Immigration Amendment: Shorter Timelines, Bigger Impact

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The Québec government has introduced an amendment to the Québec Immigration Regulation through Order in Council 154-2025. This amendment is authorized under section 15 of the Québec Immigration Act, which grants the government the power to establish conditions that employers must meet when hiring foreign nationals for temporary work in Québec.

The regulation specifically allows the government to set criteria for employers, including obtaining a positive assessment from the Minister of Immigration, Francization, and Integration regarding the potential impact of a job offer on Québec’s labor market. This assessment serves as a safeguard to ensure that hiring foreign workers does not negatively affect local employment opportunities. Additionally, section 104 of the Québec Immigration Act states that regulations issued under section 15 are not subject to the usual publication requirements outlined in the Regulations Act.

The specific change introduced by this amendment pertains to section 99 of the Québec Immigration Regulation, which previously stipulated that certain provisions applied for a duration of two years. The amendment replaces all instances of “two years” with “six months,” thereby significantly reducing the applicable timeframe for these provisions. The regulation does not provide additional details on the specific aspects affected by this change in duration, but it implies a shift toward shorter-term regulatory measures, potentially impacting both employers and foreign workers.

By shortening the period from two years to six months, the government may be aiming to increase flexibility in the immigration system, allowing for more frequent reassessments of labor market conditions and employer compliance. This adjustment could reflect the government’s intent to respond more quickly to evolving economic and employment needs within the province.

The amendment’s broader implications could include a faster turnover of work authorizations or assessments for employers seeking to hire foreign workers, as well as an increased administrative burden due to the more frequent renewal or reassessment requirements. The reduced timeframe could also introduce challenges for employers who may need to undergo assessments more frequently, potentially increasing bureaucratic hurdles and administrative costs. Additionally, for foreign workers, the shorter period could mean more uncertainty regarding their employment status and work authorization in Québec.

Given the importance of immigration in addressing labor shortages in various industries, this regulatory change could have significant consequences across multiple sectors. Employers who rely on foreign labor may need to adjust their hiring strategies, while government agencies will likely need to allocate resources to manage the increased frequency of assessments.

Quebec (154-2025) February 26, 2025