Record
for restoration. To have these foreign workers wait another 5 month to be restored (particularly those refused in
error) is unjustified. The families are struggling to make ends meet and some are needing to now go to food
banks as their funds deplete.
Thank you.
Sent from my iPhone. Please excuse all typos and short responses.
From:
Sent: [requester]
To: [requester]<[IRCC institutional email]>; Immigration Representatives / Représentants immigration
(IRCC) <[IRCC Immigration Representatives mailbox]>; [requester]
<[requester email]>
Ce!
Subject: [requester]
urgent
[External Sender]
Dear [requester],
First and foremost, I wish you all the best for 2025! May this year bring health and
resilience as we navigate the many challenges in immigration together.
I am reaching out regarding a pressing issue that has been impacting numerous employers
and workers across Canada, particularly in essential sectors such as healthcare and the
food industry. This concem was brought to your attention during the last two IRCC-IP
meetings with CBA and CAPIC in June and December 2024. I wouldn't reach out unless the
situation had become critical.
Recently, we have observed a significant increase in preemptive refusals of Work Permit
renewal applications submitted with proof of LMIA and, when applicable, CAQ
applications in progress. In many cases, these refusals are issued within 30 to 60 days of
submission—far earlier than IRCC’s posted processing time of approximately five (5)
months. This practice disproportionately affects workers and employers already grappling
with significant delays in LMIA and CAQ processing, which have been exacerbated by the
recent changes implemented by Service Canada in September and November 2024. These
changes, in turn, appear to have triggered a surge in LMIA applications.
Key Facts to Consider
1) Processing Delays with Service Canada and MIFI
- Priority sectors such as food production, healthcare, and construction, which were
previously processed within 30 days, are now facing delays of up to four months.
- Many employers have been forced to submit LMIA renewal applications much earlier than
usual to retain their workforce, driven by extended delays and the policy changes
introduced in fall 2024.
2) Disproportionate IRCC Refusals
- IRCC is refusing Work Permit renewal applications prematurely—often within 30 to 60
days of submission—due to the absence of an approved LMIA or CAQ at the time of filing
but with the proof of such ongoing applications.
- These refusals occur without granting applicants sufficient time to provide the LMIA or
CAQ, despite IRCC’s own processing time being around five (5) months. At a minimum, an
extension should be granted for applicants to submit these documents once obtained.
3) Impact on Workers and Employers
- Temporary Foreign Workers (TFWs) who lose their status face limited and often dire
options, such as applying for a Vulnerable Open Worker Permit, filing for asylum, or
working illegally, all outcomes that are direct consequences of these practices. I have
already received calls highlighting such situations.
- Employers in critical industries are experiencing operational disruptions, jeopardizing
public services and essential production.
Request for Policy Adjustments
We urge IRCC to adopt a more flexible and compassionate approach under these
unprecedented circumstances. This is particularly vital for Canadian industries and
Temporary Foreign Workers already in Canada, who are facing challenges beyond their
control due to extended processing times with Service Canada and [requester] solutions include:
A) Extending the 60-day policy for LMIA/CAQ submission to provide sufficient time for
pending applications to be finalized.
B) Ensuring that Work Permit renewal applications are not refused prematurely when proof
of LMIA/CAQ submission is on record, recognizing that delays are beyond the control of
employers and workers.
c) Considering sector-specific impacts when making discretionary decisions, particularly in
critical industries such as food production, healthcare, construction, and naval sectors. It
appears that reconsideration requests are being denied too, even in these sectors.
Without these adjustments, Canada risks worsening labor shortages in critical industries,
disrupting essential services, and causing significant harm to both employers and workers.
Furthermore, this situation could lead to an increase in false asylum claims and misuse of
Vulnerable Worker Permit applications, further straining an already overburdened system.
Additionally, it is likely to generate a surge in multiple applications and requests, such as
restoration of status, reconsideration requests, IRCC Webform submissions, and even
deputy interventions. This scenario is neither efficient nor sustainable for [requester] a
supplementary delay to allow for the submission of LMIA and CAQ due to extended
processing times with Service Canada and MIFI would not only alleviate these pressures
but also uphold the integrity and functionality of the immigration system.
I kindly request that IRCC engage in dialogue with relevant stakeholders, including Service
Canada and MIFI, to explore viable solutions that address these impacts and ensure that
policies do not inadvertently penalize those who contribute significantly to Canada’s
economic stability. “errant
I look forward to your response and to working together on solutions that benefit all
parties involved.
Thank you for your attention to this matter.
Best regards,
0047s