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Immigration News Alert

Canada Proposes Language Rules for IMP Work Permits

Key Points 

  • Pending regulatory review, Canada may require third-party language test results for certain work permit applicants under the International Mobility Program (IMP) 

Language Testing Under the IMP 

Canada announced a proposed amendment to the Immigration and Refugee Protection Regulations that would introduce mandatory third-party language proficiency testing for certain applicants under the International Mobility Program (IMP). 

According to the government, the change aims to improve language assessments and better align work permit approvals with labor market integration and long-term residency potential. While the requirement may reduce the pool of eligible candidates, the government expects that it will create business confidence and support long-term workforce retention.   

Envoy Global on the Proposed IMP Route Language Testing Requirements  

According to Envoy Global’s Canada Team Lead and Licensed Practitioner Daphne Wong, if implemented, the new requirement would hold significant consequences.

Visa-exempt applicants who would usually benefit from faster processing at a port of entry would be the most impacted, given that applications for them would typically require less paperwork and are quicker to turn around. Visa-requiring applicants typically take longer to submit due to additional supporting documentary requirements, which are country-specific, and may not be as impacted from a timeframe perspective. All applicants, despite most likely being fluent in English or French already, would then need to complete a language test in advance, which could impact urgent travel timelines and impact business deliverables.

To further complicate matters, applicants who may not have strong language skills but who are extremely specialized in particular trades or professions would also be greatly impacted, as would their prospective employers in Canada, who may not have the skillsets from the local market available to meet their business needs.

In time-sensitive situations, employers may need to consider alternative approaches, including:

  • Short-term work permit exemptions (if qualified).
  • Utilizing existing personnel within Canada (such as citizens, permanent residents or already authorized foreign workers).
  • Prior to selecting an individual for transfer or hire, conducting an internal review of suitable candidates who may already have language testing completed, that is approved by the Canadian government.

It’s also worth noting that limited appointment availability at language test centers could further extend timelines for both testing and result processing, thereby impacting the actual date of the work permit application submission and subsequent adjudication of the work permit application.

Looking Ahead at the Proposed IMP Language Testing Changes  

Consultations with provinces and territories were completed in February 2025, and further engagement with stakeholders is anticipated in spring/summer 2025. The proposed amendments are expected to be pre-published in the Canada Gazette, Part I, with a 30-day comment period during the same timeframe. 

Envoy Global will continue to track this development and provide updates as more information becomes available. 

Content in this publication is for informational purposes only and not intended as legal advice, nor should it be relied on as such. Envoy Global is not a law firm, and does not provide legal advice. If you would like guidance on how this information may impact your particular situation and you are a client of the U.S. Law Firm, consult your attorney. If you are not a client of the U.S. Law Firm working with Envoy, consult another qualified professional. This website does not create an attorney-client relationship with the U.S. Law Firm. 

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