An LMIA exemption does not mean an employer is outside the compliance system. Hiring through the International Mobility Program creates obligations that continue after the work permit is issued.
The starting point is the offer submitted through the Employer Portal. The practical question is whether the job being performed matches the offer and the applicable work permit conditions.
Check what was promised against what is happening
IRCC’s employer guidance includes obligations concerning the occupation, wages and working conditions, compliance with employment laws, and a workplace free from abuse. Employers must retain documents relating to their compliance for six years from the date the work permit is issued.
For an internal review, put the submitted offer beside the employment agreement, actual duties, payroll and work schedules. Differences should be investigated. A job title alone does not explain what the employee actually does.
Keep records that can demonstrate compliance
An IMP inspection can involve requests for contracts, job descriptions, timesheets, payroll records and tax documents. Inspectors may also request business and workplace records relevant to the conditions being reviewed. Inspections are not limited to cases where a worker has complained.
Organize the records while the employment is ongoing. Reconstructing hours, duties or compensation after an inspection request arrives is a poor substitute for contemporaneous evidence.
Do not treat a change as a paperwork formality
Before changing duties, work location or compensation, assess the effect on the submitted offer, exemption category and permit. Some changes may require action before the employee works under the new arrangement. The answer depends on the actual change and the immigration conditions.
- Keep a copy of the submitted Employer Portal offer and the work permit.
- Identify who is responsible for maintaining immigration and payroll records.
- Record the actual duties and working arrangements.
- Review proposed changes before implementation.
The aim is a record that can be explained with evidence. It is not enough for the offer to look compliant if the workplace tells a different story.
I assist with employer immigration matters and LMIA-exempt work permits. Send an inquiry if you need a review of an existing or proposed arrangement.
Official sources: IRCC: responsibilities after hiring; IRCC: IMP inspections.
General information, checked October 2, 2026. The International Mobility Program and the LMIA-based Temporary Foreign Worker Program have distinct requirements.
About the author
Miguel Martins Pereirinha is a Canadian immigration lawyer and partner at Slayen Immigration Law in Vancouver, British Columbia. He practises Canadian immigration law exclusively — work permits, permanent residence, family sponsorship, citizenship and inadmissibility — and works with clients in English and Portuguese.
