Canadian employers considering a low-wage Labour Market Impact Assessment (LMIA) now need more lead time. Employment and Social Development Canada (ESDC) confirms that low-wage positions must be advertised for at least eight consecutive weeks before an LMIA application is submitted. The recruitment record must also show meaningful efforts to reach Canadian and permanent resident workers, including youth and underrepresented groups.
What changed for low-wage LMIA recruitment
The current low-wage program requirements state that advertising must take place within the three months before the LMIA application and must run for at least eight consecutive weeks during that period. This is longer than the previous four-week minimum. ESDC described the change in a July 9, 2026 news release as one of the measures recently implemented to strengthen recruitment and program compliance.
At least one required recruitment activity must remain active until Service Canada issues a positive or negative LMIA decision. Employers should therefore plan for both a longer pre-application period and continuing recruitment after submission. An advertisement that expires too early can create a compliance problem even if it was active for eight weeks before filing.
First confirm whether the position is low-wage
The LMIA stream is determined by comparing the offered wage with the applicable provincial or territorial hourly wage threshold. A position offered below that threshold is processed under the low-wage stream; a position offered at or above it is processed under the high-wage stream. The thresholds can change, so employers should verify the current official table when planning the application and again before submission.
The stream threshold and the prevailing-wage requirement are related but different. ESDC says the offered wage must also meet the prevailing wage for the occupation and work location. For low-wage applications, this is generally the higher of the Job Bank median wage or the wage paid to current employees doing the same job at the same location with comparable skills and experience. Raising a wage only to avoid low-wage requirements may still lead to a negative decision if the wage is not consistent with the position and workplace.
Build the required recruitment plan before the ads begin
A low-wage employer must advertise on the Government of Canada Job Bank unless a written rationale supports another permitted approach. The employer must also demonstrate recruitment directed toward youth aged 15 to 30 and use at least two additional methods that are appropriate for the occupation. The additional methods must target different underrepresented groups, such as Indigenous peoples, newcomers to Canada, persons with disabilities, vulnerable youth or asylum claimants who hold valid work permits.
The recruitment methods should have distinct value. ESDC warns that several advertisements on websites of the same type may be treated as only one additional method. Employers should choose platforms that are credible for the occupation and the intended audience, and document why each method was selected. Variations can apply to certain occupations or locations, so the general rules should not be applied mechanically when an official variation may be relevant.
Use Job Bank features actively—not as a passive posting
Job Bank participation involves more than publishing the advertisement. Employers must use the Job Match service and select the default or basic matching option. For a low-wage position, the employer is required to invite job seekers rated two stars or more within the first 30 days of the advertisement to apply.
Direct Apply is enabled by default, and applications received through it must be considered. Service Canada may review recruitment activity until the LMIA decision is issued. Employers should monitor matches and applications regularly, assess candidates consistently and retain an accurate record of the steps taken. Disabling Direct Apply or ignoring applicants may be treated as a failure to meet the recruitment requirements.
Preserve evidence of the campaign and its results
The LMIA submission should include copies of the advertisements and evidence showing where, when and how long each advertisement ran. Employers may also need to show that the selected media reached people with the education, experience or skills required for the occupation. Invoices, posting confirmations, screenshots and records of other activities—such as job fairs or outreach—can help establish the recruitment history.
ESDC requires employers to keep recruitment and advertising records for at least six years and to report the results of their efforts. A practical recruitment log should record applications received, the employer's assessment steps and the legitimate job-related reason for each hiring decision. The record should be factual, consistent with the advertisement and respectful of privacy and human-rights obligations.
Check refusal-to-process rules before spending eight weeks advertising
Some low-wage LMIA applications will not be processed even when recruitment is completed. The current rules can prevent processing where a work location is in a census metropolitan area with an unemployment rate of six percent or higher, subject to listed exemptions. Low-wage workforce caps also apply at each work location: generally 10 percent, with a 20 percent cap for specified sectors and occupations and separate rules for certain exempt positions.
The applicable unemployment-rate table, cap calculation, sector classification, work location and possible exemption should be reviewed before the employer invests time and money in recruitment. Small employers are not automatically outside the cap rules. ESDC's current guidance includes a specific calculation approach for work locations with fewer than 10 employees.
Recruitment is only one part of a complete LMIA
Service Canada also assesses whether the business and job offer are genuine, whether the position reflects a reasonable employment need, whether the employer can meet the wages and other financial obligations, and whether the employer has compliance concerns. Depending on the employer's history and circumstances, recent CRA documents, business records, payroll information, licences or provincial registration may be required.
Employers applying through LMIA Online need a CRA payroll account connected to the business number, a personal Job Bank account and a registered Job Bank employer file. Where a representative submits the application, both the representative and the employer contact must have the required access to the employer file. These account and document steps should be completed while recruitment is underway, rather than left until the planned filing date.
A practical employer checklist
Before launching recruitment, confirm the NOC code and duties, work location, offered and prevailing wage, correct LMIA stream, workforce cap and refusal-to-process restrictions. Then prepare compliant advertising language, select genuinely different recruitment methods, schedule the full eight-week period and assign responsibility for Job Bank matches, Direct Apply candidates and the recruitment log.
Before submission, review the advertisement dates and content, confirm that at least one activity will remain active, reconcile the recruitment results, and assemble the business-legitimacy and stream-specific documents. A positive LMIA is never guaranteed. Careful planning helps the employer present an accurate record and avoid preventable gaps, but Service Canada decides each application under the requirements in force when it is assessed.