IRCC has updated its International Mobility Program (IMP) instructions for employer-specific work permits and employer compliance inspections. The September 18, 2026 changes reflect the current IMP Employer Portal attestation wording and align IRCC’s processing guidance with its revised approach to assessing the genuineness of job offers. If your business hires temporary foreign workers through the IMP, this is an important time to review your Employer Portal submissions, attestations, and employment records.
Employers should prioritize their IMP Employer Portal attestation to ensure compliance with IRCC requirements.
What Changed in IRCC’s September 2026 Update.
Understanding the implications of your IMP Employer Portal attestation can prevent compliance issues.
IRCC updated two related instruction pages: Employer-specific work permits – General processing – International Mobility Program and Employer compliance inspections. The updates reflect the current employer attestation text in the Employer Portal, correct outdated information, and align the instructions with the September 17 update on assessing the genuineness of an offer of employment.
For IMP employers, the practical effect is that the Employer Portal submission, the employer’s attestations, and the employer’s actual employment practices must remain consistent. IRCC uses this information when processing work permit applications and when assessing whether an employer is meeting its obligations.
Why the IMP Employer Portal Attestation Matters
When an IMP employer submits an offer of employment through the Employer Portal, the employer confirms important information about the position and accepts responsibilities related to hiring a temporary foreign worker. The Employer Portal is the system through which employers submit offers of employment for many LMIA-exempt workers under the IMP.
The attestation is not simply a formality. It connects the employer’s stated offer to its later compliance obligations. If the job details, wages, duties, workplace, or employment conditions in the Portal do not match the employer’s actual business or the worker’s employment, the employer may face questions during processing or a future compliance inspection.
What IMP Employers Should Review
Employers should review both current and recent Employer Portal submissions. This is especially important for businesses that have submitted multiple offers, changed job duties, changed locations, or used templates without checking whether the details still reflect the actual position.
Employer Portal details to check
Ensure your IMP Employer Portal attestation is clear and accurately reflects the job offer.
- Employer legal name, business address, and contact information.
- Job title, National Occupational Classification (NOC), and job duties.
- Wages, hours of work, benefits, and other conditions of employment.
- Work location and whether the role is performed on-site, remotely, or in more than one location.
- Employment start date and expected duration.
- Whether the employer attestation reflects the current Portal wording and the employer’s actual situation.
Employment records to keep ready
- Signed employment agreement or offer letter.
- Detailed job description.
- Payroll records, pay stubs, and records of hours worked.
- Records showing that wages and working conditions match the submitted offer.
- Business licence, permits, or other evidence that the business is operating.
- Correspondence, recruitment records, or other documents that explain why the position was needed.
IMP Employer Compliance Inspections: What to Expect
Timely updates to your IMP Employer Portal attestation can prevent potential compliance issues.
The updated employer compliance inspection instructions reinforce that IMP employers may be inspected after hiring a temporary foreign worker. Inspections help IRCC confirm that employers understand and meet their responsibilities, use the IMP properly, and protect temporary workers.
An inspection may be random or triggered by a concern. If IRCC selects an employer for inspection, the employer may be asked to provide documents, answer questions, or participate in an on-site visit.
Documents IRCC May Request
IRCC may ask for documents such as:
- The job description and employment contract.
- Time sheets and payroll records.
- The temporary worker’s T4 Summary of Remuneration Paid.
- The employer’s business licence or permit.
- Other records showing that the worker received the wages and working conditions stated in the offer.
If more than one employer was involved in hiring the worker, the employer that submitted the offer of employment is generally the employer IRCC will contact. That employer may be required to provide requested documents, including documents from other employers involved in the hiring process.
What Happens If IRCC Finds Non-Compliance
If IRCC identifies a violation, the employer will generally have 30 days from the date of the letter to respond about the alleged violation or proposed penalties before IRCC makes a final decision.
A response should be factual, organized, and supported by documents. Employers should not assume that a minor administrative issue will be ignored. Keeping accurate records from the beginning is usually the best way to demonstrate compliance.
Timely updates to your IMP Employer Portal attestation can prevent potential compliance issues.
How This Connects to Job-Offer Genuineness
The September 18 updates were made partly to align IMP processing with IRCC’s revised instructions on assessing the genuineness of an offer of employment. That earlier update separates the assessment steps for the IMP and Temporary Foreign Worker Program, adds a procedural fairness process for obtaining employer information when genuineness concerns arise, and addresses the handling of extrinsic information.
For employers, the message is consistent across both updates: the information provided to IRCC should accurately reflect the real employment opportunity. A carefully prepared Employer Portal submission can support the work permit application and may also help the employer respond if questions arise later.
A well-prepared IMP Employer Portal attestation is essential for a smooth application process.
For a detailed explanation of how IRCC assesses whether a job offer is genuine, read: [IRCC’s New Job-Offer Genuineness Rules: What Canadian Employers and Work Permit Applicants Need to Know].
Practical Checklist for IMP Employers
Use this checklist to review your current compliance position:
- Confirm that every active Employer Portal offer matches the actual job being offered.
- Compare the Portal submission with the offer letter, employment contract, and job description.
- Ensure wage, hours, duties, and location details are accurate and current.
- Keep payroll and timekeeping records that show workers are paid as promised.
- Retain business records that demonstrate active operations and a genuine employment need.
- Monitor IRCC correspondence and respond to information requests before deadlines.
- Review internal processes for preparing, approving, and storing Employer Portal submissions.
Key Takeaways for Employers
- IRCC has updated IMP employer-specific work permit and compliance instructions to reflect the current Employer Portal attestation wording.
- Employers should ensure their Portal submissions match the actual job offer and employment records.
- IMP employer compliance inspections can occur after hiring, and employers may be asked for payroll, contract, and business records.
- The updates align IMP processing with IRCC’s revised job-offer genuineness guidance.
- Accurate attestations, organized records, and prompt responses to IRCC requests are essential for reducing compliance risk.
Review your IMP Employer Portal attestation regularly to maintain compliance with IRCC.
Need Help With Your IMP Employer Portal Attestation?
If you employ foreign workers through the International Mobility Program, our office can help you review your Employer Portal attestation, job-offer documentation, and compliance readiness. Contact us for a consultation.