From Nov. 3, Express Entry will again award points to candidates with a qualifying job offer in a high-wage occupation, Immigration, Refugees and Citizenship Canada (IRCC) announced. In the same announcement, IRCC told the media that job offers will no longer require a Labour Market Impact Assessment (LMIA). IRCC suspended extra points for job offers as of December 2024, after widespread fraud was discovered.
The Canadian immigration system: In brief
Immigration in Canada centres around the Comprehensive Ranking System. Foreign nationals seeking to gain permanent residency (PR) or citizenship in Canada submit immigration applications to IRCC. These applications are awarded points which determine their priority order in the Express Entry immigration pathway. Points are awarded based on the applicants' skills, education, work experience, and other factors. The higher an applicant's point total, the higher the likelihood they will be awarded PR.
Until December 2024, having an LMIA-approved job offer from a Canadian employer would count towards an applicant's point total. A common way for foreign nationals to get this job offer was through the Temporary Foreign Workers Program. Foreign nationals would apply to jobs open to TFWs and, if successful, work in Canada, adding the job to their Express Entry application, increasing their points and quickening their route to permanent residency.
Before an employer can advertise a job as a TFW or other visa-eligible role, they have to go through a government-managed Labour Market Impact Assessment (LMIA) process. As part of this process, employers have to advertise a role domestically for a mandated period of time (4 consecutive weeks for high-wage roles and 8 consecutive weeks for low-wage roles). If an employer is unable to find someone to fill the role domestically, they register with Employment and Social Development Canada (ESDC), show their hiring attempt, pay a $1,000 registration fee, and if ESDC agrees with their assessment, they receive an LMIA. This approves the position for the TFW (or other) program, and ESDC provides an LMIA letter so the applicant can apply to IRCC for the appropriate visa.
The fraud
Leading up to the December 2024 decision to end the Express Entry points award for LMIA-approved job offers, there were increasing reports of an advanced industry of fraudulent LMIA-approved jobs. The fraudsters would work with or manufacture local businesses, advertise a fake job vacancy, apply to ESDC for LMIA approval, and once approved, they would sell the job to a foreign national seeking Canadian PR status. A CBC investigation reported that a typical price for these fraudulent jobs was $30,000 to $40,000. Fraudsters were so emboldened that they advertised these as fee-for-PR schemes on Canadian Facebook Marketplace and Kijiji. The same investigation found posts that actively advertised that interested buyers could purchase the role and not have to work.
Two of the most disturbing aspects of this fraud were, first, that fraudsters were so confident in their impunity that they would blatantly advertise the fraud. This suggests a lack of fear of law enforcement. Second, that LMIA approvals from ESDC were so reliable that fraudsters could set up successful businesses assuming their fraudulent LMIA would be approved with limited scrutiny.
IRCC's decision to restore points and remove the LMIA requirement returns the incentive for fraud while removing all safeguards.
The new rules
The changes to the Express Entry program that Minister Diab announced currently only apply to high-wage occupations. This is a list of 186 distinct occupations that pay above the average median wage. The list includes web developers, tradespeople, social workers, retail and customer service managers, and various medical occupations. The high-wage occupation list is divided into three tiers. The lowest tier needs a job offer more than 1.3 times the average median wage, whereas occupations in the second and first tiers must pay at least 1.5 and 2 times the average median wage, respectively.
Food counter attendants, cooks, retail salespeople, and cleaners are not on IRCC’s high-wage list, so the change does not alter the jobs most often cited in the foreign-worker debate. Low-wage LMIA applications are also refused processing this quarter in the Toronto, Vancouver, and Calgary areas, where unemployment is 6 per cent or higher, ESDC says. The concern here is that better-paid occupations can be filled with foreign workers and that fraudsters can run the same playbook under the previous rules.
Why the new rules are terrible
IRCC’s Oct. 16 release requires no advertising or local recruitment requirement for the LMIA-free job offers. The department said it “will continue to assess job offers to confirm they are genuine and meet program requirements, with measures in place to protect against fraud.” While there may be another process in place that Minister Diab neglected to mention, by removing the LMIA process, it technically also removes the mandate to prove that the role could not be filled by a Canadian. This implies that employers could advertise any high-wage role globally before Canadians ever see a job advertisement.
Another issue with the new rule is the use of the national median wage as the wage benchmark. As of 20 October, 2026, the median hourly wage is $37.63 per hour, approximately $78,277 per year, according to StatCan. The new rule does not take into account the average wage for specific occupations, just the national median wage determined by StatCan. Thus, the wage offered to foreign nationals can be substantially lower than the market rate for that profession.
For example, according to the IRCC's tables, a job vacancy advertised to a foreign worker for an industrial electrician role needs to offer 1.3 times the national median wage, $101,760 ($78,277 x 1.3). According to Job Bank data, nationally, an industrial electrician can earn up to $112,320 per year. In Alberta, that rises to $141,440. This means that employers can abide by IRCC rules while functionally undercutting Canadian workers. In this case, anywhere from $10,000 to $40,000 below market wages.
Of course, this assumes that employers are acting in good faith and actually hire a worker, rather than just selling the work permit, as had been occurring. Because, of course, nothing in this rule change actually limits the type of fraud that the Express Entry points removal was intended to stop in the first place. The LMIA process was originally put in place for the government to audit the legitimacy of employer claims. As said previously, one of the most troubling findings of these investigations into LMIA fraud was how complicit ESDC was. This fraud could not have occurred if ESDC was performing the function the LMIA process was designed for. Further, there is little evidence of RCMP enforcement. The removal of LMIA will not eliminate fraud; it just eliminates one point where the government can be held accountable.
Beyond these immediate consequences, the decision can have the effect of depressing wages in the high-wage occupational category, similar to how the TFW program was blamed for depressing wages in the low-wage category. Worst of all, it could be depressing wages with jobs that do not actually exist. The ramifications of this reckless policy can have a real impact on the livelihoods of all Canadians.
Who is hurt most by this policy?
The youth unemployment rate was 13.0 per cent in September, twice the overall rate of 6.5 per cent, and employment among those aged 15 to 24 fell by 48,000, the second monthly decline, Statistics Canada reported in its Labour Force Survey on Oct. 9. Newcomers already in Canada are also looking for work. In 2024, the unemployment rate for landed immigrants was 7.2 per cent, and 16.4 per cent for those aged 15 to 24, according to Statistics Canada’s annual figures.
Federal support for training in the trades has also shrunk. The Apprenticeship Incentive Grant and Apprenticeship Completion Grant permanently closed applications on March 31, 2025, the Government of Canada’s grants page says.
Taken together, this decision to "streamline" foreign worker access to high-wage occupations will actively hurt the employment opportunities for young Canadians coming out of school and training, as well as new Canadians who may find themselves in dead-end jobs, with newer Canadians or permanent residents taking the jobs above them. It also creates a perverse incentive for employers. As opposed to investing in worker training and development, they can initiate a race to the bottom by advertising all job opportunities to global workers. Hiring becomes less about who is best for the role and more about who fits the minimum criteria and will accept the lowest wage.
Diab should reconsider applying Express Entry points to job offers and seriously reconsider eliminating the LMIA. Her department's decision does nothing to combat fraud and only continues to chip away at the legitimacy of our immigration system and the job market.
