Navigating LMIA Advertising Requirements: What Employers Need to Know about Job Bank Changes

Applying for a Labour Market Impact Assessment (LMIA) under the Temporary Foreign Worker Program (TFWP) requires strict compliance with advertising rules. Recent changes have made the process more complex, especially on the Government of Canada’s Job Bank, which is mandatory for most LMIA applications.  

Changes to the Job Bank have made LMIA advertising even more Kafkaesque and out of line with the reality of how recruitment is normally undertaken by employers in Canada.   

Key Updates and Challenges 

• Direct Apply Requirement: As of October 16, 2025, employers must enable Job Bank’s Direct Apply feature. However, Job Bank does not consider Direct Apply a complete application method, so employers must also provide an alternative (e.g., email or in-person or online). 

• Review Deadlines: Employers must review all Direct Apply resumes within 21 days. Failure to do so will result in ad cancellation and a 14-day posting ban. 

• Retain or Reject Applicants: Since December 3, 2025, employers must mark Direct Apply applicants as “Retained” or “Rejected” and provide reasons for rejection before extending ads. Applicants should also be added to the employer’s Recruitment Summary. 

• Consider Authorized Workers: Although ESDC requires prioritizing Canadians and permanent residents for high-wage LMIAs, Job Bank may cancel ads if you ignore other authorized workers. 

• Posting Duration: Ads can only run for 21 days at a time, but LMIA rules require 30 days of advertising. Employers must extend ads before expiry or the ads will lapse. Ads can only be extended for 14 days at a time.

• CRA Business Owner: Job Bank employer files must include the business owner or director registered with the CRA. If that is not the case, or if the primary officer that is on the account does not match the CRA records, the Job Bank will not post a job listing.  

• Prevailing Wage: Job Bank is unilaterally finding certain job postings where the posted salary is above the regional median prevailing wage for the occupation to not be genuine and cancelling the ads.

Minimum Recruitment Requirements 

Before applying for an LMIA, employers must: 

1. Advertise on the Job Bank. 

2. Use at least two additional recruitment methods targeting qualified candidates. One must be national in scope. 

3. Keep ads active for at least 4 consecutive weeks within the 3 months before applying. 

Job Match and Direct Apply 

• Job Match: Required when posting on Job Bank. Invite all candidates rated 4 stars or higher for high wage LMIAs (or 2 stars or higher for low-wage LMIAs) within the first 30 days. 

• Direct Apply: Enabled by default. Employers must review and consider all applications submitted through this feature. 

Documentation 

Employers must retain proof of advertising and recruitment efforts for 6 years, including: 

• Copies of ads with dates and locations (screenshots should be taken on a weekly basis) 

• Evidence that ads targeted qualified candidates 

• Records of other recruitment activities 

Tips for Compliance 

• Review Direct Apply resumes promptly. 

• Extend ads before they expire. 

• Ensure your Job Bank account matches CRA records. 

• Keep detailed documentation for your LMIA application. 

Where can employer see the resumes submitted by applicants via Direct Apply?   

Option 1 – From the dashboard main page  

1. Sign in to Job Bank for Employers. 

2. On the main page, go to the "Applications" section.  

3. Click the applicant’s name to open their application. It includes their resume, answers to screening questions, and other details.   

4. To save the resume, click "Download resume" and save the file to your computer.   

Option 2 – From the "Applicants and matches" section   

1. Sign in to Job Bank for Employers.  

2. In your dashboard menu, click "Applicants and matches".  

3. In the "Resumes" column, click the button showing the number of resumes received.   

4. Under the "Applications" section, click the applicant’s name to open their application. It includes their resume, answers to screening questions, and other details.   

5. To save the resume, click "Download resume" and save the file to your computer.  

Note: If the applicant used the Resume Builder tool and applied via Direct Apply, you will see a match score in the top right corner of the resume preview. This score shows how well the resume matches your job posting.