LMIA 2026: What impact will Quebec’s increased wage threshold have on employers?

On July 17, 2026, in Quebec, the wage threshold used under the Temporary Foreign Worker Program (TFWP) will increase from $34.62/hour to $36.00/hour.

This increase has significant implications for employers planning to hire a temporary foreign worker (TFW) or renew the work permit of a worker already employed by the organization.

Some positions that previously fell under the high-wage stream will now be classified as low-wage positions for the purposes of submitting a new Labour Market Impact Assessment (LMIA) application.

This change may make it more difficult to renew the work permits of certain temporary foreign workers.

However, LMIA applications submitted before July 17, 2026, will continue to be assessed based on the wage thresholds that were previously in effect.

How can you determine whether a position is high-wage or low-wage?

Under the Temporary Foreign Worker Program (TFWP), a position is considered high-wage when the wage offered is equal to or greater than the wage threshold applicable in the province or territory where the work will be performed.

Conversely, a position is considered low-wage when the wage offered is below that threshold.

This distinction directly determines the recruitment requirements, the duration of the work permit granted, and the application of certain federal and provincial restrictions.

In Quebec, employers must also include a Quebec Acceptance Certificate (CAQ) with any LMIA application. The Ministère de l’Immigration, de la Francisation et de l’Intégration (MIFI) and Employment and Social Development Canada (ESDC) then jointly assess the application.

Low-wage stream

Since September 2024, the federal and Quebec governments have gradually tightened the rules applicable to this stream in order to limit the use of low-wage LMIAs in certain regions and sectors of activity.

Enhanced recruitment requirements

Employers must demonstrate that they have made reasonable efforts to recruit Canadian citizens and permanent residents before resorting to the hiring of a temporary foreign worker.

However, the requirements are more stringent. Employers must post the position on Job Bank (or Québec Emploi) as one of their mandatory recruitment efforts. The two additional recruitment activities must target different underrepresented groups. Since April 1, 2026, employers must also demonstrate that their recruitment efforts specifically target youth between the ages of 15 and 30.

The minimum advertising period is now eight consecutive weeks, and all recruitment activities must still take place within the three months preceding the submission of the application.

Work permit duration

The maximum duration of a work permit that may be issued following a low-wage LMIA is generally limited to 12 months.

Federal restrictions applicable to low-wage positions

Limitation on the number of temporary foreign workers

Since September 26, 2024, employers are generally prohibited from exceeding a cap of 10% temporary foreign workers in low-wage positions at a given work location.

However, certain industries facing significant labour shortages, particularly in the construction, food manufacturing, and healthcare sectors, continue to benefit from a higher cap of 20%.

To determine whether a business qualifies for an exemption, reference should be made to its NAICS (North American Industry Classification System) code.

Temporary measures outside census metropolitan areas

From April 1, 2026, to March 31, 2027, certain temporary measures allow employers located outside Census Metropolitan Areas (CMAs) to benefit from greater flexibility. These temporary measures vary from one province to another.

In Quebec, employers may, in particular, maintain their current proportion of temporary foreign workers in low-wage positions, even when that proportion exceeds the general 10% limit.

Restrictions related to unemployment rates

Since September 26, 2024, low-wage LMIA applications are no longer processed in Census Metropolitan Areas (CMAs) where the unemployment rate exceeds 6%. Federal authorities review these unemployment rates on a quarterly basis.

For the period from July 10 to October 8, 2026, in the province of Quebec, the Montreal and Gatineau CMAs both have unemployment rates above 6%. As a result, low-wage LMIA applications for positions located in these regions are not being processed.

Specific rules applicable in Quebec

Quebec employers are also subject to additional restrictions.

Until December 31, 2026, low-wage LMIA applications for positions located in the administrative regions of Montreal or Laval are not being processed.

This measure also applies to occupations eligible under Quebec’s Simplified Processing program. However, these occupations remain exempt from the advertising requirement when they qualify for simplified processing. The government updates the list of eligible occupations annually on February 24.

In addition, businesses with 25 or more employees must comply with francization requirements. Employers must meet the requirements of the Charter of the French Language in order to obtain a positive or neutral LMIA.

Employers must comply with certain additional requirements under the low-wage stream. These requirements are in addition to the general obligations of the Temporary Foreign Worker Program (TFWP).

In particular, employers must cover the cost of round-trip transportation at the beginning and end of the employment period. These costs include travel between the worker’s country of residence and their place of work in Canada. Employers must also provide, or assist the worker in obtaining, suitable and affordable housing.

What options are available to employers?

The wage increase does not affect temporary foreign workers who are currently employed. However, employers must take it into account when renewing a work permit supported by an LMIA.

Review the wage offered

When the wage offered is close to the provincial wage threshold, it may be worthwhile to assess the possibility of a salary increase. Such an increase could allow the position to qualify under the high-wage stream.

For example, consider a glazier earning $35.00 per hour and working in Montreal.

With Quebec’s new wage threshold set at $36.00 per hour, this position will now fall under the low-wage stream for the purposes of the next LMIA application. In addition, the moratorium on the processing of low-wage LMIAs will apply to this application.

By increasing the offered wage to $36.00 per hour, the position becomes eligible under the high-wage stream.

However, any such adjustment must remain compliant with the applicable wage requirements. Employers must offer a wage that is consistent with that paid to Canadian citizens or permanent residents performing the same job and possessing similar skills and experience.

An artificial wage increase intended solely to circumvent the program requirements could result in the LMIA application being refused.

When a position can be classified under the high-wage stream, employers benefit from several advantages. In particular, the work permit that may be obtained is generally valid for up to 36 months, reducing the frequency of renewal applications. In addition, recruitment requirements are less onerous, with a minimum advertising period of four weeks.

Consider relocating the work location

When a business operates multiple establishments, it may wish to explore the possibility of assigning the worker to a different work location. The employer must select an establishment located in a region that is not subject to the restrictions applicable to low-wage positions.

The Gatineau CMA has an unemployment rate above 6%. Accordingly, a work location situated outside that CMA may provide a viable alternative. An employer may therefore be able to submit an LMIA application that would otherwise not be eligible for processing.

Such an arrangement must, of course, accurately reflect the reality of the duties being performed and be agreed upon with the worker concerned.

Explore LMIA-exempt work permit options

In certain situations, it may be preferable to rely on a program that does not require an LMIA.

For example, some workers may be eligible for a work permit under the International Experience Canada (IEC) program.

Other workers who are pursuing a permanent residence application may also have access to work permit renewal options.

Conclusion

The wage threshold increase that came into effect on July 17, 2026, has a direct impact on many employers. The new threshold applies to LMIA applications submitted in support of both initial work permit applications and work permit renewals. As a result, some positions that were previously classified as high-wage now fall under the low-wage stream, which is subject to a more restrictive regulatory framework.

In this context, employers would be well advised to begin planning their renewal applications at least eight months in advance. They should also carefully assess the various strategies available to them in order to identify the option best suited to their operational needs and workforce planning objectives.

Would you like to assess the options available for your business or for one of your temporary foreign workers? Contact our professionals to obtain guidance tailored to your specific situation.