We’re proud to start the year with the news that MWC has been certified once again as a Living Wage Employer by Living Wage BC, reaffirming our ongoing commitment to fair and equitable compensation. This year’s certification confirms that we meet the 2026 Metro Vancouver Living Wage rate for every member of our team.

Being a Living Wage Employer means more than meeting a wage threshold, it reflects our belief that fair pay is essential to employee well-being, stability, and long-term success.

A living wage* is the hourly rate required to cover everyday essentials such as:

• Food and clothing
• Rental housing
• Childcare
• Transportation
• Modest savings to support unexpected illness or emergencies

*The living wage calculation is based on a two-parent household with two children—the most common family structure in BC—with both parents working full-time. Because costs differ across the province, living wage rates vary by region.

By maintaining this certification, MWC joins a growing network of employers across BC who are taking meaningful action to support their employees and local communities. Living Wage BC also works to advance public policies that help families better manage the rising cost of living.

Click here to learn more about Living Wage BC and discover other organizations committed to paying a living wage.

MWC’s Board Chair, Mary Grace de Guzman, worries about how IRCC’s announcement will negatively impact migrant care workers. “As a former migrant care worker, I feel disappointed hearing this news. I know that there were a lot of care workers waiting for this program to open with the hope that their lives and futures in Canada would finally become stable. This pause will leave the most vulnerable workers in limbo”, says Ms. De Guzman.

The HCIP replaced the Home Support Worker (HSW) and Home Child Care Provider (HCCP) Pilots that ran from 2019 to 2024. Under the HSW and HCCP, care workers came to Canada with sector specific work permits, finished the required amount of work, and then submitted their work experience to IRCC for final processing. The HSW and HCCP also allowed workers who were already in Canada under the Temporary Foreign Worker Program to apply.

When the HCIP was announced, it offered reduced education and language requirements, the high expectations for which prevented many workers from applying under the previous programs. The HCIP also offered permanent residence on arrival for workers who qualified for the program and were not already living in Canada. However, no spots were ever actually opened under the Permanent Residence on Arrival category. Only workers already living and working in Canada were allowed to apply in March 2025.

When the HCIP opened on 31 March 2025, the spots were extremely limited and filled up within minutes. Many hopeful applicants reported being shut out by technical issues and IRCC system crashes before then learning that spots were filled. Workers who tried unsuccessfully to apply in 2025 have been eagerly waiting for the program to reopen. Many migrant worker groups anticipated that the program would reopen on 31 March 2026. In their recent announcement, IRCC did not mention when the pause would end and they have not provided any assurances to workers that it will.   

IRCC’s announcement has left many care workers who are already living and working in Canada feeling abandoned. Ms. De Guzman states, “I am crying for these workers. It is just so unfair to treat us like this after we have contributed so much to Canada. The government keeps breaking its promises to care workers”.

MWC’s Legal Director, Jonathon Braun, shares Ms. De Guzman’s frustrations. He states, “Migrant care workers must often leave their own families to take care of Canadian children and elderly. For many of these workers, a pathway to permanent residence was a pathway to being reunited with their own families. IRCC’s announcement means that these families will continue to be torn apart”. He continues, “It is absolutely gut-wrenching. The very least that our government can do for these workers in thanks for their sacrifice is to provide a safe and reliable pathway to permanent residence. Instead, our government has betrayed migrant care workers”.

“If the government wants to make things right for our vital migrant care workers, they need to reopen the program immediately and ensure that all migrant care workers in Canada can apply”, says Mr. Braun.

For more information, please contact MWC’s Legal Director, Jonathon Braun, at 604-446-2561.

Migrant Workers Centre is devastated and appalled by this news. We will be advocating for the government to keep its promise to care workers and reopen the program. We encourage allies to reach out to their government officials and do the same.

IMPORTANT: Care Workers with Occupation Specific Work Permits are NOT affected by this news. If you have an Occupation Specific Work Permit under the Home Child Care Provider and Home Support Worker Pilots, you can still submit your work experience to IRCC to continue your Permanent Residence Application processing.

In the coming days, MWC will be publishing a full press release about the unnecessary harm caused by this decision.

There are two key pieces of legislation referenced in this document:the Immigration and Refugee Protection Act (“IRPA” or the “Act”) and the Immigration and Refugee Protection Regulations (“IRPR” or the “Regulations”).

“Unauthorized work” includes working without a valid permit (such as while on a visitor record) or violating the conditions of a permit, such as working for an unauthorized employer, outside the permitted location, or in a different role than what is listed on the permit. Study permits often have caps on how many hours can be worked, for example, and working more than those hours
is unauthorized. These caps may not be clearly marked on the permit itself and are subject to change.

The Regulations define work as “an activity for which wages are paid or commission is earned, or that is in direct competition with the activities of Canadian citizens or permanent residents in the Canadian labour market.” The IRCC Guidelines state that for “unpaid work” officers must consider whether there is entry into the labour market. For example, volunteer and charity work
are often not seen as entering the labour market and therefore not work, but this involves a case-by-case evaluation, and if you are not sure please speak to a lawyer.

Having engaged in unauthorized work may negatively affect one’s ability to be issued a Work Permit, depending on the specifics of each situation. According to IRPR Section 200(3)(e):
(3) An officer shall not issue a work permit to a foreign national if
(e) the foreign national has engaged in unauthorized study or work in Canada or has failed to comply with a condition of a previous permit or authorization unless:
(i) a period of six months has elapsed since the cessation of the unauthorized work or study or failure to comply with a condition,
(ii) the study or work was unauthorized by reason only that the foreign national did not comply with conditions imposed under paragraph 185(a), any of subparagraphs 185(b)(i) to (iii) or paragraph 185(c);

IRPR 200(3)(e)(ii) refers to the conditions on a permit, which are listed in IRPR Section 185, and are the type of work, the employer, the duration of the work for any one employer, and the location of the work. This section means that officers may grant a Work Permit if the unauthorized work was while the individual held a valid Work Permit but worked in a different location than stated on the permit, for example:
IRPR 200(3)(e)(i) requires individuals to wait a period of at least six months after ceasing unauthorized work before they can be issued a new work permit. Officers have discretion to grant a permit after this period based on the circumstances. This only means that they are able to issue a permit, but it is not a guarantee that they will.

The most helpful information about these permits can be found here. As stated in these Guidelines, “In addition, per subsection R200(3.1), paragraph R200(3)(e) does not apply to migrant workers referred to in subsection R207.1(1), who have engaged in unauthorized work or failed to comply with a condition. Migrant workers are required to meet all other requirements of the IRPA and IRPR, including valid temporary resident status.”

This means the six-month restriction does not affect eligibility for this permit. It is often beneficial to clearly disclose any unauthorized work in your application, particularly when workers have taken on unauthorized work in order to reduce dependency on abusive employment, or after leaving an abusive situation. IRCC will then have this information upfront, and there is no need to fear disclosing what was already explained again in the future.

However, as demonstrated above, unauthorized work while on a Work Permit can be seen as less serious that unauthorized work while on visitor status. When disclosing unauthorized work performed while here as a visitor, please be mindful of the timing and the possibility of misrepresentation in a subsequent application for a Work Permit. If there are any doubts, please book an appointment with a lawyer to discuss the specifics of your situation.

A finding of misrepresentation can lead to a five-year ban on immigration applications and possible removal from Canada. It is taken very seriously. Unauthorized work on its own is a violation of immigration laws, but it does not automatically lead to a misrepresentation finding. However, if someone has applied for a permit or extension and omitted or misrepresented their unauthorized work, this could escalate the situation and carry severe consequences.

Misrepresentation includes not only false statements or omissions in your application, but also the submission of false or fabricated documents — such as employment reference letters, paystubs, bank statements, etc. This can also include falsely claiming work experience that you do not actually have.

Under IRPA 40(1)(a):
“A permanent resident or a foreign national is inadmissible for misrepresentation that directly or indirectly misleads or withholds material facts relevant to a determination under this Act.” For misrepresentation to be established, the false statement or omission must be “material,” meaning it could influence the outcome of an immigration decision. Courts have defined material misrepresentation as information that is objectively relevant to an officer’s assessment. In Idelfonso v. Canada (Citizenship and Immigration), 2025 FC 392, Justice Zinn reiterated that the test for materiality is determined by its potential to mislead immigration authorities and create a risk of error in administering the Act. Materiality of a misrepresentation is established “if it is important enough to affect the process” and cause an error in the administration of the Act, even if it is not decisive or determinative of an application.

Here are some key points and recent caselaw:

• Misrepresentation can be indirect, such as by a shady consultant or legal representative. In Haghighat v. Canada (Citizenship and Immigration), 2021 FC 598, the Court found that even if the representative is convicted of fraud, and even if the misrepresentation is the consultant providing their client with a fake IRCC passport request letter, the applicant can be inadmissible for that misrepresentation.
• As per Singh v. Canada (Citizenship and Immigration), 2021 FC 959, it is considered misrepresentation for someone to not disclose in a visitor extension application that they have accepted a job and that the employer has a LMIA application in process.
• Not disclosing previous visa refusals to other countries such as the US has been found to be misrepresentation. See Canada (Citizenship and Immigration) v. Singh Sidhu, 2018 FC 306, Abdool v. Canada (Citizenship and Immigration), 2024 FC 1172, Sharsheev v. Canada (Citizenship and Immigration), 2024 FC 49
  Feel free to read more here.

Anonymous reports, often called poison pen letters, can be sent to immigration authorities by former employers, abusive ex-partners, or anyone, alleging unauthorized work or misrepresentation. If detailed enough, these letters may trigger an investigation, potentially leading to a finding of misrepresentation, a removal order, or a five-year ban. Because of this
risk, voluntary disclosure may be the safer option to avoid future consequences. Unfortunately, anyone can report a foreign national that they suspect to be in violation of immigration laws by informing CBSA or calling their hotline.

If you have any questions or want to know how these laws apply to a specific situation, please book an appointment with a lawyer.

LAST REVIEWED: 2025 DECEMBER

You can find the campaign and donate to support migrant workers at this link.

We are proud to announce that MWC is officially certified as a Living Wage Employer by Living Wage BC! This means that we meet the Metro Vancouver Living Wage rate 2025 for all of our staff. A living wage* is the hourly amount someone needs to earn to cover basic expenses.

Living Wage BC encourages employers to pay a living wage as well as advocates for government policies that would help families make ends meet!

Click here to find other organizations that are also part of the Living Wage Employers!

El 4 de septiembre de 2025, usted emitió un comunicado solicitando la cancelación o reforma drástica del Programa de Trabajadores Extranjeros Temporales de Canadá (TFWP, por sus siglas en inglés). El Migrant Workers Centre también ha pedido desde hace tiempo reformas a este programa, incluyendo el otorgar la residencia permanente a todos los trabajadores migrantes al momento de su llegada. Sin embargo, en lugar de luchar por los derechos de los trabajadores migrantes vulnerables, su anuncio los culpa injustamente de la crisis de vivienda y de otros problemas sociales que son responsabilidad del gobierno. 

Fundado en 1986, el Migrant Workers Centre (“MWC”) es una organización sin fines de lucro en Columbia Británica dedicada a la defensa legal de los trabajadores migrantes. MWC facilita el acceso a la justicia para los trabajadores migrantes dando servicios legales y de apoyo gratuitos a esta comunidad. También trabajamos para promover políticas de inmigración justas y mejorar los estándares laborales para los trabajadores migrantes a través de la reforma legal y de políticas públicas, así como mediante litigios estratégicos. 

A Migrant Workers Centre nos preocupa y decepciona su declaración, ya que parece ser un abandono de los principios de defensa a los derechos laborales que su partido ha sostenido históricamente. Si su oficina está verdaderamente preocupada por poner fin a la explotación y los abusos inherentes al TFWP, existen muchas acciones concretas que su gobierno mayoritario puede tomar aquí mismo en Columbia Británica para promover los derechos de los trabajadores migrantes y limitar el poder de los malos empleadores que hacen mal uso del programa y abusan de los trabajadores: 

1. Apoyar a los grupos de justicia migrante en su llamado por el estatus de residencia permanente para todos. La restricción laboral que enfrentan los trabajadores migrantes y su estatus migratorio precario crean las condiciones que incentivan a los malos empleadores a explotar a los trabajadores migrantes y degradar las condiciones de trabajo y los salarios (incluyendo al robo de salario). 

2. Reformar la ley laboral (Employment Standards Act) e implementar mayores protecciones para los trabajadores migrantes: 

1. Aumentar el plazo de prescripción y el período de recuperación para presentar quejas. Actualmente, los trabajadores solo tienen 6 meses para presentar quejas por robo de salario y solo pueden recuperar hasta un año de salario. Muchos trabajadores migrantes no conocen sus derechos hasta que es demasiado tarde, y muchos aguantan a la explotación y los abusos durante años debido a su estatus migratorio precario.  

2. Implementar pago de horas extras y protecciones de horas de trabajo para los trabajadores agrícolas. En la discusión pública sobre este tema se ha sugerido exentar a los trabajadores agrícolas de la cancelación o reforma del TFWP, a pesar de que estos son de los trabajadores más explotados en Canadá. Actualmente, los trabajadores agrícolas pueden laborar más de 16 horas al día, siete días a la semana, sin tener derecho a pago de horas extras. Si su preocupación es la explotación, entonces ayude a poner fin a la explotación institucionalizada de los trabajadores agrícolas y a las leyes laborales racistas y discriminatorias que la permiten.  

3. Eliminar las exclusiones de indemnización para trabajadores de la construcción. Actualmente, los trabajadores de la construcción pueden ser despedidos sin previo aviso ni pago en su lugar. Los trabajadores migrantes con permisos de trabajo específicos para un empleador no pueden simplemente buscar otro empleo si son despedidos.  

4. Eliminar a las categorías que migratorias que excluyen y perjudican a las trabajadoras del cuidado. Las categorizaciones actuales hacen que muchas trabajadoras queden excluidas del pago de horas extras por diferencias mínimas y arbitrarias en sus empleos. Por ejemplo, una trabajadora del cuidado que vive en el hogar de su empleador y a quien se le paga directamente podría tener derecho a pago de horas extras, mientras que a la misma persona se le negaría el pago de horas extra si se le paga a través de un programa gubernamental, aun cuando ambas realizan el mismo trabajo. 

3. Dotar de recursos adecuados al ministerio laboral (Employment Standards Branch, o ESB). La ESB es el único tribunal administrativo que conocemos que no ofrece servicios de interpretación a los demandantes cuya primera lengua no es el inglés. Esto es especialmente dañino considerando que la ESB es responsable de aplicar la Ley de Protección de los Trabajadores Extranjeros Temporales. El Migrant Workers Centre ha presentado una denuncia de derechos humanos contra el ministerio laboral de BC por negarse a proporcionar interpretación a un trabajador que la necesitaba para participar adecuadamente en el proceso de investigación; continuaremos presentando denuncias similares mientras este problema persista.  

La ESB también debe tener el mandato de procesar urgentemente las quejas de los trabajadores migrantes, dado su estatus migratorio precario y su limitada movilidad laboral. Las leyes contra represalias no significan nada si una investigación de este tipo tarda más de un año en comenzar.  

4. Dotar de recursos adecuados al Tribunal de Derechos Humanos. Actualmente, el Tribunal tarda aproximadamente dos años en notificar a la parte demandada de la queja, y el proceso completo puede tardar más de cuatro años. Estas demoras son un gran obstáculo al acceso a la justicia y hacen que muchos trabajadores migrantes abandonen sus quejas o decidan no presentarlas. Es devastador que un trabajador migrante que ha sufrido acoso sexual en el lugar de trabajo deba esperar cuatro años antes de obtener un resultado justo. 

5. Reformar la Ley de Arrendamientos Residenciales. Es importante aumentar las protecciones para los trabajadores que viven en alojamiento proporcionado por sus empleadores. Las trabajadoras del cuidado que viven con sus empleadores están completamente excluidas de las protecciones de la sección 48 de la ley y pueden ser desalojadas sin previo aviso si son despedidas. Los trabajadores que tienen derecho a aviso de desalojo solo cuentan con 10 días para presentar una disputa si su empleador viola la ley. La mayoría de los trabajadores migrantes no conocen sus derechos como inquilinos hasta que es demasiado tarde y no tienen recurso alguno si son desalojados ilegalmente. 

6. Fortalecer las normas de seguridad en el lugar de trabajo. Los trabajadores migrantes a menudo toleran condiciones inseguras debido a su estatus migratorio precario. Se deben establecer reglas más estrictas para proteger a los trabajadores, especialmente en relación con olas de calor y humo de incendios forestales, y estas reglas deben aplicarse de manera proactiva.. 

También solicitamos que su gobierno implemente un equipo dedicado en WorkSafe BC para reclamos de trabajadores migrantes, que actúe con un enfoque informado por el trauma, sensibilidad cultural y capacitación sobre las limitaciones del TFWP y las dificultades que enfrentan los trabajadores migrantes para hacer valer sus derechos. 

7. Invertir en apoyo legal. La provincia es responsable de muchas de las leyes y prácticas que ponen en riesgo a la comunidad de trabajadores migrantes, pero proporciona muy poco financiamiento a organizaciones comunitarias y sin fines de lucro que atienden a esta comunidad. 

Si su oficina sigue estas acciones, podrán reducirán la explotación en el Programa de Trabajadores Extranjeros Temporales respetando la dignidad de los trabajadores migrantes, en lugar de tratarlos como chivos expiatorios. Agradeceríamos la oportunidad de dialogar con usted más a fondo sobre estas acciones para que podamos trabajar juntos en el avance de los derechos de todos los trabajadores.  

Atentamente, 

Jonathon Braun 

Director Legal 

Migrant Workers Centre  

302-119 W. Pender Street 

Vancouver BC V6B 1S5 
Tel: 604-909-4107 

Email: [email protected] 

Website: www.mwcbc.ca  

On 4 September 2025, you issued a surprise statement calling for the cancellation or drastic reformation of Canada’s Temporary Foreign Worker Program (TFWP). The Migrant Workers Centre has also long called for significant reforms to this program, including the granting of permanent residence on arrival for migrant workers. However, instead of fighting for the rights of vulnerable migrant workers, your announcement unfairly blames them for the housing crisis and other government failures.

Founded in 1986, the Migrant Workers Centre (“MWC”) is a non-profit organization in BC dedicated to legal advocacy for migrant workers. MWC facilitates access to justice for migrant workers through the provision of legal education, advice, and full representation. The organization also works to advance fair immigration policy and improved labour standards for migrant workers through law and policy reform and test case litigation.

The Migrant Workers Centre was extremely concerned and disappointed by your statement, as it appears to be an abandonment of the workers’-rights principles that your party has long stood on. If your office is truly concerned with ending the exploitation and abuse inherent in the TFWP, there are concrete actions that your majority government can take right here in British Columbia to advance the rights of migrant workers and limit the powers of bad actors who misuse the program and abuse the workers within it:

1. Support migrant justice groups in calling for permanent residence status for all. Lack of employment mobility and precarious immigration status create the conditions that incentivize bad employers to exploit migrant workers and drive down working conditions and wages (including through wage theft).
   
2. Reform the Employment Standards Act and implement stronger protections for migrant workers:
   • Increase the limitation period and recovery period for filing complaints. Currently, workers only have 6 months to file complaints about wage theft, and they can only claim up to a year of wages. Many migrant workers do not learn about their rights until it is too late, and many put up with exploitation and abuse for years because of their precarious immigration status.
   • Implement overtime pay and hours of work protections for agricultural workers. There have been suggestions in the public discussion of this issue that there be carveouts for agricultural workers – who are some of the most exploited migrant workers in Canada – from any cancellation of the Temporary Foreign Worker Program. Currently, agricultural workers can work 16+ hour days, seven days a week, and are entitled to zero overtime pay. If you are worried about exploitation, then help end the institutionalized, exploitation of agricultural workers and the racist and discriminatory employment laws that enable this exploitation.
   • End severance exclusions for construction workers. Currently, construction workers can be terminated without any notice or payment in lieu of notice. Migrant workers on employer-specific work permits cannot simply find alternate employment if they are terminated from a construction job.
   • End harmful categories for care workers that exclude many from protections. Care worker categorizations result in many workers being excluded from overtime protections based on very minor and arbitrary differences in their jobs. For example, a live-in care worker who is paid by an employer directly might be entitled to overtime wages while a care worker who is paid through a government grant might not be entitled to overtime, even if both workers are performing the same job.
     
3. Properly resource the Employment Standards Branch (ESB). The ESB is the only administrative tribunal we are aware of that does not provide interpretation services for complainants whose first language is not English. This is especially harmful considering the ESB is tasked with administering the Temporary Foreign Worker Protection Act. The Migrant Workers Centre has filed a Human Rights Complaint against the BC Ministry of Labour for its refusal to provide interpretation to a worker who needs it to properly participate in the ESB investigation process; we will continue to file similar complaints while this problem persists.
   
   The ESB must also be mandated to urgently process complaints from migrant workers given their precarious immigration status and limited employment mobility. Laws against retaliation mean nothing if it takes over a year before an investigation into that retaliation begins.
   
4. Properly resource the Human Rights Tribunal. Currently, the Tribunal takes about two years to even notify a respondent of the complaint, and the entire complaint process can take upwards of four years. These unjustifiable delays are a major impediment to access to justice and result in many migrant workers abandoning complaints or simply choosing not to file. It is heartbreaking that a migrant worker who has faced sexual harassment in the workplace will likely need to wait four years before getting any type of justice.
   
5. Reform the Residential Tenancy Act. Increase protections for workers who live in accommodation provided by their employers. Care workers who live with their employers are completely excluded from section 48 protections and can be evicted without notice if they are terminated. Workers who are entitled to eviction notice only have 10 days to file a dispute if their employer breaks the law. Most migrant workers do not about their tenancy rights until it is too late and have no recourse if they are illegally evicted.
   
6. Enhance rules for workplace safety. Migrant workers often put up with unsafe work conditions because of their precarious immigration status. Stronger rules need to be put in place to protect workers, especially regarding heat waves and wildfire smoke, and these rules must be enforced proactively.
   
   We also call on your government to implement a dedicated WorkSafe BC team for migrant worker claims that approach claims with a trauma-informed, cultural sensitivity and is trained to understand the limitations of the Temporary Foreign Worker Program and a migrant worker’s difficulty in asserting their rights.
   
7. Fund Legal Support. The province is responsible for many of the laws and practices that put the migrant worker community at risk, but the province provides very little funding to non-profits and community organizations to respond to the needs of the migrant worker community.

These concrete actions will reduce exploitation in the Temporary Foreign Worker Program in a way that respects the dignity of migrant workers, rather than treating them as scapegoats. We would appreciate the opportunity to discuss these actions with you further so that we can work together in the advancement of all workers’ rights.

Sincerely,

Jonathon Braun
Legal Director
Migrant Workers Centre 
302-119 W. Pender Street
Vancouver BC V6B 1S5
Email: [email protected]
Website: www.mwcbc.ca

Estamos reclutando voluntari@s para traducir documentos y mensajes que apoyan a personas migrantes en sus procesos legales. No se requiere título de traducción; solo dominio del idioma y compromiso.

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¡Tu ayuda puede cambiar vidas!

May 15, 2025

The Right Honourable Mark Carney, P.C., M.P., Prime Minister of Canada, Ottawa
The Honourable Lena Metlege Diab, Minister of Immigration, Refugees and Citizenship
The Honourable Patty Hajdu, Minister of Jobs and Families
The Honourable Gary Anandasangaree, Minister of Public Safety

On behalf of Migrant Rights Network, Canada’s largest migrant-led coalition, we congratulate you on forming Canada’s new government and call for immediate action on immigration rights and justice. We urge your government to:

● Ensure permanent residency for all migrants in Canada including international students, refugees, temporary foreign workers and undocumented people.
● Eliminate employer-tied work permits that enable exploitation.
● Strengthen protections and rights for all migrants.
● Prioritize family reunifi cation and end family separation.
● Reform refugee processes to uphold humanitarian values.

Building One Shared Society: No Worker Left Behind

Canada stands at a historic crossroads. As you begin your term, you do so amidst intersecting crises of affordability, economic instability, climate change, xenophobia and inequality, including persistent gender and racial inequities —but also immense opportunity for growth and prosperity. As you set out to implement your vision, we offer pragmatic recommendations that align with your priorities.

Over two million migrants—undocumented people, temporary foreign workers, international students, refugees, and others—are already living and working here. They are growing our food, raising our children, healing our sick, building our homes, and powering supply chains. Migrants are essential not just to our economies but also to our communities.

Addressing Root Causes, Not Scapegoating

We urge you to break from the failures of recent immigration policy. Research from the Canadian Centre for Policy Alternatives and the National Right to Housing Network demonstrates that Canada’s housing and affordability crises stem from decades of inadequate public investment, deregulation, and investor-driven speculation—not immigration. Racist scapegoating of migrants linking them to the housing crisis fractures our society and undermines the core values of fairness, solidarity, and inclusion that Canada must uphold. Capping immigration and restricting access to permanent residency will not solve the crises we face.

Current permit expiration policies are creating economic disruption: approximately 1.2 million people, many of whom are on work permits, are expected to leave Canada this year. This instability represents an estimated $50 billion in potential lost annual tax revenue according to a RBC report while creating unnecessary administrative burdens and workforce disruptions across key industries. A 2024 report from the Conference Board of Canada on the other hand found that improving temporary resident pathways to permanent status could add up to 2.1% to Canada’s GDP by 2030.

Many migrants came to Canada with the promise of permanent residency over the last fi ve years. The reduction in immigration and temporary foreign worker levels announced in 2024 breaks that promise, eroding trust in this government and undermining our shared future.

Gender and Racial Justice Must Be Centered

Migrant women, racialized, queer and gender-diverse people face some of the greatest barriers to safety and rights. They are paid less at work, face sexual and physical violence when they are tied to their employers or spouses, are unable to care for their families when there are caps on pilot programs, are denied access to reproductive care and face double punishment when they speak up about abuse and mistreatment. Recognizing that women and LBGTQ people’s security and well-being are central to a strong and united society and economy means closing the immigration gaps that compound their vulnerability.

Permanent Residency Is About Rights, Not Numbers

Over the past two years, immigration debate in Canada has been reduced to numbers. But the real issue is not how many migrants live here—it is about what rights and conditions they face. In August 2024, the UN Special Rapporteur on Contemporary Forms of Slavery described Canada’s temporary immigration system as a “breeding ground for modern slavery.” This echoed what migrant-led organizations like us, academics, and advocates have long made clear: denying permanent residence status creates a power imbalance that fuels exploitation and weakens labour standards and human rights for all. This burden falls disproportionately on women, Black, Indigenous, and racialized migrants, deepening systemic inequities in Canada’s labour market.

Short-Term Economic Stability Measures (First 100 Days)

● Workforce Retention Initiative: Implement permit extensions for workers with permits expiring between 2024-2027, including post-graduate work permits, who have worked and studied in Canada for years but were negatively impacted by the recent immigration changes.

● Construction Sector Workforce Stabilization: Move quickly on the tripartite council (government, employers, labour unions) to create a regularization program for undocumented construction
workers. This directly supports your government’s ambitious housing targets of 500,000 new homes annually.

● Healthcare Workforce Retention: Continue accepting applications for the Home Care Worker Immigration program. The program was closed within hours of its opening, leaving over 40,000 applicants unable to apply, facing work permit expiration, separation from their families and facing continued abuse. This change will address critical healthcare staffi ng shortages and will support the government’s plan of in-Canada focus transitioning temporary workers to permanent residency.

● Administrative Efficiency Reforms to Humanitarian and Compassionate Application system: Reform the Humanitarian and Compassionate application process to provide interim healthcare, immediate work/study permits, and a stop to deportations while applications are processed.

Medium-Term Economic Growth & Equity Measures (First Six Months)

A. Ensure Permanent Resident Status for All Migrants in Canada to Fuel Economic Growth & Collective Well-Being

Healthcare and Childcare:
○ Expedite and ensure permanent residence for migrant and undocumented care workers to address critical healthcare staffing shortages and support workers essential in implementing the $10-a-day childcare program. Program eligibility must be expanded to include home care workers, security guards, cooks, cleaners and administrative staff at care facilities.

Agriculture and Fisheries:
○ Ensure permanent residence for all migrant food sector workers—including those in the Seasonal Agricultural Workers Program, fish processing, aquaculture, and undocumented workers—who are essential to Canada’s food security. Reopen and expand the Agri-Food Immigration Program, and remove job offer, education, and language barriers.

Modernize immigration and guarantee permanent resident status for all:
○ Expand federal immigration permanent residency levels.
○ Recognize all work (gig, low-wage, part-time, seasonal, unpaid, on the study permit) toward permanent residence eligibility.
○ Eliminate discriminatory scoring systems based on age, education, or wage level.
○ Expand Provincial Nominee Program allocations.
○ Remove job offer letters or job experience requirements to reduce employer control.
○ Conduct consistent immigration draws.
○ Guarantee dignity and equality for all by ensuring immigration status is not conditional on paid work.
○ Implement a comprehensive regularization program for undocumented residents.
○ End all detentions and deportations.

B. Ensure Security, Stability, and Decent Work

● End employer-specific work permits.
● Reject the insufficient “Sector Specific” work permit model planned for 2027, and reject proposals to increase wage deductions on temporary foreign workers.
● End hour/industry exclusions (including 24 hours of work limit for international students and exclusions of sex related industries) that entrench indentured labour.
● Implement enforceable national housing standards for migrant workers.
● Work with provinces to harmonize employment standards and regulate inter-provincial recruiters.
● Provide open work permits to all undocumented people.
● Allow all international students regardless of program or length of study to apply for post-graduate work permits.
● Ensure full access to unionization for all migrants including through sectoral certifi cation and bargaining
● Transform the Open Work Permit for Vulnerable Workers program to better protect migrants by ensuring work permits are valid for at least five years and renewable; granting automatic permanent residence to whistleblowers; extending work permits to family members; requiring automatic investigation of implicated employers with support for workers seeking reparations; implementing 5-day processing with transparent, uniform rules; allowing applications from undocumented migrants; shifting the burden of proof to employers; and providing housing and employment support.
● End Canada Border Services Agency collusion and partnerships with other federal departments; as well as provincial and municipal bodies and agencies, including police and Ministries of Labour, which are largely resulting in the criminalization of migrants who are attempting to protect themselves.

C. Economic Security Measures

● Improve accessibility and adequacy of EI benefits for all. Reduce hours worked to 360 for eligibility and increase EI benefits to 75% of previous earnings with a minimum benefit of $600 per week.
● Ensure seasonal migrant workers can access EI benefits while abroad.

D. Justice for Refugees

● Expand the Government-Assisted Refugee Program.
● End the Canada-US Safe Third Country Agreement – the US is not safe for refugees.
● Urgently expand and ensure resettlement of Sudanese and Palestinian refugees, as well as others escaping conflict, in coordination with their representative bodies.

E. Unite Families

● Prioritize family reunification across all immigration streams.
● Ensure all workers and students can live with their families, with access to open work/study permits, healthcare, and federal benefits.

Implementation Partnership

You have been elected on a platform of hope, urgency, and the belief that Canada can do what was once thought impossible. We urge you to act on that promise by ensuring that migrants who already contribute to Canada’s economy, health, and communities are granted permanent residency and access to rights.

We request a meeting with the Minister of Immigration, Refugees and Citizenship Canada; Minister of Jobs and Families and Minister of Public Safety within the next 30 days to discuss practical implementation of these recommendations.

The path forward is not about fixing a broken system—it is about transforming it. And that work starts now. Let us build a future of shared prosperity, justice, and opportunity for all. This future must be feminist, anti-racist, and inclusive, ensuring that gender and racial justice are at the heart of all immigration and social policy.

Please reach out to Syed Hussan, at [email protected] and 416-453-3632 to schedule a meeting.

Sincerely,

Migrant Rights Network

Migrant Rights Network includes Butterfly – Asian and Migrant Sex Workers Project (ON), Careworker Connections Education Support Organization (ON), Centre for Migrant Worker Rights Nova Scotia, Chinese Canadian National Council Toronto Chapter (CCNCTO), Cooper Institute (PEI), FCJ Refugee House (ON), Madhu Verma Migrant Justice Centre (NB), Migrant Students United Vancouver, Migrant Workers Alliance for Change (National), Migrant Workers Centre BC, Migrante Canada, Migrante Ontario, OCASI – Ontario Council of Agencies Serving Immigrants, Parkdale Community Legal Services (ON), RAMA Okanagan, Sanctuary Health Vancouver, Vancouver Committee for Domestic Workers and Caregivers Rights, and Workers’ Action Centre (ON). See full list of members at MigrantRights.ca/About