Business Immigration Series: What Is Going On With LMIAs in 2025?

For business owners, employers, and immigration practitioners alike, Labour Market Impact Assessments (LMIAs) have long been a central component in hiring foreign workers through Canada’s Temporary Foreign Worker Program (TFWP). However, 2025 marks a pivotal year for LMIA rules, introducing more constraints, higher thresholds, and tighter oversight.

In this blog post, we break down the major LMIA developments in 2025, why they matter, what challenges they bring, and how employers and foreign workers can adapt strategically.

What Is an LMIA and Why It’s Crucial

Before diving into the changes, a quick refresher: an LMIA is a document from Employment and Social Development Canada (ESDC) that essentially verifies a foreign national’s employment will not negatively affect Canada’s labour market. For many work-permit streams, a positive LMIA is a prerequisite for the foreign national to receive a work permit.

From 2025 onward, we are seeing a recalibration: LMIAs will still exist, but the criteria and advantages are evolving.

Key Changes to LMIAs in 2025

1. Wage Thresholds Raised (High-Wage Stream Revised)

As of June 27, 2025, ESDC increased the wage thresholds that determine whether a job falls under the high-wage or low-wage stream.

This means many roles that previously qualified under the “low-wage” category may now be reclassified into the high-wage bracket—bringing stricter requirements, but also potentially better protections for workers.

Because of this, employers will need to reevaluate job offers, salary levels, and classification strategies.

2. Shorter LMIA Validity Period

One of the changes brought forward is reducing how long a positive LMIA remains valid. The standard validity has been cut from 12 months to 6 months. 

Government of Canada

This shorter window shortens the timeline for employers and prospective workers to act. Delays in downstream processes (work permit applications, labour compliance, etc.) may create tighter coordination challenges.

3. Caps and Restrictions on Low-Wage LMIAs

Several new restrictions target LMIA applications for lower-paying jobs:

Refusal to process in high-unemployment regions: If the job is low-wage and located in a Census Metropolitan Area (CMA) with an unemployment rate of 6% or higher, LMIA applications may not be processed.

Caps on proportions: Low-wage positions must not exceed a fixed percentage of the total workforce at a work location—typically 10%.

Duration limit reduced: For low-wage roles, the authorized work period is reduced from up to two years down to one year.

These constraints significantly raise the bar for employers relying on foreign labour in low-wage roles.

4. Moratoria in Select Regions & Suspensions

Some regions with high unemployment rates are subject to moratoria or temporary suspensions on processing low-wage LMIAs.

For example, as of April 4, 2025, LMIA processing for low-wage positions in certain high-unemployment census areas has been paused (through July 10, 2025, in many cases).

These moratoria change frequently as labour statistics shift, so geographic awareness and timing are critical.

5. No More LMIA Bonus Points for Express Entry

One of the big policy shifts in 2025: as of March 25, Immigration, Refugees and Citizenship Canada (IRCC) removed CRS (Comprehensive Ranking System) bonus points for job offers supported by LMIAs.

While LMIAs remain relevant (because many streams still require them), the removal of bonus points changes how attractive a LMIA-based job offer is — particularly for prospective permanent residents who relied on those extra CRS points.

6. Stricter Employer Legitimacy Requirements

Employers can no longer rely on simple attestations (e.g., from lawyers or accountants) to confirm business legitimacy. Instead, more rigorous documentation—financial statements, tax filings, payroll records—is required.

This tightening indicates increased scrutiny on the side of enforcement and verification.

Moreover, beginning in late 2025, new advertising rules are being introduced: employers applying for LMIA must use the “Direct Apply” feature on the National Job Bank. Failing to accept or review applications submitted through Direct Apply may jeopardize the four-week recruitment requirement and lead to application rejection.

7. Bridging & Transition Policies for Closed Work Permits

In a somewhat favorable move, IRCC has extended a public policy allowing foreign nationals holding closed (employer-specific) work permits to change employers (or occupations) before obtaining a new work permit, under certain conditions.

While not LMIA-specific, this shift interacts with the labour market and employment flexibility, making it slightly less risky for employers to anticipate transitions.

Why These LMIA Changes Matter — Implications & Risks

Greater Employer Burden: Compliance, documentation, and strategic planning become more demanding.

Reduced Flexibility in Low-Wage Roles: Many low-wage positions may no longer be viable through LMIA pathways in certain regions.

Timing is more critical: Shorter validity, moratoria in certain areas, and stricter windows demand tighter coordination.

Shift in value of LMIA-based job offers: Without CRS bonus points, the incentive for some applicants to pursue LMIA-dependent offers diminishes.

Heightened rejection risk: Given the stricter thresholds, any misstep in documentation or recruitment can lead to denial.

Regional variability: Employers and applicants must monitor local unemployment rates to determine eligibility.

Strategies for Employers & Applicants in 2025

Here are some practical tips to navigate the evolving LMIA landscape:

Assess Wage Brackets Carefully

Given the raised threshold, evaluate your role: is it now considered high-wage? If yes, prepare for higher obligations.

Act Early

With LMIA validity now shorter, begin your recruitment and application well in advance to avoid delays.

Robust Recruitment Records

With stricter proof required, maintain detailed records of job postings, applications, screening, and reasons for rejection.

Stay Regionally Aware

Monitor whether your work location falls in a CMA with high unemployment, which might block low-wage LMIA processing.

Complementary Hiring Strategies

Where possible, rely more on LMIA-exempt pathways (e.g., via the International Mobility Program, intra-company transfers, trade agreements).

Review Succession and Transition Plans

For longer-term hires, employers should build a plan for reducing reliance on temporary foreign workers and showing that commitment in LMIA applications.

Consider Legal Support

Given the increasing complexity and stakes, working with an immigration lawyer helps reduce risk, anticipate complications, and structure applications more defensively.

Conclusion

In 2025, LMIAs are not what they once were. With tighter wage thresholds, limited validity periods, caps on low-wage roles, regional moratoria, removal of Express Entry points, and stricter employer requirements, the landscape is shifting dramatically.

For businesses that rely on foreign talent, the path forward requires strategic adaptation, careful timing, and diligent compliance. Some roles may find it increasingly difficult to qualify under LMIA-based streams, forcing employers to consider alternative immigration streams or rethink their hiring models.

If your business or foreign worker clients are navigating LMIA applications in 2025, Immigrationway can help you manage risk, prepare strong applications, and adjust strategies in response to these evolving rules.