Prepare for 2025–2026 LMIA Changes: Key Policies HR Must Act On Now

As Canada recalibrates its immigration priorities, HR departments face a crucial inflection point. In 2025–2026, stricter LMIA rules could delay hiring plans, disrupt onboarding timelines, and even jeopardize access to international talent.

This article decodes the latest LMIA policy shifts and equips you with expert-backed, actionable strategies to stay compliant and competitive in the evolving hiring landscape.

Context: Canada Is Reshaping Its LMIA Landscape

The Labour Market Impact Assessment (LMIA) process is undergoing one of its most significant overhauls in a decade. Canada’s federal and provincial governments are tightening controls to curb low-wage job dependency and prioritize high-value roles.

In 2025, Ottawa introduced national intake caps, while sectoral freezes in Quebec and B.C. now target roles in food service, retail, and personal care.

Processing alert: LMIA wait times have increased to 10–12 weeks nationally, and up to 16 weeks in Quebec for low-wage roles.

This reshaping reflects Canada’s shift toward a more selective, skills-based labour market.

Implications for Employers & HR Teams

The days of reactive recruitment are over. HR must now embrace forecasting and compliance as essential components of workforce planning.

Audit activity has jumped 37% since 2023. Common triggers include wage discrepancies, poorly documented recruitment efforts, and NOC mismatches.

Organizations relying on foreign workers must budget more time and resources to navigate the LMIA process. Missing a sectoral window or misfiling paperwork could delay a critical hire by months.

Strategic HR leaders are now integrating immigration risk assessments into quarterly hiring reviews.

Impact on Immigration Pathways via LMIA

LMIA-backed job offers still unlock access to Express Entry and PNP programs, but the bar is higher. Candidates now need:

• Enhanced language scores (CLB 7+)
• Job offers that align with TEER 0–3 NOC categories
• Salaries meeting or exceeding regional medians

Companies serious about long-term retention must tailor roles that satisfy both operational needs and PR criteria. Many are also exploring LMIA-exempt pathways under CUSMA, ICT, or Mobilité Francophone streams to mitigate bottlenecks.

Policy Trends to Watch in 2025–2026

Emerging patterns: Ottawa is favouring tech, trades, and healthcare. Employers in these sectors may benefit from faster processing and priority support.

Recommendations for HR Leaders

Be proactive, not reactive:

• Start LMIA recruitment 9–12 months in advance
• Audit-proof your files: Document job ads, interview notes, and wage justifications
• Use compliant job titles and NOC codes aligned with new TEER structure

Expand your options:

• Consider LMIA-exempt routes (e.g., CUSMA, Mobilité Francophone)
• Partner with licensed RCICs to ensure up-to-date filings and submissions

Book an Immigration Audit Call + Get the Work Permit Risk Playbook:

Schedule a free immigration audit with AskAïa to proactively assess your hiring practices. You’ll also receive our Work Permit Risk Playbook to support audit preparation and workforce continuity.

HR teams that align immigration compliance with long-term hiring strategy will stay ahead of this shifting terrain.