IMP Employer Compliance in Canada: Portal, Inspections, and Penalties

If your Ontario business hires foreign nationals through the International Mobility Program (IMP), you are not simply a bystander after the work permit is issued. IMP employer compliance Canada obligations start the moment you submit an offer of employment and continue throughout the worker's entire stay. Falling short — even unintentionally — can result in bans, public shaming on a government website, and steep financial penalties. This guide walks you through the key obligations in plain language.

The IMP covers work permit categories that are exempt from a Labour Market Impact Assessment (LMIA) — the government review that normally requires you to prove no Canadian worker was available. Common exemptions include intra-company transfers, CUSMA (formerly NAFTA) professionals, international agreements, and significant-benefit permits. Because an LMIA is not required, the government compensates with a stricter compliance regime directly aimed at employers.

Understanding these obligations before you hire — not after an IRCC inspector calls — is what separates employers who have a smooth experience from those who face consequences. As of writing, verify all rules and figures on Canada.ca or with IRCC directly, as requirements change.

Submitting an Offer of Employment Through the Employer Portal

Before most IMP work permits can be issued, you must submit an Offer of Employment through the IRCC Employer Portal (found at Canada.ca). This is a mandatory pre-step — the foreign national cannot apply for their work permit until you have completed this step.

What the Employer Portal Requires

When logging into the Employer Portal, you will be asked to provide:

• Your business details (legal name, CRA business number, contact information)
• The foreign national's personal information
• Position details: job title, NOC code (National Occupational Classification), wage, hours of work, and province
• Duration of the proposed employment
• The specific exemption code that applies to this hire

Review these details carefully. The information you enter creates a binding record of what you promised to provide the worker.

The Employer Compliance Fee

After submitting the offer, you must pay a compliance fee to IRCC (as of writing — confirm the current amount on Canada.ca). This fee applies per offer of employment and is non-refundable, even if the work permit is ultimately refused. It funds the inspection program described below.

Once both steps are complete, IRCC generates an offer of employment number that the worker includes in their work permit application.

Ongoing Compliance During Employment

Submitting the portal offer is only the beginning. The Immigration and Refugee Protection Act (IRPA) and associated regulations impose continuing obligations on IMP employers for the full duration of the employment.

Wages, Working Conditions, and Occupation

You must provide the foreign worker with:

• The wage you promised. You cannot pay the worker less than what you entered in the Employer Portal. If you give Canadian employees a raise, the same raise must generally be extended to the foreign national in the same role.
• The working conditions you promised. This includes hours, benefits, workplace safety standards, and any other terms in the offer.
• The occupation you promised. You cannot reassign the worker to a materially different role without submitting a new offer. A software developer hired as a software developer cannot quietly be moved to a general administrative position.

You must also comply with all applicable provincial employment standards and occupational health and safety legislation for the duration of employment. In Ontario, that means the Employment Standards Act, 2000 and the Occupational Health and Safety Act.

What Happens if Circumstances Change

If the worker's role, wage, or working conditions change significantly, you should update the Employer Portal offer. Letting the situation drift without updating creates a compliance gap that can be discovered during an inspection. If you need to end the employment early, document the reasons and keep records — IRCC distinguishes between layoffs that are genuinely beyond your control and reductions designed to cut costs at the worker's expense.

IRCC Employer Inspections

IRCC has the authority to inspect any IMP employer to verify compliance. Inspections are not rare events reserved for bad actors — they are built into the program design. IRCC can select employers:

• Randomly, as part of a routine audit cycle
• Based on tips or complaints from workers, unions, or community organizations
• Because a risk indicator was flagged during the work permit review

What Inspectors Look For

During an inspection, IRCC may ask you to produce:

• Payroll records showing wages actually paid
• Time sheets and records of hours worked
• Employment contracts and offer letters
• Workplace policies (vacation, overtime, sick leave)
• Records of any changes to the worker's role or compensation
• Proof of compliance with provincial employment standards

Inspectors typically request documentation in writing first. If you cannot produce adequate records, IRCC may conduct an on-site visit or interview the worker directly. Responses are usually required within a tight deadline — often 30 days or less.

Consequences of Non-Compliance

Non-compliance under the IMP can have serious, lasting consequences. IRCA and IRCC's compliance program give the government broad enforcement powers.

Administrative Monetary Penalties (AMPs)

IRCC can impose Administrative Monetary Penalties (AMPs) — financial fines — for each violation found during an inspection. Penalty amounts depend on the type and severity of the violation and your employer size. Multiple violations in a single inspection can result in multiple penalties assessed at the same time. As of writing, confirm current penalty amounts on Canada.ca, as the scale is periodically updated.

Bans on Hiring Foreign Nationals

Beyond fines, non-compliant employers can be banned from hiring foreign nationals through either the IMP or the Temporary Foreign Worker Program (TFWP) for a fixed period. A ban effectively shuts down your ability to hire internationally — a significant operational consequence for businesses that depend on skilled foreign workers.

Publication of Non-Compliant Employers

IRCC publishes the names of employers found non-compliant on its website. This public naming is a significant reputational risk. The list is publicly searchable and can affect your standing with clients, partners, and future employees.

Best Practices for Record-Keeping

Compliance is largely a documentation problem. Employers who face the worst outcomes are often those who were doing the right thing but had no paper trail to prove it. Practical steps:

• Keep payroll records for at least six years after the foreign national's last day of work (align with standard CRA retention rules as a minimum).
• Document every change to wages, hours, or duties in writing at the time it occurs — not retroactively.
• Cross-reference your Employer Portal submissions against actual employment contracts before the worker arrives so there are no gaps between what you promised and what you offer on paper.
• Conduct internal audits annually if you regularly hire through the IMP. Compare portal data to payroll records.
• Train your HR team on the difference between IMP and LMIA-based hires and what each requires.
• Do not destroy records if you receive an inspection notice — document retention obligations are triggered from that point.

If you use a staffing agency or third-party recruiter, remember that the compliance obligations rest with the employer of record — the entity named on the Employer Portal offer. You cannot delegate compliance away by outsourcing the hire.

Frequently asked questions