{"id":18291,"date":"2026-11-05T16:41:16","date_gmt":"2026-11-05T21:41:16","guid":{"rendered":"https:\/\/cila.co\/?p=18291"},"modified":"2026-11-05T16:44:22","modified_gmt":"2026-11-05T21:44:22","slug":"cila-comments-on-the-immigration-levels-plan-2027-2029","status":"publish","type":"post","link":"https:\/\/cila.co\/fr\/cila-comments-on-the-immigration-levels-plan-2027-2029\/","title":{"rendered":"CILA Comments on the Immigration Levels Plan 2027-2029"},"content":{"rendered":"

In his opening remarks at the 2026 Canada Investment Summit, Prime Minister Mark Carney emphasized the ambition of the Government of Canada to catalyze $1 trillion in investment and confirmed that Canada is one of the world\u2019s most connected economies.[1]\u00a0<\/span>\u00a0<\/span><\/p>\n

<\/p>\n

Media are welcome to contact CILA at: research@cila.co<\/a><\/strong><\/p>\n

Achieving these objectives requires more than capital investment. It requires a skilled, productive, and adaptable workforce capable of supporting Canada\u2019s economic development and major infrastructure projects.<\/span>\u00a0<\/span><\/p>\n

Immigration and investment must therefore be viewed as complementary pillars of the economic strategy of Canada. Investment without an adequate workforce cannot deliver projects, while immigration without corresponding investment, employment opportunities, and economic development cannot realize its full potential. Canadian employees and targeted immigration together supply the welders, electricians, engineers, nurses and researchers to meet the substantial needs for labour forces of nation-building projects and infrastructure.<\/span>\u00a0<\/span><\/p>\n

The Canadian Immigration Lawyers Association (CILA) recognizes the Government\u2019s responsibility to manage immigration levels responsibly, maintain public confidence, and protect the integrity of Canadian immigration system. However, these objectives must be balanced against the country\u2019s long-term economic, demographic, and humanitarian needs.<\/span>\u00a0<\/span><\/p>\n

The following discussion identifies six significant policy challenges and outlines our recommendations for addressing them.<\/span><\/p>\n

1) Balancing Immigration Reductions with Canada\u2019s Long-Term Needs<\/span><\/b><\/h3>\n

Reducing immigration levels may help alleviate pressure on housing, infrastructure, and public services. However, substantial reductions, particularly when implemented without sufficient consideration of regional and sector-specific labour needs, may also create unintended economic consequences.<\/span>\u00a0<\/span><\/p>\n

Canada\u2019s immigration policies must support both sustainable population growth and the country\u2019s long-term economic competitiveness.<\/span>\u00a0<\/span><\/p>\n

Entrepreneur Immigration and Investment<\/span><\/b>\u00a0<\/span><\/p>\n

Entrepreneur immigration has traditionally played an important role in attracting foreign capital, encouraging innovation, creating employment opportunities, and supporting business development.<\/span>\u00a0<\/span><\/p>\n

The suspension of federal business immigration pathways, including the Self-Employed Persons Program and Start-Up Visa Program, raises concerns about Canada\u2019s ability to attract international entrepreneurs and investors.<\/span>\u00a0<\/span><\/p>\n

While CILA recognizes the need to address program integrity concerns and application backlogs, the absence of accessible federal business immigration pathways may discourage entrepreneurs from establishing businesses in Canada and redirect potential investment toward competing jurisdictions. A sustainable immigration strategy should preserve opportunities for genuine entrepreneurs who demonstrate the financial capacity, business experience, and commitment necessary to contribute to Canada\u2019s economy. (<\/span>Read CILA\u2019s dedicated report on this topic here)<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

Temporary Foreign Workers and Canadian Employers<\/span><\/b>\u00a0<\/span><\/p>\n

Reductions in temporary resident admissions also have significant implications for Canadian employers. The federal admission target for the Temporary Foreign Worker Program decreased from 82,000 in 2025 to 60,000 in 2026, while the target for the International Mobility Program declined from 285,750 to 170,000.<\/span> [2]<\/span>\u00a0<\/span><\/p>\n

Although these reductions are intended to better manage temporary resident numbers, they may disproportionately affect employers in industries experiencing persistent labour shortages, including healthcare, construction, agriculture, and certain service industries as well as rural, remote, and sparsely populated communities. Foreign workers should not automatically be viewed as displacing Canadian workers. In many circumstances, they complement the domestic workforce by filling positions that employers have been unable to staff locally.<\/span>\u00a0<\/span><\/p>\n

Maintaining an adequate workforce enables businesses to continue operating, expand their activities, and preserve employment opportunities for Canadian citizens and permanent residents. Immigration policy should therefore distinguish between employers who rely on foreign workers to address genuine labour shortages and those who misuse temporary foreign worker programs.<\/span>\u00a0<\/span><\/p>\n

International Students and Economic Contributions<\/span><\/b>\u00a0<\/span><\/p>\n

International students also make substantial contributions to the Canadian economy and educational institutions. According to Global Affairs Canada, international students generated approximately $47.5 billion in spending in 2024, contributing nearly $39 billion to Canadian GDP, supporting 407,262 jobs, and generating approximately $9.4 billion in tax revenue.[3]<\/span>\u00a0<\/span><\/p>\n

However, international student arrivals have declined significantly. According to IRCC\u2019s 2026 reporting, approximately 115,385 international students arrived in Canada in 2025, representing a decline of approximately 61% compared with 2024.[4]<\/span>\u00a0<\/span><\/p>\n

While CILA recognizes the need to address concerns regarding educational quality, student protection, housing availability, and program integrity, substantial reductions in international student admissions may also affect educational institutions, local economies, employment, and government revenues.<\/span>\u00a0<\/span><\/p>\n

Temporary pathway for refugee claimants contributing to the key sectors<\/span><\/b> \u00a0<\/span><\/p>\n

CILA proposes IRCC to review a temporary public policy to grant permanent residence to established refugee claimants, including failed refugee claimants, who are currently addressing acute labor shortages in key Canadian economic sectors.<\/span>\u00a0<\/span><\/p>\n

Some refugee claimants are working in essential sectors such as construction, healthcare, agriculture and other key sectors. Many of them have been established in Canada for many years. Despite their vulnerability, these people are building Canadian houses, treating our sick, and securing our food supply chains.<\/span>\u00a0<\/span><\/p>\n

Presently, we are seeing highly vulnerable but exceptionally integrated individuals facing deportation, despite serving as essential assets to our communities.<\/span>\u00a0<\/span><\/p>\n

IRCC has successfully implemented similar measures in the recent past. The pandemic-era temporary pathway for refugee claimants working in the healthcare sector (“Guardian Angels”) proved that regularizing established claimants who contribute to critical societal needs is both highly effective and widely supported by the Canadian public.<\/span>\u00a0<\/span><\/p>\n

We recommend IRCC to build upon both this precedent and the framework previously suggested in the December 2024 CILA-CARL proposal<\/a>. <\/span>By introducing a temporary PR pathway for these established workers, IRCC can simultaneously alleviate the enforcement backlog and support Canada\u2019s most strained economic sectors.<\/span><\/p>\n

2) Transparency and Immigration Policy Stability<\/span><\/b><\/h3>\n

Predictability and transparency are essential to maintaining confidence in Canadian immigration system. Immigration decisions often involve substantial financial commitments, career changes, family arrangements, and long-term planning. Applicants reasonably expect that the policies governing their immigration pathways will remain sufficiently stable to allow them to make informed decisions. Sudden changes to eligibility requirements, particularly when implemented without adequate transitional measures, may disproportionately affect individuals who have already made significant commitments in reliance on existing policies.<\/span>\u00a0<\/span><\/p>\n

This concern is especially relevant to entrepreneur immigration programs. Entrepreneurs may invest substantial capital, establish businesses, hire employees, and undertake commercial obligations in Canada with the expectation of pursuing permanent residence through an established immigration pathway.<\/span>\u00a0<\/span><\/p>\n

Unlike many other immigration applicants, entrepreneurs cannot readily reverse their investments or withdraw from ongoing business commitments when immigration policies change. Changes introduced after these investments have been made may expose legitimate entrepreneurs to significant financial losses and uncertainty regarding their immigration prospects.<\/span>\u00a0<\/span><\/p>\n

Similar concerns arise for international students. Frequent changes to study permit and Post-Graduation Work Permit (PGWP) eligibility requirements create uncertainty for students who have committed substantial resources to Canadian education based on the policies in effect when they enrolled.<\/span>\u00a0<\/span><\/p>\n

Although immigration eligibility cannot be guaranteed indefinitely, policy changes should be implemented with reasonable notice and appropriate transitional protections.<\/span><\/p>\n

3) Application Backlogs and Processing Times<\/span><\/b><\/h3>\n

Transparency in immigration policy must be accompanied by greater transparency and accountability in application processing. The inventory report of IRCC in May 2026 recorded approximately 2,092,700 applications, including 941,400 applications exceeding established service standards.[5] Only 47% of permanent residence applications were being processed within service standards.<\/span>\u00a0<\/span><\/p>\n

IRCC acknowledged that processing delays are partly attributable to annual admission limits, explaining that applications exceeding available admission spaces may need to wait until additional spaces become available.[6]<\/span>\u00a0<\/span><\/p>\n

Although admission targets are necessary for immigration planning, prolonged processing delays can create serious consequences for applicants, their families, and Canadian employers. Processing performance also varies considerably between immigration programs. For example, IRCC reported that approximately 76% of Federal Skilled Worker and Canadian Experience Class applications received decisions within the six-month service standard between September 2025 and August 2026.[7]<\/span>\u00a0<\/span><\/p>\n

On the other hand, the Home Care Worker Immigration Pilots illustrate the practical consequences of prolonged processing times. On June 23, 2026, IRCC acknowledged that not all applicants who submitted applications in 2025 had received an Acknowledgement of Receipt.[8] Processing-time estimates reported in September 2026 suggested that some applicants could face waits of approximately 76 months, with a substantial number of applications remaining in the inventory. Such prolonged uncertainty creates significant challenges for caregivers and the Canadian families who depend on their services.<\/span>\u00a0<\/span><\/p>\n

The nature of caregiving employment also makes prolonged processing particularly problematic. An elderly care recipient may pass away, or a family may no longer require caregiving services. Applicants should not face disproportionate immigration consequences simply because the circumstances of their original employment change during an exceptionally lengthy processing period.<\/span><\/p>\n

4) Express Entry Reforms and the Need for Comprehensive Economic Immigration Reform<\/span><\/b><\/h3>\n

The Express Entry changes introduce additional Comprehensive Ranking System points for eligible Canadian work experience or qualifying job offers in high-wage occupations.[9]<\/span>\u00a0<\/span><\/p>\n

While CILA recognizes the Government’s intention to improve economic outcomes and strengthen Canadian labour market integration, these adjustments do not adequately address the fundamental structural weaknesses of Canada’s economic immigration selection system.<\/span>\u00a0<\/span><\/p>\n

Express Entry has become increasingly complex, unpredictable, and difficult for applicants and employers to navigate. Frequent changes to CRS criteria, category-based selection, and program priorities have undermined transparency and predictability. \u00a0<\/span>\u00a0<\/span><\/p>\n

The proposed emphasis on qualifying job offers raises further concerns regarding program integrity. Although removing the Labour Market Impact Assessment requirement may reduce administrative burdens, it also places greater responsibility on immigration officers to verify the genuineness of job offers. Without clear standards, consistent assessment procedures, and effective employer verification mechanisms, these changes may create new opportunities for fraudulent job offers while imposing disproportionate burdens on legitimate small businesses and newly established employers.<\/span>\u00a0<\/span><\/p>\n

CILA is also concerned that the growing emphasis on French-language proficiency within Express Entry may, in certain circumstances, outweigh other important indicators of economic establishment, including Canadian work experience, demonstrated employment stability, occupational qualifications, and long-term labour market contributions. While promoting Francophone immigration outside Quebec remains an important national objective, language-based selection should complement rather than displace broader economic immigration priorities. The Government should evaluate whether current selection incentives produce sustainable Francophone settlement outside Quebec and whether stronger verification measures are necessary to address potential misrepresentation concerning language proficiency and intended province of residence.<\/span>\u00a0<\/span><\/p>\n

CILA recommends a comprehensive restructuring of Express Entry rather than continued incremental adjustments to an increasingly complicated system. Eligibility should prioritize applicants who have accumulated certain years of authorized Canadian work experience, demonstrated proficiency in at least one official language, maintained lawful status, fulfilled their tax obligations, established financial stability, and secured continuing employment with a verified Canadian employer, subject to applicable admissibility requirements.<\/span>\u00a0<\/span><\/p>\n

Such an approach would recognize the contributions of established temporary residents, improve workforce retention, and provide employers with greater certainty while the Government undertakes broader economic immigration reforms.<\/span>\u00a0<\/span><\/p>\n

More fundamentally, the <\/span>Immigration and Refugee Protection Act<\/span><\/i>, enacted more than two decades ago, warrants a comprehensive legislative review to ensure that the Canadian immigration framework reflects current economic realities, demographic pressures, regional labour market needs, and long-term national interests. (<\/span>Read CILA\u2019s report on IRPA reform here<\/span><\/a>).<\/span><\/p>\n

5) Asylum Reforms and Expanded Discretionary Powers under Bill C-12<\/span><\/b><\/h3>\n

Bill C-12 introduces significant changes affecting asylum eligibility, information sharing, and the Government’s authority to manage immigration applications and documents in the public interest. CILA recognizes the importance of maintaining an effective asylum system, discouraging fraudulent claims, and ensuring that immigration processes are not misused.\u00a0<\/span>\u00a0<\/span><\/p>\n

According to IRCC, asylum claims from temporary resident visa holders declined substantially in 2026, including a reported 73% reduction in August 2026 compared with August 2024.[10] These figures may reflect changes in migration patterns, enforcement measures, and immigration policies. However, a reduction in asylum claims should not, by itself, be treated as evidence that access to refugee protection has improved or that all claims deterred were without merit.<\/span>\u00a0<\/span><\/p>\n

CILA is concerned that overly restrictive eligibility rules could prevent certain individuals from accessing a full assessment of their protection claims. In addition, the expanded authority to suspend, cancel, or modify immigration applications and documents in the public interest also raises concerns regarding transparency, legal certainty, and procedural fairness.<\/span>\u00a0<\/span><\/p>\n

Although such powers may be necessary in exceptional circumstances, their exercise should be subject to clear statutory safeguards, appropriate oversight, and meaningful opportunities for affected individuals to challenge decisions.<\/span><\/p>\n

6) Family Reunification and Sponsorship<\/span><\/b><\/h3>\n

Family reunification remains a fundamental objective of Canadian immigration system and an important contributor to social stability and community integration. However, limited admission spaces and growing application inventories have contributed to prolonged family separation. IRCC has acknowledged that demand for family sponsorship exceeds available admission spaces, placing additional pressure on processing times, including those for in-Canada spousal sponsorship applications.<\/span>\u00a0<\/span><\/p>\n

On July 15, 2026, IRCC announced a pause in the intake of new applications under the Parents and Grandparents Program (PGP), while continuing to process existing applications and planning to admit up to 15,000 parents and grandparents as permanent residents in 2026.[11]\u00a0<\/span>\u00a0<\/span><\/p>\n

Although CILA recognizes the need to manage admission levels responsibly, the limited availability of the PGP creates uncertainty for Canadian citizens and permanent residents seeking to reunite with their parents and grandparents.<\/span>\u00a0<\/span><\/p>\n

In addition, while the Super Visa has become the primary practical alternative for extended family reunification, administrative barriers remain. Parents and grandparents who wish to renew an expiring Super Visa may need to apply for a new visa through an outside-Canada application process, even when they are already lawfully residing in Canada.<\/span>\u00a0<\/span><\/p>\n

While an extension of temporary resident status may be available from within Canada, this is not equivalent to obtaining a renewed Super Visa. For elderly individuals, particularly those with medical vulnerabilities or mobility limitations, uncertainty surrounding renewal and travel documentation can create unnecessary hardship.<\/span>\u00a0<\/span><\/p>\n

Conclusion and Policy Recommendations<\/b><\/h3>\n

The long-term prosperity of Canada depends on the effective alignment of immigration policy with its economic, demographic, labour market, and infrastructure priorities. CILA recognizes the Government\u2019s responsibility to manage immigration levels, address pressures on public services, and maintain public confidence in the immigration system.<\/span>\u00a0<\/span><\/p>\n

However, immigration reductions and administrative reforms must be implemented in a manner that does not unnecessarily undermine economic competitiveness, discourage legitimate investment, destabilize Canadian employers, or create prolonged uncertainty for applicants and their families.<\/span>\u00a0<\/span><\/p>\n

CILA therefore recommends that the federal government take the following actions:<\/span>\u00a0<\/span><\/p>\n

1.<\/strong> Align immigration levels with demonstrated economic and labour market needs. Adopt a more targeted approach to immigration reductions that considers regional labour shortages, essential occupations, infrastructure priorities, and the contributions of temporary residents already established in Canada.<\/span>\u00a0<\/span><\/p>\n

<\/p>\n

2.<\/strong> Restore credible federal entrepreneur immigration pathways. Develop or reopen pathways for genuine entrepreneurs and investors, with appropriate program integrity measures, transparent eligibility criteria, and meaningful recognition of business investment, innovation, and job creation.<\/span>\u00a0<\/span><\/p>\n

<\/p>\n

3.<\/strong> Improve policy stability and transitional protections. Provide reasonable advance notice of major immigration policy changes and introduce transitional measures for applicants who have already made substantial financial, educational, or business commitments in reliance on existing programs.<\/span>\u00a0<\/span><\/p>\n

<\/p>\n

4.<\/strong> Establish greater accountability for processing times and application backlogs. Publish program-specific processing targets, provide more transparent inventory information, and develop measures to address applications that substantially exceed established service standards. Pause workforce reductions at IRCC until IRCC is able to achieve its own processing standards.<\/span>\u00a0<\/span><\/p>\n

<\/p>\n

5.<\/strong> Ensure fairness and consistency in the revised Express Entry system. Publish clear evidentiary standards for genuine job offers, provide appropriate guidance for small and newly established businesses, and regularly evaluate whether the revised CRS framework reflects actual labour market needs of Canada.<\/span>\u00a0<\/span><\/p>\n

<\/p>\n

6.<\/strong> Preserve procedural fairness and access to refugee protection. Ensure that asylum eligibility restrictions and expanded discretionary powers include appropriate safeguards, transparent decision-making, and meaningful review mechanisms.<\/span>\u00a0<\/span><\/p>\n

<\/p>\n

7.<\/strong> Strengthen family reunification measures. Maintain viable permanent residence pathways for family sponsorship, improve processing predictability, allow more families to sponsor parents and grandparents, and establish a streamlined in-Canada renewal process for eligible Super Visa holders.<\/span>\u00a0<\/span><\/p>\n

References<\/span><\/b>\u00a0<\/span><\/p>\n

[1] Prime Minister of Canada. (2026, September 15). <\/span>Prime Minister Carney delivers opening remarks at the Canada Investment Summit<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[2] Immigration, Refugees and Citizenship Canada (IRCC). (2025). <\/span>Immigration Levels Plan 2026\u20132028: Question Period Notes<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[3] Global Affairs Canada. (2026). <\/span>Economic impact of international education in Canada, 2024<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[4] Immigration, Refugees and Citizenship Canada (IRCC). (2026, March 23). <\/span>International students: Parliamentary committee briefing<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[5] Immigration, Refugees and Citizenship Canada (IRCC). (2026, May 28). <\/span>IRCC applications at a glance: Inventories and backlogs<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[6] Ibid.<\/span>\u00a0<\/span><\/p>\n

[7] Immigration, Refugees and Citizenship Canada (IRCC). (2026). <\/span>Application processing system: Immigration statistics and service standards<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[8] Immigration, Refugees and Citizenship Canada (IRCC). (2026, June 23). <\/span>Home Care Worker Immigration Pilots: After you apply<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[9] Immigration, Refugees and Citizenship Canada (IRCC). (2026, October). <\/span>Changes to Express Entry for high-wage occupations<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[10] Immigration, Refugees and Citizenship Canada (IRCC). (n.d.). <\/span>Asylum claims: Immigration statistics and open data<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

[11] Immigration, Refugees and Citizenship Canada (IRCC). (2026, July). <\/span>Measures to responsibly manage the Parents and Grandparents Program<\/span><\/i>. <\/span>Government of Canada<\/span><\/a>.<\/span>\u00a0<\/span><\/p>\n

\u00a0<\/span>\u00a0<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"

In his opening remarks at the 2026 Canada Investment Summit, Prime Minister Mark Carney emphasized the ambition of the Government of Canada to catalyze $1 trillion in investment and confirmed that Canada is one of the world\u2019s most connected economies.[1]\u00a0\u00a0<\/p>\n","protected":false},"author":115,"featured_media":18296,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"inline_featured_image":false,"footnotes":""},"categories":[6],"tags":[29,36,94,37,1492,256,42,92,203,164,51],"class_list":["post-18291","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-thought-leadership","tag-express-entry","tag-family-class","tag-humanitarian","tag-immigration-levels-plan","tag-immigration-levels-plan-2027-2029","tag-irpa","tag-pr","tag-refugees","tag-study","tag-study-permit","tag-tr"],"aioseo_notices":[],"aioseo_head":"\n\t\t\n\t\n\t\n\t\n\t\n\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t