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“Carry-on only” – Brief updates in immigration law

By Jonathan Mor and Heelan Kwon
August 26, 2025
  • Employment Standards
  • Immigration
  • Labour
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Quick reads for short trips

Introducing “Carry-on only,” a new series designed to provide updates on immigration law and policy in five minutes or less.

Changes to the Ontario Immigrant Nominee Program

Canada’s current immigration level and future targets have recently been a popular topic of discussion in the media, as well as an area of focus for our new government. Indeed, in his first Mandate Letter, Prime Minister Carney provided a list of his government’s priorities, which included “[a]ttracting the best talent in the world to help build our economy, while returning our overall immigration rates to sustainable levels.”[1]

Consistent with this mandate, the 2025–2027 Immigration Levels Plan published by Immigration, Refugees and Citizenship Canada (IRCC) seeks a decrease in overall permanent resident admissions to 395,000 in 2025, 380,000 in 2026 and 365,000 in 2027.[2] The reduction in targets for permanent resident admissions has affected all of Canada’s economic immigration programs, with corresponding changes made to various eligibility requirements and program quotas.  

With respect to the programs administered under the federal Express Entry system, one particular change has attracted a great deal of attention from employers and skilled temporary foreign workers alike. Since its inception, Express Entry has awarded additional points to a candidate’s Comprehensive Ranking System score for a qualifying offer of arranged employment. Most recently, those with a qualifying offer of arranged employment in an executive position garnered an additional 200 points, while all other skilled foreign workers were awarded an additional 50 points. 

The availability of these points was critical to many candidates seeking permanent residence in Canada, and often ensured that their score was high enough to qualify for an Invitation to Apply. However, as of March 25, 2025, points are no longer awarded for a qualifying offer of arranged employment.[3] This change (among others) has made it more difficult to seek permanent residence under Express Entry.

As a result of the increased difficulty of seeking permanent residence under Express Entry, we have seen a renewed interest in other economic immigration programs in Canada. In particular, the programs administered by provincial and territorial governments, such as the Ontario Immigrant Nominee Program (OINP), have recently become more popular with foreign workers.

In light of the above, employers and foreign workers in Ontario should take note of several program changes that have recently been made to the OINP. These include the following:

  1. While most streams of the OINP require support from a qualifying employer in Ontario, the application process has always been primarily driven by the foreign worker. However, as of July 2, 2025, employers seeking to support a foreign worker under the OINP’s Employer Job Offer streams are now required to register for the new Employer Portal. This portal is used to register the employer’s business, as well as submit information regarding the job offer and supporting documents directly to the OINP. Significantly, an applicant is no longer able to register an expression of interest under an Employer Job Offer stream until their employer has successfully submitted a “job offer” through the OINP Employer Portal.[4]
  2. The OINP has always been afforded broad discretion under the Ontario Immigration Act (2015, S.O. 2015, c. 8) to conduct inspections and investigations in order to ensure program integrity. Indeed, administrative penalties may be enforced in the event of non-compliance. It is important to be aware that the OINP now has the additional authority to require in-person interviews for foreign workers and their supporting employers for purposes of substantiating the application during the review process.
  3. The OINP has recently been given the authority to return applications before a provincial nomination has been issued, even if the underlying eligibility requirements have been met. The decision to return an application may be based on a variety of factors, including nomination allocation, alignment with Ontario’s most pressing labour market needs, and program integrity risk factors.

Given the renewed interest in the OINP and the recent changes made to the program, it is critical that employers in Ontario familiarize themselves with current program requirements. Particular attention should be paid to those requirements that govern an employer’s role and responsibilities under the OINP, as well as the consequences of non-compliance.

For more information, please contact Jonathan Mor and Heelan Kwon.


[1] See https://www.pm.gc.ca/en/mandate-letters/2025/05/21/mandate-letter.

[2] See IRCC’s Notice – Supplementary Information for the 2025-2027 Immigration Levels Plan.

[3] See the IRCC’s Ministerial Instructions Amending the Ministerial Instructions Respecting the Express Entry System, 2025-1

[4] See the OINP’s Employer Portal user guide.

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Jonathan Mor

About Jonathan Mor

Jonathan Mor is a partner in our Employment and Labour group, specializing in cross-border business immigration law. With extensive experience practicing both Canadian and US law, Jonathan has successfully handled complex immigration matters for corporate clients of every size, from multinational companies with well-established affiliates all over the world, to partnerships, sole proprietors and professionals.

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Heelan Kwon

About Heelan Kwon

Heelan Kwon is an immigration senior associate in our Employment and Labour group. Heelan has significant experience assisting clients navigate the Canadian immigration landscape. She has delivered immigration solutions to corporate clients ranging from Fortune 100 multinational companies to local start-ups and individual professionals. Her clientele has spanned various industries including the technology, manufacturing, financial, engineering, aerospace, defence and professional services sectors.

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