As of September 2025, employers seeking a Labour Market Impact Assessment (LMIA) must now use the Job Bank’s Direct Apply feature when posting job ads.

This regulatory shift strengthens transparency and accountability in the Temporary Foreign Worker Program (TFWP) by ensuring employers engage directly with Canadian applicants before turning to foreign talent.

A key requirement is that employers must review resumes submitted via Direct Apply within 21 days. Failure to comply could result in their postings being suspended or removed, ultimately delaying LMIA applications and disrupting hiring plans.

This reform reflects the government’s goal of prioritizing Canadian workers while maintaining access to global talent when local labour shortages persist.

Breaking Down the New Rule

The Direct Apply feature is now central to LMIA-related recruitment efforts. It allows eligible Canadian job seekers to submit resumes directly through Job Bank, ensuring employers actively consider domestic applicants.

Previously, some job postings were accused of being “paper exercises” to satisfy LMIA requirements without genuine recruitment. By enforcing Direct Apply, the government aims to eliminate these practices.

Key requirements include:

• Automatic Enablement – Direct Apply is switched on by default for new postings. Employers may not ignore it.

• 21-Day Review Window – Resumes must be reviewed within three weeks, or postings risk removal.

• Multiple Application Options – Employers must provide at least one additional method (e.g., email, website form) beyond Direct Apply to ensure inclusivity.

• For low-wage positions, the broader requirement of three recruitment activities remains, including outreach to underrepresented groups.

Example in Practice

Consider a Toronto restaurant owner hiring cooks:

Under the old system, ads on Job Bank and other sites might suffice, with little proof of engagement.

Now, the employer must enable Direct Apply, review resumes within 21 days, and document all steps.

Ignoring a qualified Canadian applicant could lead to an LMIA denial during compliance reviews.

How Employers Can Stay Compliant

Posting New Jobs:

Log into Job Bank for Employers.

Fill out job details, requirements, and applicant instructions.

Ensure “By Direct Apply” is selected (default).

• Add at least one extra application method.

• Submit and publish.

• Updating Existing Postings:

• Edit the posting, enable Direct Apply, confirm another application method, then resubmit.

Managing Applications:

• Access resumes via the dashboard under “Applicants and matches.”

• Preview or download applications (both notify applicants for transparency).

• Document decisions to demonstrate compliance in case of audits.

• All resumes are stored on Job Bank for six years, simplifying record-keeping for inspections.

Impact on Employers: Pros and Cons

• Advantages: Access to a wider candidate pool, reduced recruitment costs, centralized storage, and applicant-matching insights.

• Challenges: Strict 21-day review deadlines add administrative pressure, especially for small businesses or industries with seasonal peaks.

Larger firms may adapt smoothly, but SMEs may need training or outside support to manage compliance.

Implications for Job Seekers and TFWs

For Canadian workers, this is a major win:

Faster, easier applications through Job Bank.

Assurance that employers must review resumes within 21 days.

Greater transparency, reducing the likelihood of being overlooked.

For temporary foreign workers, the rule ensures LMIAs are granted only when domestic recruitment fails. While this could add extra steps for employers, it makes TFW positions more secure and credible once approved.

International job seekers may increasingly use Job Bank to build visibility, particularly those hoping to secure LMIA-backed offers for Express Entry.

Agriculture Exception Ending Soon

Employers in primary agriculture should also note: the temporary suspension of LMIA advertising requirements ends December 31, 2025. After that, standard advertising rules will once again apply.

Final Takeaway

The mandatory Direct Apply rule for LMIAs, now in effect, is a decisive move to strengthen the integrity of Canada’s recruitment system.

By forcing genuine engagement with domestic applicants and setting strict compliance timelines, the government is balancing protection for Canadian workers with continued access to global talent when necessary.