Quebec extends moratorium on low-wage TFWP LMIAs through end of 2026 — what employers and workers need to know
Quebec has extended its suspension on Labour Market Impact Assessments (LMIAs) for the low-wage stream of the Temporary Foreign Worker Program (TFWP) in the Montreal and Laval regions. The freeze — first introduced in 2024 — will now remain in effect until December 31, 2026. Employers and foreign workers in the affected areas should prepare for continued restrictions on hiring or renewing low-wage foreign workers under the LMIA-dependent TFWP for the foreseeable future.
What changed
- Extension confirmed: The moratorium on processing low-wage LMIAs for jobs located in Montreal and Laval now runs through December 31, 2026.
- Scope: The freeze applies to new LMIA applications in the low-wage stream and to LMIA renewals for existing low-wage positions in the affected regions.
- Hourly threshold: In Quebec, the low-wage threshold is $34.62 per hour (the threshold used to define low-wage vs high-wage positions in the province at the time of the announcement).
Which areas are affected
The suspension covers employers and positions located in the Montreal and Laval administrative regions, including municipalities such as:
Baie-D’Urfé, Beaconsfield, Côte-Saint-Luc, Dollard-des-Ormeaux, Dorval (and Dorval Island), East Montreal, Hampstead, Kirkland, Laval (city of), Mount Royal, Montreal West, Pointe-Claire, Sainte-Anne-de-Bellevue, Senneville, Westmount and central Montreal.
Who and what is exempt
The moratorium does not apply universally. Exemptions include:
General exemptions (apply across regions):
- Jobs located outside Montreal and Laval.
- Jobs that meet or exceed the federal high-wage threshold.
- LMIA requests already approved under Quebec’s facilitated processes (TSS) tied to an existing approved LMIA.
- LMIA applications filed before September 3, 2024.
Sectoral or occupation exemptions (Quebec):
- Agriculture
- Construction
- Food processing
- Education
- Health and social services
- Home health-care providers (for medical care and certain childcare cases)
Employers in those sectors may still be able to apply for LMIAs for low-wage positions, subject to the usual program rules.
Why this is happening
The moratorium forms part of a broader federal-and-provincial response to reduce pressure on housing and public services, and to better manage temporary resident volumes. Federal policy has also targeted low-wage LMIA processing in metropolitan areas with higher unemployment rates. Quebec’s extension underscores the province’s focus on limiting low-wage temporary worker inflows in densely populated regions while protecting certain essential sectors.
National context: how Quebec’s freeze compares to other regions
The federal government implemented a similar LMIA processing freeze in multiple Canadian metropolitan areas where unemployment exceeded predefined thresholds. While Quebec’s freeze now runs through the end of 2026, other regions across Canada have had freezes confirmed only up to earlier dates (for example, some areas listed in federal updates through early January 2026). Employers should check whether their region remains affected and for how long.
Practical implications for employers
- Recruitment planning: Employers in Montreal and Laval must plan to recruit locally or hire workers who qualify under exempt categories or high-wage thresholds.
- Budget & timelines: Expect delays or inability to secure LMIA-backed low-wage workers until at least January 1, 2027 (unless policy changes). Revisit workforce strategies and training/upskilling for local hires.
- Legal compliance: Avoid attempting to circumvent the LMIA process; non-compliance risks penalties and future LMIA refusals.
- Use exemptions where applicable: If your role or sector is exempt, prepare complete LMIA applications and evidence of exemption eligibility.
Practical implications for foreign workers
- Renewals impacted: Low-wage temporary workers in Montreal and Laval may face challenges renewing employer-specific work permits if their role depends on a low-wage LMIA.
- Explore alternatives: Workers and employers can investigate exempted sector pathways, higher-wage roles, or other immigration pathways (provincial streams, express entry-aligned provincial nomination where eligible).
- Plan long term: If you rely on a low-wage TFWP position, consider upskilling, obtaining additional credentials, or changing to an occupation that meets high-wage criteria or is in an exempt sector.
What employers and workers should do now
- Audit positions: Identify which roles are affected and whether they meet exemption criteria.
- Engage HR/legal counsel: Work with immigration counsel or HR specialists to explore alternatives (exempt LMIA streams, local recruitment, internal upskilling).
- Document recruitment efforts: If you plan to reclassify roles or seek exceptions, keep complete records of recruitment and business needs.
- Monitor policy updates: Provincial and federal lists of affected regions and exempt occupations are updated periodically — stay informed.
- Consider provincial programs: Some PNP streams or employer-driven provincial initiatives may provide alternative hiring or retention options.
Bottom line
Quebec’s extended moratorium on low-wage LMIAs for Montreal and Laval is a major constraint for employers that rely on LMIA-backed low-wage foreign labour. While exemptions protect certain essential sectors, most employers in affected regions must now pursue alternative recruitment strategies or move to higher-wage job classifications. Foreign workers should assess their status and explore other pathways where possible. The extension signals that Canada and Quebec remain focused on managing temporary resident populations and prioritizing local labour market stability over low-wage temporary hiring in high-unemployment urban areas.
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