Québec’s Simplified LMIA Process: Significant Changes for Employers in 2025

On February 24, 2025, the Ministère de l’Immigration, de la Francisation et de l’Intégration (MIFI) released a revised list of occupations eligible for the facilitated Labour Market Impact Assessment (LMIA) process under the Temporary Foreign Worker Program (TFWP) for foreign workers destined for Québec. This update marks a substantial shift in immigration policy, reducing the number of qualifying occupations from 267 to just 76. Québec employers relying on foreign talent to address labor shortages must take note of these changes and adjust their workforce planning accordingly.

Overview of the Facilitated LMIA Process in Québec

The TFWP allows Canadian employers to hire foreign nationals to fill temporary positions when qualified Canadian candidates are unavailable. Typically, employers must obtain an LMIA—a process that involves demonstrating a labor shortage through specific recruitment efforts, adhering to prevailing wage standards, providing private health insurance (where applicable), and covering all associated fees.

To streamline this process for occupations with well-documented shortages, the Canadian government offers a facilitated LMIA process. Under this simplified framework, employers are exempt from the standard four-week job posting requirement, reducing both the time and cost of hiring foreign workers. In Québec, this fast-track option has historically offered expedited processing by Service Canada, making it an attractive tool for employers across various sectors.

Until February 23, 2025, Québec’s facilitated LMIA list was expansive, encompassing 267 occupations across all levels of Training, Education, Experience, and Responsibilities (TEER). However, the updated list reflects a dramatic reduction, signaling a shift in provincial priorities regarding temporary foreign workers.

Key Changes to Québec’s Facilitated LMIA List

The revised list, effective February 24, 2025, introduces significant restrictions:

1. Reduced Scope: The number of eligible occupations has dropped from 267 to 76—a nearly 75% reduction.
2. Exclusion of Certain TEER Levels: Managerial positions (TEER 0), intermediate roles requiring only high school or job-specific training (TEER 4), and labor jobs with no minimum education requirements (TEER 5) are no longer eligible.
3. Targeted Sectors: The new list focuses on specific high-demand fields, including:
   • Engineering: Civil, mechanical, and industrial engineers; technologists and technicians.
   • Health Care: Social workers, general practitioners, specialists (e.g., psychologists, physiotherapists), nurses, pharmacists, and physician assistants.
   • Information Technology: Programmers, systems analysts, and software engineers.
   • Construction: Electricians, welders, and machinists.
   • Education: Early childhood educators, kindergarten, primary, and secondary school teachers.
   • Food Industry: Cooks, butchers, bakers, and food service supervisors.

The updated list aligns with the 2021 National Occupational Classification (NOC) system, which categorizes occupations with specific codes. Some eligible job titles are marked with an asterisk, indicating that only those specific roles qualify—not all titles under the corresponding NOC code.

Implications for Québec Employers

This overhaul of the facilitated LMIA process will reshape how Québec employers address labor shortages through the TFWP. Key impacts include:

• Limited Access to Fast-Track Processing: With fewer occupations eligible, many employers will need to revert to the standard LMIA process, which requires more extensive recruitment efforts and longer processing times.
• Exclusion of Key Roles: The removal of managerial, intermediate, and labor-level positions means employers in these areas must explore alternative immigration pathways or rely more heavily on domestic talent.
• Increased Recruitment Burden: For roles no longer covered by the simplified process, employers will need to conduct and document robust recruitment activities to satisfy LMIA requirements.
• Strategic Workforce Planning: Businesses must reassess their hiring strategies, particularly for renewing the status of current temporary foreign workers or onboarding new candidates.

What Employers Can Do Next

Québec employers should act swiftly to adapt to these changes. Here are some practical steps to consider:

1. Review the Updated List: Confirm whether the occupations you rely on remain eligible for the facilitated LMIA process.
2. Explore Alternatives: Programs like the International Mobility Program (IMP) offer LMIA-exempt work permit options that may suit your needs.
3. Enhance Recruitment Efforts: For roles now excluded from the simplified process, prepare to meet the stricter requirements of the regular LMIA stream.
4. Consult Immigration Experts: Partner with legal professionals to ensure compliance and optimize your immigration strategy.