Critical Job Bank LMIA Requirements

If you’re a Canadian employer navigating the Labour Market Impact Assessment (LMIA) process, understanding recent Job Bank changes isn’t optional, it’s essential. Over the past year, Employment and Social Development Canada (ESDC) and Service Canada have implemented significant updates that directly impact LMIA compliance and approval rates.

The stakes are high: Non-compliance with these new requirements can result in application refusals, wasted advertising periods, and costly delays.

Here’s what’s changed and why it matters to your business.

1. Direct Apply Is Now Mandatory for LMIA Postings

What Changed:

As of September 2024, ESDC has made it clear: employers applying for an LMIA must use the Direct Apply feature for all LMIA-related postings on Job Bank.

The Risk:

Failure to properly use Direct Apply or failure to demonstrate that you’ve correctly reviewed and documented applications can result in LMIA non-compliance and outright refusal. Immigration law firms across Canada are now advising clients that this is a make-or-break compliance requirement.

2. No More Anonymous Employers: Full Transparency Required

What Changed:

Since November 2024, Job Bank has cracked down on vague business identities. Numbered company names can no longer be used as operating names, and business names are now automatically displayed to job seekers.

The Risk:

Vague, inconsistent, or anonymous business naming raises immediate red flags for both Job Bank officers and LMIA assessors. This can trigger:

- Job Bank posting delays or declines

- Questions about business legitimacy during LMIA assessment

- Increased scrutiny of your entire application

3. Stricter Employer File Requirements: CRA-Linked Primary Officer

What Changed:

Job Bank now explicitly requires every employer file to list a business owner or director who is registered with the Canada Revenue Agency (CRA) as the Primary Officer. Until your employer file is approved, postings remain in “Pending” status and cannot be advertised.

The Risk:

If your employer file is incomplete or incorrectly configured, your job posting won’t move from Pending to Advertised. This directly impacts your ability to complete the required 4-week LMIA advertising period and can derail your entire timeline.

4. Wage Transparency and Accuracy Are Non-Negotiable

What Changed:

Job Bank median wages are updated annually (most recently November 19, 2025), and LMIA program requirements explicitly state employers must use current Job Bank wage data. Additionally, several provinces now legally require salary disclosure in job postings.

The Risk:

Posting a wage that’s doesn't meet the criteria, missing wage information where required, or showing inconsistencies between your ad and LMIA application can result in:

- Job Bank posting declines

- LMIA refusals

- Negative assessments on your recruitment efforts

5. Remote, Hybrid, or On-Site? Workplace Designation Must Align

What Changed:

Since July 2024, Job Bank requires employers to specify whether positions are Remote, Hybrid, On-site, or On the road.

The Risk:

Any mismatch between your advertised workplace type and your LMIA application details raises questions about:

- The genuineness of the job location

- Whether you’re testing the correct labour market

- Overall application credibility

Why These Changes Matter More Than You Think

These updates represent a fundamental shift: ESDC and Job Bank are tightening compliance standards and closing loopholes. The margin for error has shrunk dramatically.

The Real Problem:

Most employers don’t discover compliance issues until:

- Their Job Bank posting is declined or stuck in “Pending”

- Their LMIA application is refused

- They’ve already lost weeks or months in the process

By then, it’s too late and expensive to fix.

What You’re Up Against:

·       Complex, interconnected requirements across multiple systems

·       Documentation standards that must be perfect

·       Timing dependencies that can’t be recovered if missed

·       Regulatory language that’s difficult to interpret without immigration expertise

Don’t Risk Your LMIA Application

At Crossing Oceans Immigration Services, we specialize in ensuring Canadian employers get their LMIA applications right the first time. We stay current on every regulatory change, understand the nuances of Job Bank compliance, and know exactly what ESDC officers are looking for.

We handle:

- Job Bank employer file setup and verification

- Compliant job posting creation and management

- Direct Apply documentation and review protocols

- Wage determination and NOC classification

- Complete LMIA preparation and submission

The cost of getting it wrong far exceeds the investment in getting it right.

Contact us to Ensure Your LMIA Application Is Compliant!

Email info@crossingoceansimmigration.com

Let’s discuss your specific situation and create a compliance strategy that works.