Important Update: LMIA Recruitment Requirements for Employers Using Job Bank

Tamara M-k
Oct 25
3 min read

As of September 2025, Employment and Social Development Canada (ESDC) has introduced new requirements for employers recruiting through Job Bank as part of the Labour Market Impact Assessment (LMIA) process. As per ESDC, these changes are designed to enhance transparency and ensure fair access to job opportunities for Canadian job seekers.

Key Changes to Job Bank Recruitment Requirements

1. Mandatory Use of “Direct Apply”

Employers must use the Direct Apply feature on Job Bank.
This feature is enabled by default and allows job seekers with a Plus account to apply directly through your job posting.
Employers are required to download and review all resumes submitted via Direct Apply.
Disabling Direct Apply or failing to consider applicants who use it may result in non-compliance with LMIA recruitment efforts.
Employers can view all resumes submitted by applicants directly on their job posting from their employer Dashboard, under "Applicants and matches".

Note: If you select Direct Apply, you must also offer at least one additional application method (e.g., email, phone, mail, in person, or external website).

2. Direct Apply Resume Review Timeline

Employers must review Direct Apply resumes within 21 days of receipt.
Failure to do so may lead to your job advertisement being suspended or removed, which can disrupt your LMIA process.

3. Using Job Match

Employers must also continue to use Job Bank’s Job Match feature.
You must invite all matched candidates who meet the required star rating:
- 2+ stars for low-wage LMIA applications
- 4+ stars for high-wage LMIA applications

Primary Officer Requirement

Your Job Bank employer file must now include a business owner or director registered with the CRA as the Primary Officer.

Accounts without a valid Primary Officer may have their job advertisements suspended.
Learn how to update your employer file to include a registered owner or director.

🧾 New Business Licence Requirement

Employers who have not received a positive LMIA in the past 2 years must now submit a valid municipal business licence with their application.

If a municipal licence is not required in your area:

Submit any applicable permit or licence required to operate your business.
Some Service Canada Officers may request proof that no licence is required.

Acceptable alternative documents include:

T4 Summary of Remuneration Paid
T2 Schedule 100 & 125 (for corporations)
PD7A Statement of Account for Source Deductions
Other CRA-issued documents that demonstrate your business is active and provides goods/services in Canada

Important: Only submit documents that have been processed and issued by the CRA. Service Canada won't accept documents that have been printed and filled out from the CRA website if they haven't been submitted to and processed by the CRA.

✅ Employer Compliance Checklist

Use this checklist to ensure you're meeting all updated LMIA recruitment requirements:

Requirement	Status
✅ Direct Apply is enabled on your Job Bank posting	☐
✅ All Direct Apply resumes are downloaded and reviewed within 21 days of receipt	☐
✅ At least one additional application method is listed on the Job Bank ad	☐
✅ Job Match is used and all matched candidates are invited	☐
✅ Valid municipal business licence or acceptable alternative is submitted	☐
✅ CRA-issued documents are current and processed and issued by the CRA	☐
✅ Primary Officer is a registered business owner or director with CRA	☐
✅ At least one ad remains posted at all times until a decision is made on the LMIA	☐