ESDC tightens who counts as your "genuine employer." Here's what it does to work-permit-linked jobs.

What happened. On September 18, Employment and Social Development Canada added a new "Employers" sectionacross the Temporary Foreign Worker Program's main streams: high-wage, low-wage, the Global Talent Stream, the Agricultural Stream, the Seasonal Agricultural Worker Program, the in-home caregiver program, LMIAs that support permanent residence, and the Recognized Employer Pilot. The guidance spells out in far more detail how Service Canada decides which business is actually your employer.

What it does to your status. The guidance sets out circumstances where an arrangement doesn't meet the genuine-employer requirement. A staffing or employment agency can't hold the LMIA for a job where another business actually directs your work, and an employer that gets your LMIA approved can't later ask you to invoice as an independent contractor instead of staying on payroll; ESDC treats that as a compliance failure even if nothing else about the job changes. What decides it isn't which business's name is on the paperwork. It's who actually controls, supervises, pays and can dismiss you. If your job runs through an agency, a subcontractor, or a related company rather than the business you actually report to, that's exactly the gap this guidance is built to test.

What it means. The risk is immediate for anyone whose employer is applying for an LMIA, or whose work permit depends on a new one. Because the guidance also covers LMIAs supporting permanent residence, the employer relationship can matter beyond the immediate work permit.