New LMIA Rule 2025: Direct Apply Now Mandatory for Canadian Employers on Job Bank

If you are an employer in Canada seeking a Labour Market Impact Assessment (LMIA) to hire through the Temporary Foreign Worker Program (TFWP), there's a significant change you need to know.

Effective September 2025, employers hiring through the Temporary Foreign Worker Program must now enable the “Direct Apply” feature on Canada’s Job Bank as part of their Labour LMIA advertising requirements.

This change, introduced by Employment and Social Development Canada (ESDC), sets a higher standard for recruitment compliance and directly impacts how employers must advertise and process applications.

What Changed?

Previously, employers were required to:

• Post their job opening on the Job Bank for at least 4 consecutive weeks.

• Advertise the position through two additional recruitment methods (e.g., company website, LinkedIn, industry job board).

Enabling Direct Apply on the Job Bank was optional.

Now, it is mandatory. Employers must accept and review all applications received through the Direct Apply feature. Failure to do so can result in non-compliance and a rejected LMIA application.

Additional Advertising Rules Still Apply

In addition to this new requirement, employers must:

• Maintain at least two additional application methods (e.g., email, company portal, LinkedIn). Direct Apply alone does not meet the advertising requirement.

• Keep proof of all postings and recruitment efforts.

• Review every resume submitted via Direct Apply within 21 days. Ignoring submissions leads to non-compliance.

• Document and retain records: resumes received, reasons for rejection, recruitment efforts for at least six years.

• Demonstrate genuine efforts to hire Canadians and permanent residents before turning to the TFWP.
  
  

Consequences of Non-Compliance

Employers who fail to comply may face:

• Restrictions or removal of job postings from the Job Bank.

• Refusal of their LMIA application.

Both outcomes can create major delays and may derail hiring plans entirely.

What Job Seekers Should Know

This change benefits job seekers too. With Direct Apply enabled, candidates can submit applications directly within Job Bank, with no need to create multiple accounts or navigate external platforms. It streamlines the process and ensures applicants aren’t filtered out before even being reviewed. This makes the hiring process more transparent and accessible.

Why was this Change Introduced?

The federal government has been tightening LMIA rules to ensure employers make good-faith efforts to recruit within Canada before turning to the TFWP. With affordability and labour market pressures at the forefront, this measure aims to:

• Improve transparency in recruitment,

• Give Canadian applicants a fairer chance, and

• Reduce concerns about overreliance on foreign labour.

Final Thoughts

If you are hiring through the TFWP, this change is a red flag on compliance you can't afford to ignore. Ensure Direct Apply is active, review submissions promptly, and track every step taken to meet the recruitment requirements.

Failure to do so may result in delays, rejections, or penalties that could severely impact your ability to hire through the TFWP.

If you are preparing an LMIA application, now is the time to ensure your postings and recruitment practices meet the new national standard.

To learn more information or seek legal advice, please do not hesitate to reach out to our experienced law firm at rharding@hardingimmigrationlaw.com or book a consultation here.