Hiring Temporary Foreign Workers in 2026: understanding the restrictions in effect
In 2026, recruiting temporary foreign workers remains complex and challenging. Between reduced temporary immigration targets, freezes on low‑wage Labour Market Impact Assessment (LMIA) applications, and new administrative requirements, employers must navigate a regulatory framework that is constantly evolving.
To avoid refusals, delays, or non‑compliance, it is essential to understand the rules in effect and anticipate their implications.
Basic principles of immigration
To better understand the impact of the various measures in place, it is important to grasp the core principles of immigration. In other words, to hire a temporary foreign worker, the employer must demonstrate that the position cannot be filled locally. This demonstration is made through a Labour Market Impact Assessment (LMIA) and, in Quebec, concurrently with an application for a Certificat d’Acceptation du Québec (CAQ).
Once the LMIA and CAQ are approved, the worker may apply for a work permit.
Some work permits are exempt from LMIA/CAQ requirements. These fall under the International Mobility Program (IMP).
Conversely, the Temporary Foreign Worker Program (TFWP) includes all permits requiring an LMIA and is the primary target of the new restrictions.
The role of wage
The wage offered for the position determines the type of LMIA.
A “low‑wage” LMIA applies when the wage offered is below the median wage for the province or territory where the job is located. A “high‑wage” LMIA applies when the wage is equal to or above the median.
This distinction is crucial, as most current restrictions affect the “low‑wage” stream.
Restrictive measures in effect in 2026
Extension of the low‑wage LMIA freeze in Montreal and Laval
The Government of Quebec has extended the suspension of low‑wage LMIA processing until December 31, 2026. The freeze applies to the administrative regions of Montréal and Laval.
Montreal administrative region includes the following municipalities:
– Baie-D’Urfé
– Beaconsfield
– Côte-Saint-Luc
– Dollard-des-Ormeaux
– Dorval
– Hampstead
– Kirkland
– L’Île-Dorval
– Montréal
– Montréal-Est
– Montréal-Ouest
– Mont-Royal
– Pointe-Claire
– Sainte-Anne-de-Bellevue
– Senneville
– Westmount
Laval administrative region corresponds to the city of Laval.
As a result, it is not possible to submit a low‑wage LMIA for a position located in any of these municipalities. The freeze also applies to work permit renewals. Certain sectors are exempt from this refusal.
Federal freeze on low‑wage LMIAs in Census Metropolitan Areas (CMA) with unemployment above 6.00%
Since September 26, 2024, no low‑wage LMIA applications are processed in regions where the unemployment rate exceeds 6%.
Unemployment rates are updated quarterly. The measure applies to both initial applications and renewals.
The maximum duration of a low‑wage LMIA‑based work permit is limited to 12 months. Certain sectors, identified by NAICS code, remain exempt.
Increase in the reference median wage
The median wage used to determine LMIA stream classification is updated annually. The most recent update took effect on June 27, 2025. As a result, many positions automatically shifted to the “low‑wage” category, even if they had previously been considered “high‑wage,” making them subject to the applicable restrictions during permit renewal.
Limit on the proportion of low‑wage positions
An employer may hire temporary foreign workers for low‑wage positions up to 10% of their total workforce per worksite. Any LMIA application exceeding this quota will not be processed.
However, for certain specific industries, identified by NAICS code, the quota is increased to 20%.
New LMIA‑related obligations
French‑Language requirement (TFWP)
Effective December 17, 2025, with verification scheduled three years later (December 17, 2028), TFWP workers who have accumulated three years of residence in Quebec must demonstrate oral French level 4 in order to obtain a new work‑related CAQ.
Mandatory Francization for companies
Since December 17, 2025, Quebec businesses with 25 or more employees must comply with francization requirements to obtain a positive LMIA.
The agricultural sector is exempt from both obligations.
What realistic alternatives exist in 2026?
LMIA‑exempt work permits — International Mobility Program (IMP)
LMIA‑exempt work permits can offer an alternative to LMIA restrictions.
Francophone Mobility for employers outside Quebec: allows issuance of a 36‑month LMIA‑exempt work permit. The job does not need to be in French, but the worker must demonstrate proficiency in spoken French.
International Experience Canada (IEC) for citizens of 36 eligible countries (generally non‑renewable and subject to seasonal quotas): allows a work permit of up to 24 months, LMIA‑exempt. Employers must submit an electronic job offer.
Recruiting workers already in Canada
Hiring workers already in Canada is another strategy employers may consider.
Holders of open work permits may work for any employer, meaning no employer‑side application is required. However, employers must plan ahead for future immigration steps before the permit expires.
Workers undergoing permanent residence processing may access LMIA‑exempt work permits while awaiting a decision. In Quebec, holders of a Quebec Selection Certificate (CSQ) can access LMIA‑exempt work permit options.
Internal adjustments
For companies with multiple worksites in different CMAs, changing the job location may be an option. For example, a low‑wage LMIA cannot be submitted on the Island of Montreal, but it is possible in the Quebec CMA. A discussion about relocating the worker may be appropriate.
Similarly, if the salary offered to the temporary foreign worker is slightly below the median wage, increasing the wage may be considered. If financially feasible, this can shift the position into the “high‑wage” stream and avoid the restrictions in place.
However, employers must be mindful of pay‑equity considerations between Canadian citizens/permanent residents and foreign workers.
Conclusion
In 2026, access to temporary foreign workers is more restricted than ever, particularly for low‑wage positions. Employers must now adapt their immigration strategies, analyze available options, and anticipate the impact of regulatory measures.
Contact our professionals to address your questions and guide you through the options available to your temporary foreign workers.