Canada Updates Guidelines for LMIA‑Exempt Work Permits Under Reciprocal Employment (R205(b) – C20)

Immigration, Refugees and Citizenship Canada (IRCC) has implemented updated guidance for the Reciprocal Employment category under R205(b) – C20 of the Immigration and Refugee Protection Regulations (IRPR). These changes apply to Labour Market Impact Assessment (LMIA)‑exempt work permits issued through the International Mobility Program (IMP). The revised instructions clarify how officers assess reciprocity, outline updated processing expectations, and help ensure consistent decision‑making across visa offices and ports of entry.

The update was published on February 20, 2026, and reorganizes the Program Delivery Instructions (PDIs) to align with the broader IMP format.

Overview of the Reciprocal Employment Category

Under R205(b), a foreign national may receive an LMIA‑exempt, employer‑specific work permit when their employment creates or maintains reciprocal employment opportunities for Canadian citizens or permanent residents abroad. The intent is to support Canada’s economic and cultural interests by allowing balanced mobility exchanges between Canada and partner countries.

Reciprocity can occur through:

  • Program‑based arrangements, such as cultural exchange programs or international agreements
  • Employer‑based exchanges, including global mobility programs that demonstrate balanced inbound and outbound flows of personnel

Examples of common C20 uses include professional coaches or athletes working for Canadian teams and participants in cultural exchange agreements between Canada and partner countries.

The general requirement remains that exchanges should result in a neutral labor market impact for Canada, and reciprocity must exist with the specific country from which the foreign worker is entering.

Key Updates to IRCC Instructions

1. More Precise Interpretation of Reciprocity

Officers must now assess whether Canadians or permanent residents receive similar employment opportunities in the specific country of the foreign worker, not simply abroad in general. This represents a clarification of how reciprocity should be evaluated.

2. Recognition of “Maintaining” Reciprocal Employment

Officers may consider whether the job offer in Canada contributes to maintaining existing reciprocal opportunities abroad. This broadens the interpretation beyond new opportunities alone.

3. Integrated Port‑of‑Entry (POE) Guidance

The updated PDIs remove the separate POE banner and fold port‑of‑entry procedures directly into the main content. This is intended to improve clarity and consistency for officers and applicants.

4. New Instructions for GCMS Notes

The update introduces detailed requirements for GCMS data entry, including:

  • Destination province and city must match the job offer
  • The NOC code for the role must appear in the offer of employment

These requirements support improved accuracy in case processing.

5. Guidance on Document Expectations and Evidence

The revised instructions emphasize the type of evidence officers may require to assess reciprocity, including:

  • Exchange agreements
  • Employer statements or institutional letters
  • Historical data demonstrating two‑way staff mobility

Officers may request additional documentation where needed to verify proportionality and reciprocity.

6. Family Member Provisions

A newly added section clarifies that family members of high‑skilled C20 workers may qualify for open work permits under R205(c)(ii) (formerly C41/C46).

7. Duration of Work Permits for Certain Applicants

For foreign nationals exempt from travel document requirements (such as U.S. citizens), officers are reminded to issue work permits for the full duration of the job offer, even if the passport expires earlier.

8. No Requirement for Formal Agreements

IRCC confirms that a formal international or corporate agreement is not mandatory. Employers can rely on documentation demonstrating that reciprocal opportunities exist.

Erickson Insights & Analysis

Erickson Immigration Group will continue monitoring developments and sharing updates as more news is available. Please contact your employer or EIG attorney if you have questions about anything we’re reporting above or if you have case-specific questions.