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Effective September 2025, Canadian employers must utilize the Job Bank's "Direct Apply" feature for all Labor Market Impact Assessment ("LMIA") related job postings. This is a fundamental shift from optional to mandatory usage, designed to enhance transparency and prevent fraudulent practices. The Direct Apply mandate creates new procedural obligations and documentation requirements that employers must integrate into their current recruitment protocols.
Employers must actively review and consider all applications received through this Direct Apply function, and failure to do so may result in denial of the LMIA. They should continue to advertise for a minimum of four consecutive weeks on the Job Bank plus two additional recruitment methods.
Strategic Implications
The requirement reflects Canada's intensified focus on labor market testing integrity and prioritization of domestic workers. The Direct Apply requirement creates an audit trail of genuine recruitment efforts while standardizing application processing.
This change necessitates enhanced coordination between HR teams, global mobility functions, and legal counsel to elevate documentation standards and implement more robust evidence of recruitment efforts and application review processes.
Counsel Michelle Muñoz-Machen was a contributing author to this client alert.
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