On March 25, 2025, Immigration, Refugees and Citizenship Canada (IRCC) implemented a significant change to the Express Entry system: candidates looking for permanent residency will no longer receive Comprehensive Ranking System (CRS) points for having a valid job offer supported by a Labour Market Impact Assessment (LMIA) or by an LMIA-exempt work permit. As a result of this change, many Express Entry profiles have significantly lower scores, making these profiles uncompetitive. Affected foreign workers may no longer be in a position to rely on Express Entry as a path to permanent residency.1
WHY THIS MATTERS
- Candidates who were previously eligible for an additional 50 or 200 CRS points for arranged employment will no longer benefit from this advantage. As a result, they will have scores that are lower than the threshold required to be invited for permanent residence.
- This change will have a considerable impact on executives and other skilled workers who relied on these points to remain competitive in the Express Entry pool as their profiles will have scores well below the cut -off.
- The removal of arranged employment points may reduce overall CRS cut-off scores, though not necessarily enough to benefit all affected applicants. If the CRS cut-off scores do not decrease significantly, many foreign workers will not be in a position to secure permanent residence through Express Entry.
- The change does not impact:
- candidates who submitted a permanent residence application before March 25, 2025, or
- candidates who received an Invitation to Apply (ITA) before March 25, 2025, and have not yet submitted their application.
Background
This policy change follows the government of Canada’s 2025–2027 Immigration Levels Plan, which lowered annual permanent-residence targets to 395,000 (2025), 380,000 (2026), and 365,000 (2027) respectively (for prior overage, see GMS Flash Alert 2024-210, October 25, 2024).
According to IRCC, the elimination of arranged employment points is intended to address abuse of the LMIA system and foster fairness in the Express Entry program.
KPMG INSIGHTS
There are several actions steps that employers may wish to consider:
- Reviewing their foreign worker population could help establish which individuals may be affected.
- Engaging immigration counsel early, particularly for senior executives, long-term transferees, and those who may now be at risk of falling short of Express Entry thresholds.
- Considering alternative PR pathways, and in conjunction with immigration counsel, determine the appropriate steps forward. Other pathways might include Provincial Nominee Programs (PNPs). (However, note that PNP allocations have also been reduced. Furthermore, PNP programs require employer support and warrant additional compliance considerations.)
- Evaluating work permit extension options for employees whose status is expiring and who may require more time to explore permanent-residence strategies.
- Offering additional support for long-term transferees who have purchased property and were intending to apply for a rebate of the Foreign Buyers Tax after becoming permanent residents.
- Developing a communications strategy with respect to informing affected stakeholders
The path to permanent residence is expected to become more competitive in the coming years, requiring employers to actively support their temporary foreign worker population. When key foreign talent has the necessary support to remain in Canada, employers can can help foster their agility in a competitive labour market.
Individuals or employers with questions or concerns about the new measures are encouraged to contact thir usual immigration counsel or a member of the immigration team with KPMG Law LLP (see the Contacts section) for further guidance.
FOOTNOTE:
1 IRCC, in a December 23, 2024 press release, characterized this change as a “temporary measure.” See IRCC, "Canada takes action to reduce fraud in Express Entry system" (December 23, 2024). The March 25, 2025, Ministerial Instructions made this change official.
Contacts
More Information
Disclaimer
* Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.
The information contained in this newsletter was submitted by the KPMG International member firm in Canada.
GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.
© 2025 KPMG LLP, an Ontario limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.