For Employers/Employer Compliance
Risk Management

Employer Compliance

Hiring temporary foreign workers comes with legally binding obligations enforced by Service Canada. Non-compliance can result in fines up to $1,000,000, permanent bans, and public disclosure. Asteco helps employers stay compliant from day one.

Why Compliance Matters

Employers who hire temporary foreign workers through the Temporary Foreign Worker Program (TFWP) or the International Mobility Program (IMP) are subject to federal compliance requirements under the Immigration and Refugee Protection Regulations (IRPR), enforced by Employment and Social Development Canada (ESDC). Compliance inspections can occur at any time — announced or unannounced — and can be triggered by complaints, random selection, or previous non-compliance.

The consequences of non-compliance are serious. Penalties are published publicly — your business name and address appear on a Government of Canada website listing non-compliant employers. Previously issued LMIAs may be suspended or revoked. Prevention is always better than remediation.

Cannot Be Recovered from Workers

The LMIA processing fee ($1,000), the IMP employer compliance fee ($230), and any recruitment costs cannot be charged to or recovered from the temporary foreign worker under any circumstances. This is a serious violation.

ESDC Employer Contact Centre

Report changes to an approved LMIA or TFW working conditions immediately by calling 1-800-367-5693. Voluntary early disclosure is always better than having issues discovered during an inspection.

Employer Obligations Under the IRPR

Wages & Working Conditions

Pay the temporary foreign worker wages that are the same as — or not less favourable than — those in the LMIA or offer of employment
Pay raises up to the current rate of inflation may be acceptable but will be reviewed by inspectors
Provide working conditions that are the same as — or not less favourable than — those in the LMIA or offer of employment
Provide the same workplace benefits offered to Canadian employees in the same position
Make every effort to provide an abuse-free workplace
Remain engaged in the same business as described in the offer of employment for the length of the work permit

Record Keeping — 6 Years

Retain all relevant records for 6 years beginning on the first day of the period of employment for which the work permit was issued
Records must include: all documents related to the LMIA, conditions set out in the IRPR, and the LMIA decision letter and annexes
Keep records of changes in housing conditions — for example, when a TFW chooses to leave employer-provided housing
ESDC can inspect records for up to 6 years after the TFW started working — not just during the work permit period

Reporting Requirements

Inform ESDC immediately of any changes or errors with an approved LMIA — call the Employer Contact Centre: 1-800-367-5693
Report any changes in the temporary foreign worker's working conditions
Address any compliance issues promptly and consider voluntary disclosure to ESDC before an inspection occurs
Prove efforts to hire and train Canadians or permanent residents if that was a factor in the LMIA approval

Worker Rights & Protection

Never prevent the worker from leaving their employment
Never confiscate or hold the worker's passport, work permit, or other identification documents
Fulfill all LMIA commitments regarding creating and protecting jobs for Canadian citizens and permanent residents
Prove that all information provided in the LMIA application was accurate
For live-in caregivers: provide private, furnished living areas in the household
For Seasonal Agricultural Worker Program: provide adequate housing as required

Types of Compliance Inspections

ESDC can inspect employers for suspected non-compliance, previous non-compliance, random selection, or other triggers. Inspections can be on-site or virtual, announced or unannounced, and without a warrant (except private dwellings).

Document Review (Virtual)

ESDC reviews employment records, payroll documents, recruitment records, and copies of the LMIA or offer of employment remotely without visiting the worksite.

Trigger: Most common — can occur at any time, announced or unannounced

On-Site Worksite Inspection

ESDC officers visit the employer's worksite in person to verify working conditions, interview workers and employees, examine premises, and review records on site. Can be conducted without a warrant (excluding private dwellings).

Trigger: Triggered by complaints, random selection, previous non-compliance, or communicable disease at the worksite

Follow-Up Inspection

A subsequent inspection following a previous inspection where violations were found or corrective measures were required.

Trigger: Follows a previous inspection with findings of non-compliance

What Inspectors Can Do

Interview employers, employees, and temporary foreign workers
Request copies of documents and records
Take photographs, video or audio recordings during the inspection
Examine anything on the premises related to the IRPR and LMIA approval
Request access to examine computers or other electronic devices
Conduct inspections with other relevant authorities
Enter a private household with consent or with a warrant (in-home caregiver situations)
Inspect compliance with any of 29 specific conditions under the Immigration and Refugee Protection Regulations (IRPR)

The Inspection Process — Step by Step

01

Notification

ESDC notifies the employer of the inspection — including the period under review, the authority for the inspection, the conditions being reviewed, and instructions for what must be provided.

02

Review & Response

The employer must attend the inspection, answer questions, and prove compliance. Follow-up must be completed within the timeframe specified. A time extension can be requested.

03

Initial Finding

If compliance issues are found, ESDC sends an initial finding of non-compliance asking the employer to justify why they were not compliant — including what happened, what was corrected, and how recurrence will be prevented.

04

Notice of Preliminary Finding (NOPF)

If the justification is not accepted, ESDC issues a Notice of Preliminary Finding (NOPF) detailing violations and possible sanctions. The employer has 30 days to respond with new information or documentation.

05

Notice of Final Determination (NOFD)

After reviewing the employer's response to the NOPF, ESDC issues a Notice of Final Determination (NOFD) confirming the final violations, consequences, and next steps.

Consequences of Non-Compliance

Penalties are determined using a points system based on the type, severity, and history of violations. All cases resulting in monetary penalties or bans are publicly disclosed on canada.ca.

Warning

Issued for minor or first-time violations. No monetary penalty but employer must take corrective action. Business name is not published when the sanction is a warning.

Minor administrative errors
Minor record-keeping gaps
Reporting delays with no harm to workers

Administrative Monetary Penalty

Fines up to $100,000 per violation, to a maximum of $1,000,000 per year. Outstanding LMIA applications will not be processed and no refund of LMIA fees will be issued if the employer becomes ineligible due to unpaid penalties.

Underpaying wages
Failing to provide required working conditions
Significant record-keeping failures
Providing false information in the LMIA application

Permanent Ban from TFWP and IMP

A permanent ban from both the Temporary Foreign Worker Program and the International Mobility Program for the most serious violations. Previously issued LMIAs may also be suspended or revoked.

Abuse or mistreatment of workers
Serious misrepresentation in the LMIA application
Repeated and severe violations

Public Disclosure

ESDC publishes the employer's business name and address — along with details of violations and consequences — on the Government of Canada's non-compliant employers list. Business names are not published when the only sanction is a warning.

All cases resulting in monetary penalties or bans are publicly disclosed on canada.ca

How to Prepare — Before an Inspection Arrives

01

Organize Your Records

Ensure all recruitment records, payroll records, employment contracts, LMIA documents, and work permits are organized and accessible. Records must be kept for 6 years from the first day of the TFW's employment.

02

Verify Wage Compliance

Confirm every TFW is being paid wages that are not less favourable than those in the LMIA or offer of employment. Review payroll records carefully. Any pay raises should be documented with justification.

03

Review Working Conditions

Confirm working conditions match what was committed to in the LMIA — including hours, benefits, and workplace safety. Document any changes and ensure they are not less favourable.

04

Consider Voluntary Disclosure

If you identify any compliance issues before an inspection, ESDC encourages voluntary disclosure. Proactively notifying ESDC of issues can result in a more favourable outcome than having violations discovered during an inspection.

05

Contact Asteco Immediately

If you receive notice of a compliance inspection, contact Asteco before responding to ESDC. Professional guidance at this stage can significantly affect the outcome.

How Asteco Can Help

Compliance briefing at the time of LMIA or IMP approval — explaining all 29 IRPR obligations before the worker starts
Record-keeping guidance — what to keep, how to organize it, and for how long
Pre-inspection compliance review — Asteco audits your records before an inspection to identify and address gaps
Voluntary disclosure advice — if issues are identified, Asteco advises on whether and how to proactively disclose to ESDC
Representation support during inspections — Asteco advises employers through each stage of the inspection process
Response to Notice of Preliminary Finding (NOPF) — Asteco prepares a comprehensive response within the 30-day window
Corrective action plan preparation following inspection findings
Ongoing compliance monitoring throughout the work permit validity period

Disclaimer: Employer compliance requirements are established by ESDC under the Immigration and Refugee Protection Regulations and are subject to change. This page reflects requirements as published by ESDC as of March 12, 2026. Penalty amounts and inspection procedures may be updated at any time. This information is for general guidance only and does not constitute legal advice. If you receive notice of a compliance inspection, contact Asteco immediately.

Compliance Quick Facts

Record Retention6 years
Inspection WindowUp to 6 years
Max Fine per Violation$100,000
Max Fine per Year$1,000,000
Worst Case BanPermanent
Violations DisclosedPublicly
NOPF Response Window30 days

ESDC Employer Contact Centre

1-800-367-5693

Report LMIA changes immediately

Get Compliance SupportBook a Consultation