Service Canada has announced that Dual Intent Labour Market Impact Assessment (LMIA) applications submitted prior to September 26, 2024 will soon begin processing. In connection with this, employers with pending applications have received a notice requiring them to take action by September 4, 2025.

This announcement marks a significant development for employers whose PR-linked LMIA applications have been pending for a long time. However, because requirements have changed since many of these applications were originally submitted, employers may now be asked to update or supplement their documents to ensure smooth processing.

Unlike standard LMIA applications under the Temporary Foreign Worker Program, the Dual Intent LMIA is directly tied to permanent residency applications.
Given the time elapsed since many submissions, the information in the original files may now be outdated or incomplete. Common examples include:

• Worker’s name has changed or a replacement is required
• Wages offered have been modified since the original application
• Provincial employer registration certificates have expired
• Tax or payroll records submitted are from older years
• Policy changes have made previously accepted documents (e.g., attestations) no longer valid

In such cases, relying solely on the original documentation could delay or negatively impact the assessment.

The notice outlines two possible courses of action:

1. Withdraw the Application

If an employer no longer wishes to proceed, they must reply to the notice email with a brief explanation. Processing fees will not be refunded.

2. Submit Updated Information

Employers are encouraged to provide updates through LMIA Online to help expedite processing. Information that may require updating includes:

• Worker’s name – changes or replacements must be submitted using the official form (note: names cannot be altered once a decision letter has been issued).
• Wages offered – any changes must be communicated in writing to the worker and uploaded to LMIA Online.
• Recruitment efforts – additional recruitment activities and results since the original submission should be reported.
• Provincial requirements – valid employer registration certificates are required in BC, Manitoba, Saskatchewan, and Nova Scotia. (Applications submitted in Nova Scotia before July 15, 2024 are exempt.)
• Job Bank account status – accounts become “inactive” after one year of inactivity, so employers should log in and update their contact details.
• Business legitimacy documents – as of October 2024, attestations are no longer accepted; employers must provide official supporting documents.
• Tax and payroll documents – CRA-vetted documents (T2 Schedules, T4 Summaries, PD7As, etc.) must be provided, preferably from the most recent tax years.

This notice signals that the government is finally moving forward with long-delayed Dual Intent LMIA applications.
At the same time, changes to program rules mean that documents once considered sufficient may now be outdated. Employers should be aware that failing to update their applications could result in delays or adverse decisions.

Notably:

• Attestations are no longer accepted as proof of business legitimacy or ability to fulfill job offers.
• CRA official documents are now required, replacing payroll or tax records generated by accounting software.

Dual Intent LMIA applications submitted before September 26, 2024 will soon be processed.

• Employers must respond by September 4, 2025, either by withdrawing or submitting updates.
• Policy changes since 2024 mean additional documentation may now be required.
• Submitting updated information through LMIA Online is strongly recommended to avoid delays.

Employers who received this notice should review their applications carefully and update documents as needed well before the deadline.