Portal, and compliance files must be retained for six full years. Employers that outsource onboarding to third-party recruiters are urged to re-audit their arrangements to ensure no recruitment fees have been clawed back from foreign talent—an offence that cannot be ‘cured’ once discovered. Practically speaking, foreign workers already in Canada do **not** have to re-apply because of the update. However, mobility managers should warn incoming transferees that border officers and inland inspectors now have explicit authority to demand a copy of the signed employment contract. In short, the paper trail must be airtight long after the employee has landed. This development underscores Canada’s broader pivot from growth at all costs to sustainable, rules-based immigration—one that places a heavier compliance burden on the corporate side of global mobility.
Source: Immigration2Canada
