Mandatory Direct Apply, stricter documentation, and enhanced compliance rules
Based on the most recent sources from 2025-2026, here is a comprehensive summary of the new LMIA requirements for Direct Apply and employee screening as of September 2026:
Direct Apply Requirements (Effective September 2025)
As of September 2025, employers applying for a Labour Market Impact Assessment (LMIA) must now use the Job Bank Direct Apply feature when advertising positions under the Temporary Foreign Worker Program (TFWP).
Employers must keep the "Direct Apply" application method activated and review and consider applications submitted through that method as part of the employer's recruitment efforts.
Key Direct Apply Compliance Rules:
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Job Bank's Direct Apply is now mandatory. Since September 2025, employers must use it as an application method, and Service Canada compares those numbers against your recruitment log.
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If Direct Apply is disabled, or where applications submitted under Direct Apply are not downloaded, reviewed and considered, employers will be considered not to have met the TFWP recruitment requirements for LMIA purposes.
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If a Job Bank posting remains active after the LMIA is submitted, all advertising requirements, including the mandatory Job Match and Direct Apply features, must continue to be met. Service Canada will review all recruitment activities up until a decision is made on the LMIA application.
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Employers are required to download and review all resumes submitted via Direct Apply, and disabling Direct Apply or failing to consider applicants who use it may result in non-compliance with LMIA recruitment efforts.
How Direct Apply Works
Direct Apply is now the default application method for new job postings, enabling job seekers to submit their applications quickly and directly through postings.
For Job Seekers:
Direct Apply is a feature that lets you submit your application directly on Job Bank for job postings that offer this option, and you can choose to send either a resume you've uploaded or one you've created using the Resume Builder.
Job seekers can download their resume in PDF, as the Resume Builder now lets them save their resume in a professional, shareable PDF format.
For Employers:
Employers can access all resumes submitted via Direct Apply in their Job Bank employer dashboard by signing in, going to the "Applications" section, clicking the applicant's name to open their application which includes their resume, answers to screening questions, and other details, and can download the resume to save to their computer.
Hiring is made easier with one click where employers can see an applicant's resume, cover letter, answers to screening questions and employment eligibility, and can provide instant decisions and feedback by accepting or rejecting applications from the "Applicants and matches" section of the dashboard.
Employers can now see how well the candidates' profile matches their job posting when they apply via Direct Apply.
When employers reject an application, they'll choose a reason, and that reason will be shared with the applicant as helpful feedback.
How to Download Applications
Employers can download applications through their Job Bank employer dashboard:
- Sign in to Job Bank for Employers
- Navigate to the "Applications" section on the main page
- Click on the applicant's name to view their full application
- Click "Download resume" to save the file to your computer
30-Day Feedback System (2025-2026)
When applicants apply through Job Bank, they'll know within 30 days if their application was retained, and if not, they'll start receiving reasons so they can improve for future opportunities.
Recent Platform Updates (2026)
The Direct Apply applicants table and the job posting extension page were updated, making it simpler to review applications and manage job postings.
Employers have access to updated screening questions when creating a job posting, which helps identify the best candidates more easily.
Recruitment Documentation Requirements
Recruitment Log Documentation
Employers must record Canadian and permanent resident applicants and why each was not hired. The recruitment log must be comprehensive and structured:
Complete log of all applications received during the recruitment period, organized chronologically, with each applicant showing: name (or reference number if anonymized), date application received, whether an interview was conducted (and date if yes), and the specific reason the applicant was not selected.
Employers must maintain complete records of all recruitment activity including all job postings across all platforms with dates, all applications received organized chronologically, all correspondence with applicants including invitation to interview and rejection communications, and all interview records and assessment notes, retained for at least six years from the date of the LMIA issuance.
Advertising Evidence & Screenshots
Employers must run compliant ads, use Job Match and Direct Apply, and keep dated screenshots.
For online job postings, take screenshots of the posting on each platform at the time it is live, capturing the full posting content, the platform name in the URL bar, and the posting date where it is visible on the page, and save these screenshots as dated PDF files with the platform name in the filename.
ESDC officers cannot verify advertising claims from images that could have been taken from anywhere - the screenshot must be unambiguous about what platform it is from and when it was live.
Advertising Duration Requirements
The temporary suspension of minimum advertising requirements ended January 1, 2026, and employers must once again provide proof of advertising and recruitment efforts when applying for an LMIA.
Federal law mandates that employers advertise the vacancy locally on Job Bank Canada and two additional channels for a minimum of 4 weeks.
Employers must activate the direct apply system for at least 30 days.
High-Wage Positions
The minimum recruitment period is four consecutive weeks, and all postings must run for this entire period without gaps.
Low-Wage Positions (Effective April 1, 2026)
Low-wage roles need eight consecutive weeks of advertising on Job Bank plus at least two other methods, with documented targeted youth recruitment.
At least one advertisement must also run throughout LMIA application processing, meaning continuous, uninterrupted advertising until a decision is made.
Required Documentation Categories
ESDC requires four main categories of documents for standard TFWP LMIA applications: business legitimacy documents (registration, CRA Business Number, financial statements), recruitment evidence (job postings, recruitment log, interview records), job offer documents (signed offer letter, prevailing wage evidence, foreign worker qualifications), and stream-specific plans (Transition Plan for High-Wage, Accommodation Plan for Low-Wage).
Employers may need to provide business licenses, CRA payroll records, T4 summaries, financial statements, bank statements, proof of active operations, lease agreements, recruitment screenshots, interview notes, applicant rejection explanations, and organizational charts, maintaining copies of advertisements, dates ads were posted, proof of payment for advertisements, detailed applicant tracking, interview summaries, and reasons for rejecting applicants.
Retention Period
Employers must retain records of recruitment and advertising efforts to hire Canadians or permanent residents for a minimum of six years for inspection purposes.
Low-Wage Position Requirements (Effective April 1, 2026)
As of April 2026, employers filing a new LMIA for a low-wage position must advertise for 8 consecutive weeks and include youth-targeted recruitment methods.
As of April 1, 2026, employers must show efforts to recruit youth (aged 15–30) and use at least two additional recruitment methods appropriate to the occupation.
Since April 1, 2026, low-wage roles must show efforts to reach youth, plus other underrepresented groups.
These measures are in effect from April 1, 2026 until March 31, 2027.
Proof of advertising submission was reinstated for primary agriculture LMIAs on January 1, 2026.
Business Legitimacy & Employee Screening Requirements
Core Business Legitimacy Assessment:
Before ESDC assesses recruitment efforts, wages, or labour market impact, a Service Canada officer first determines whether your employer is a real, operating business with a genuine need for this specific worker.
We assess your LMIA application and any supporting documents to confirm that your business: is providing a good or a service in Canada, is offering employment that's consistent with the reasonable needs of your business, can fulfill all of the terms of the job offer, including the wages for temporary foreign workers and other applicable financial obligations, has no compliance issues.
Documentation Requirements:
Sponsoring companies must prove they operate an actively engaged, legally established business inside Canada that provides ongoing goods or services to the public. Compliance is verified using certified corporate tax filings, commercial lease agreements, and municipal business licenses.
Employers whose most recent positive LMIA was issued within the past two years are generally not required to re-submit business legitimacy documents. All other employers must provide a valid municipal business licence, or if one is not required in their area, at least one alternative document such as a T4 Summary, T2 Schedule 100 and Schedule 125, a PD7A statement, or other documents.
A critical point from ESDC's updated 2026 guidance: all CRA-sourced documents must be official copies issued by CRA directly – not downloaded PDFs or self-printed summaries from the CRA My Business Account portal.
LMIA Application Fees and Costs
LMIA Application Fee
The standard LMIA application fee is $1,000 CAD per position, which is non-refundable and cannot legally be passed on to the worker. The fee won't be refunded if your application is withdrawn, cancelled or if your LMIA is negative.
Fee Exemptions
The Primary Agriculture stream (including the Seasonal Agricultural Worker Program and the Agricultural Stream) is exempt from the $1,000 LMIA fee. Additionally, families using the Home Child Care Provider Pilot or the Home Support Worker Pilot do not use the traditional LMIA process and therefore do not pay the standard fee.
Other standard TFWP streams (high-wage, low-wage, Global Talent Stream, standard caregiver) are subject to the $1,000 fee per position.
Worker Fees
While employers pay the LMIA fee, the worker pays CAD $155 for the work permit and CAD $85 for biometrics, totalling CAD $240.
Processing Times
Standard LMIA processing takes 10 to 20 weeks, with some streams (such as the Global Talent Stream) processed in 2 weeks.
The Global Talent Stream has remained the fastest option with average decisions coming in around 7–9 business days, agricultural and seasonal agriculture streams are processed within 7–14 business days, and mid-range streams such as high-wage and low-wage positions average about 38–45 business days in 2025.
Wage Thresholds Update
As of July 17, 2026, updated hourly wage thresholds are in effect, which are used to determine whether a position applied for is considered high-wage or low-wage.
Regional Restrictions
If your worksite is in a Census Metropolitan Area (CMA) with an unemployment rate of 6% or higher, applications for low-wage positions (below the provincial median wage) may be refused.
Since September 26, 2024, ESDC will not process most low-wage LMIA applications for jobs located in census metropolitan areas where the unemployment rate is 6 per cent or higher, subject to limited sector exceptions.
Since mid-2024, ESDC will not process low-wage LMIA applications in Census Metropolitan Areas (CMAs) where unemployment is at or above 6%, and as of early 2026, major centres including Toronto, Calgary, Edmonton, and Ottawa-Gatineau remain blocked.
As of April 10, 2026, low-wage LMIA applications are not being processed in 30 census metropolitan areas where unemployment is 6 percent or higher, including Vancouver, Toronto, Montreal, Calgary, Edmonton, Winnipeg, and Halifax. The 2026 Temporary Foreign Worker Program cuts reduced LMIA approvals by 37%.
Workforce Cap Changes (August 2026)
Employment and Social Development Canada (ESDC) changed the low-wage workforce cap calculation for employers with fewer than ten employees at a given work location on August 18, 2026.
From April 1, 2026 to March 31, 2027, eligible employers in rural areas outside census metropolitan areas may use a temporary 15 per cent cap.
Compliance and Enforcement (2025-2026)
According to the Government of Canada's 2026 compliance report, ESDC finalized 1,488 compliance inspections between April 1, 2025 and March 31, 2026, with 12% of employers inspected found to be non-compliant, and over $10.2 million in monetary penalties were issued - more than doubling the prior year's total of $4.5 million - with 30 employers banned from the program entirely.
