As of July 2, 2025, the Ontario Immigrant Nominee Program ("OINP") has officially launched a new digital Employer Portal. By way of context, the OINP's Job Offer Stream allows foreign workers to apply for permanent residency in Ontario if they have a full-time, permanent job offer in a skilled occupation (TEER 0, 1, 2, or 3) in Ontario.
OINP Job Offer Stream's Requirements
If the applicant is in Canada, they must have valid legal status at the time of application and must continue to maintain valid legal status until the time of nomination.1 The applicant's employer must have actively been operating its business for at least three years; have business premises in Ontario; meet the minimum revenue requirements of $1 million in total gross annual revenue if the work location is in the Greater Toronto Area ("GTA") or $500,000 if outside the GTA; employ at least five full-time employees who are Canadians or permanent residents if the work location is in the GTA or at least three full-time employees if outside GTA; and offer the foreign worker at least the median wage level for the occupation in the specific work location in Ontario.2 Furthermore, where applicable, the employer may be required to demonstrate that reasonable efforts were made to recruit a qualified Canadian or permanent resident before offering the permanent job offer to the foreign worker.3
The Employer is Now in the Driver's Seat
Previously, the foreign worker (applicant) would initiate OINP's Job Offer Stream process by creating an Expression of Interest ("EOI") that included the job offer details and, if invited to apply, would submit the full nomination application. The employer would then provide the foreign worker with the necessary documentation and information to submit directly to the OINP.
Moving away from the previous applicant-led model, the new process requires employers to take the first step by creating a My Ontario account, registering their business, and submitting a detailed job offer before any job candidate can register an EOI. This shift applies to all positions offered through the Foreign Worker, International Student, and In-Demand Skills streams.
Under the new system, employers should have exclusive control over the employer-based aspects of the application. The Employer Portal guidelines specify that only employers may complete the employer registration and submit the details of the business and job offer (i.e., this process can no longer be done by the applicant).
More Discretion and Greater Scrutiny to Protect Program Integrity
Per the Ontario Regulation 421/17 Approvals under the Ontario Immigrant Nominee Program and Other Matters,4 the OINP may suspend receiving applications or return applications and application fees for which a decision has not been made, based on the following factors:
- allocation of nomination spots;
- volume of applications received and their pending decisions;
- target number of number of approvals in the calendar year;
- Immigration, Refugee and Citizenship Canada's case volume and status for processing permanent residence applications;
- immediate labour market needs of Ontario; and
- immigration compliance or enforcement concerns.
Furthermore, OINP may request in-person interviews for both employers and foreign workers to address any issues concerning credibility and authenticity of applications.5
Employer Support for OINP
Employers should be aware that the process is now front-loaded with responsibility and tight timelines. To prepare, employers are encouraged to proactively identify candidates they plan to support, gather necessary documentation in advance, and ensure internal users are trained on the Employer Portal's functionality.
This shift represents a meaningful change to employer obligations under the OINP and will require proactive internal coordination. Employers seeking guidance or support during the transition can contact reach out to our McMillan's immigration team for assistance in adapting their internal processes to meet the new requirements.
Footnotes
1 Approvals Under the Ontario Immigration Nominee Program and Other Matters, O Reg 421/17.
2 Government of Ontario, "2025 Ontario Immigrant Nominee Program Updates" (2 July 2025), online.
3 Government of Ontario, "OINP Employer Job Offer: Foreign Worker Stream" (2 July 2025), online.
4 Ibid.
5 Ibid. See "Reasonable recruitment efforts".
The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.
© McMillan LLP 2025
