“NEW LMIA ADVERTISING RULES: WHY “DIRECT APPLY” ON JOB BANK IS NOW MANDATORY”

Canada’s Temporary Foreign Worker Program (TFWP) has always balanced two priorities: helping employers fill critical labour shortages and ensuring that Canadians and permanent residents get the first opportunity at available jobs. To maintain this balance, employers hiring through an LMIA (Labour Market Impact Assessment) have long been required to prove that they made genuine efforts to recruit domestically before turning to foreign workers.

One of the cornerstones of this process has been mandatory job advertising—posting vacancies on Canada’s official Job Bank, plus using at least two other recruitment methods. Now, the federal government has added a significant new layer to these rules: employers must enable and use the “Direct Apply” feature on Job Bank.

WHY THE CHANGE?

The shift toward Direct Apply did not happen in a vacuum. For years, critics of the TFWP argued that some employers treated recruitment requirements as a formality rather than a real attempt to hire locally. Concerns were raised that:

• • • Employers could make applications harder to access by redirecting candidates to external websites or portals.
    • Qualified Canadians and permanent residents were sometimes overlooked, despite applying.
    • The TFWP risked being overused, contributing to wage suppression and putting added strain on Canada’s housing and affordability challenges.

By making Direct Apply mandatory, Ottawa is effectively removing barriers between job seekers and employers. It ensures that Canadian citizens and permanent residents can submit resumes directly within the Job Bank platform—and that employers cannot ignore those applications without consequence.

THE EVOLUTION OF LMIA ADVERTISING REQUIREMENTS

To understand the significance of this change, it helps to look back at how LMIA advertising rules have developed:

1. 1. 1. Initial Framework – Employers hiring through the TFWP were required to advertise positions widely to demonstrate no local candidates were available.
      2.  Job Bank Posting Requirement – Over time, Job Bank became the government’s primary recruitment tool, making it mandatory for employers to post there for at least four consecutive weeks.
      3.  Multiple Recruitment Channels – Employers also had to advertise in at least two additional ways (e.g., LinkedIn, newspapers, industry-specific job boards).
      4.  Now: Direct Apply Rule – Employers must enable Direct Apply on Job Bank and review all applications submitted this way, or risk LMIA rejection.

This evolution reflects the government’s increasing emphasis on transparency and accountability in the recruitment process.

WHAT HAPPENS IF EMPLOYERS IGNORE THE RULE?

Non-compliance carries serious consequences:

• • • Job postings without Direct Apply enabled may not count toward the four-week advertising requirement.
    • Ignoring applications from Canadians or permanent residents through Direct Apply can lead to restrictions on the employer’s Job Bank account.
    • Ultimately, this could result in a rejected LMIA application, delaying or preventing the hiring of foreign workers.

In addition, Direct Apply can be applied retroactively to existing Job Bank postings, meaning employers must update current ads to remain compliant.

IMPACT ON EMPLOYERS

For employers, this means a stricter and more transparent recruitment process. Companies must be prepared to:

• • • Accept and evaluate applications directly from Job Bank.
    • Document their recruitment efforts clearly to show they considered local candidates.
    • Continue advertising through at least two additional channels beyond Job Bank.

While it adds an administrative step, this policy also strengthens the legitimacy of an LMIA application by making it harder to argue that employers ignored available domestic talent.

IMPACT ON JOB SEEKERS

For Canadian citizens and permanent residents, the new rule is a win. Job seekers can now:

• • • Apply directly within Job Bank, without navigating external portals or company websites.
    • Know that their applications must be considered as part of an LMIA employer’s recruitment obligations.
    • Gain more equitable access to jobs that previously might have seemed out of reach.

THE BIGGER PICTURE

This new policy is not just about recruitment mechanics—it is part of the federal government’s broader strategy to reduce reliance on temporary residents, address labour market concerns, and ease public pressures around affordability and housing.

By ensuring that Canadians and permanent residents truly get the first shot at available jobs, Ottawa is reinforcing the original intent of the TFWP: temporary foreign workers should be brought in only when no qualified local candidates are available.