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Canada | Updated guidance for Labor Market Impact Assessment‑exempt work permits

Immigration, Refugees and Citizenship Canada (IRCC) issued new guidance on how it determines whether certain Labor Market Impact Assessment (LMIA)- exempt work permits can be issued under the reciprocal employment category.

Key highlights:

Under R205(b) – C20, work permits may be issued without an LMIA when a foreign national’s employment creates reciprocal (similar) job opportunities for Canadian citizens or permanent residents in other countries.

IRCC’s updated guidance clarifies what reciprocal employment is and tightens certain administrative details. Key changes include:

  • Specifying that Canadians or Canadian permanent residents must have reciprocal employment opportunities in the country the foreign national worker is coming from, rather than generally abroad
  • Confirming that Canadian permanent residents must have access to reciprocal opportunities, not just citizens
  • Clarifying that a job offer qualifies for an LMIA-exempt work permit if it maintains an existing exchange rather than just creating a new one
  • Requiring the province and city listed in the application to match the job offer exactly

IRCC published the updated guidance on Feb. 20, 2026, and it applies moving forward.

This alert has been provided by the BAL Global Practice Group.

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