Thesis: The Temporary Foreign Worker Program Canada (TFWP), especially its low-wage and LMIA-based streams, has expanded rapidly in recent years. Empirical data and reports indicate that, alongside the official economic rationale, serious harms, wage suppression, employer abuse, regional inequities, and barriers for Canadians seeking employment have become increasingly visible. Legal reforms, stronger enforcement, greater transparency, and possibly major restructuring are required to ensure the program fulfils its lawful purpose without undermining Canadians’ labour rights or enabling systemic abuse.

1. Growth of the Program and Statistical Trends

To evaluate the claim that the Temporary Foreign Worker Program is “going through the roof” and impacting local job opportunities, one must start with the numbers. In 2023, employers were approved to hire approximately 239,646 temporary foreign workers under closed work permits requiring a Labour Market Impact Assessment (LMIA). In 2018, that number was about 108,988. Thus, from 2018 to 2023, the LMIA-based TFW workforce more than doubled.

Between 2015 and 2023, LMIA approvals rose from about 82,683 jobs in 2015 to 228,429 in 2023, an increase of 176%. As of the 2021 Statistics Canada data, approximately 4.1% of the workforce in Canada were temporary foreign workers, up from 1.9% a decade earlier. These quantitative changes show that the program has expanded significantly. The major question is whether this expansion is lawful, fair, and whether unintended negative consequences have been managed or mitigated.

2. Economic Impacts: Unemployment, Job Displacement, and Wage Effects

2.1 Unemployment Rate

As of May 2025, Canada’s unemployment rate was reported at 7.0%, the highest in nearly nine years outside of COVID-19 spikes, with about 1.6 million people unemployed. Regional disparities exist; in many parts of the country, certain census metropolitan areas have unemployment rates of 6% or higher. This matters because the government in January 2025 imposed restrictions on processing LMIAs for low-wage positions in regions with unemployment above 6%.

2.2 Displacement and Competition

Public opinion is divided, but many Canadians assert that TFWs reduce opportunities for young and local workers to secure decent jobs. For example, an Angus Reid Institute survey found that about half of Canadians believe the program unfairly impacts young workers, though many also say that sectors using TFWs are ones locals often avoid.

A key legal safeguard in the TFWP is the LMIA: employers must show that there are insufficient qualified Canadians or permanent residents before hiring foreign workers. However, critics claim LMIA enforcement is weak, allowing employers to rely on TFWs even when locals are available.

2.3 Wage Suppression & Labour Standards

According to a Reuters report in August 2024, the growth of low-wage streams has contributed to wage suppression: employers hiring TFWs for low-wage work reduce competitive pressure to raise salaries. Amnesty International reports “excessive working hours,” “wage theft,” tasks not in the original contract, unsafe working conditions, and discriminatory abuse as systemic in the program.

3. Legal and Regulatory Violations, Abuse, and Systemic Weaknesses

3.1 Abuse of Worker Rights

Amnesty International’s report “Canada has destroyed me” describes multiple cases of migrant workers under the TFWP being:

Forced to work long hours, sometimes 70–80 hours/week, without adequate rest days.
Subjected to tasks outside their contracts.
Given substandard or unsafe housing, inadequate access to health care.
Facing threats of termination or repatriation if they raise concerns or become unable to work.

A United Nations Special Rapporteur identified the program as a “breeding ground for contemporary forms of slavery,” pointing to “asymmetries of power” and structural vulnerabilities arising from employer-specific closed permits.

3.2 Enforcement, Inspections, and Penalties

The Government of Canada’s ESDC conducted 2,122 inspections under the TFWP in one recent fiscal year. Of these, 94% of employers were found compliant; 6% non-compliant. In that same period, $2.1 million in Administrative Monetary Penalties (AMPs) were levied, which is approximately 36% more than in the previous year, where the penalties were $1.54 million.

Additionally, 12 employers were banned from the program in that period, up from 7 in the prior year. So, while there is enforcement, the scale of violations reported in advocacy and media sources suggests enforcement is not catching all abuses, especially covert ones (e.g., wage deductions, under-reporting of hours, housing violations).

3.3 LMIA, Low-Wage Stream, and Regulatory Loopholes

Critiques focus particularly on the Low-Wage stream of TFWP. One legal/regulatory change in August 2024 included the removal of certain LMIA processing in low-wage occupations in regions with high unemployment. Allegations of misuse or gaming of the LMIA process have surfaced, including fake job postings, misrepresentation, lack of proper advertising to Canadian workers, or employer collusion. Some cases of fake Letters of Acceptance (for international students) have also been flagged.

4. Arguments Against the Claim: What the Data Does Not Fully Support

To ensure legal and factual balance, some claims are not fully borne out:

There is limited empirical evidence that all sectors are dominated by TFWs to the point that Canadians cannot find work in other industries.
Concentration of TFWs is seen mainly in agriculture, food services, accommodation, and construction.
While reports of abuse exist, evidence of large-scale collusion between employers and ministries is mostly anecdotal.
Refugee claim statistics are rising, but their impact on labour markets is still debatable.
The notion that most TFWs or student permit holders use fake documents remains under investigation, with some proven cases but no definitive scale yet.

5. Legal Framework, Obligations, and Needed Reforms

Under Canadian law and international human rights obligations, the TFWP is supposed to ensure:

Employers prove that no qualified Canadians or permanent residents are available for the job.
Worker rights under labour law: minimum wage, safe working conditions, proper accommodations.
Inspections and penalties for non-compliance.

Proposed reforms include:

Restricting LMIA processing for low-wage positions in high-unemployment regions.
Increasing penalties and employer bans.
Ministerial acknowledgment that reforms are urgently required.

6. What the Evidence Strongly Suggests

Rapid growth in LMIA-based and low-wage streams.
More foreign workers admitted under stricter requirements than before.
Increases in inspections and penalties, but non-compliance remains non-trivial.
Wage suppression and displacement effects are supported by economic commentary.
Legal loopholes and weak enforcement enable misuse.

7. What Remains Unproven

Peer-reviewed evidence of exactly how many Canadians are displaced solely by TFWP.
Proof of widespread government collusion.
Scale of student permit abuse distorting labour markets on the same level as TFWP.

8. Strong Legal Arguments for Reform

Potential Charter challenges on equality and labour rights.
Strengthened LMIA requirements and transparency.
Sector-based or open work permits instead of employer-specific ones.
Oversight, whistle-blower protections, and independent labour tribunals.

9. Policy Recommendations

9.1 Restriction of the Low-Wage Stream

Immediate review and curtailment of the Low-Wage stream.
Suspension of authorizations where unemployment exceeds 6%.
Consider phased elimination of the stream.

9.2 Strengthened Monitoring and Enforcement

More inspectors assigned to oversight.
Proportional penalties for violations.
Random audits and unannounced inspections.

9.3 Rigour in the LMIA Process

Genuine recruitment efforts before LMIA applications.
Mandatory auditing of advertising records.
Automatic revocation for misrepresentation.

9.4 Protection of Temporary Foreign Workers

Employer-specific permits replaced by open/sector-based permits.
Pathways to permanent residence for eligible workers.
Strong whistle-blower protections.

9.5 Transparency and Public Accountability

Release of disaggregated TFWP data.
Registry of non-compliant employers.
Mandatory parliamentary reporting.

9.6 Strengthening Legal Recourse

Accessible mechanisms for workers to pursue claims.
Immigration protection while claims are pending.
Specialized tribunals for swift adjudication.

10. Political Context and Divergent Perspectives

10.1 The Liberal Government’s Position

The Liberal government under Prime Minister Mark Carney and Immigration Minister Lena Metlege Diab defends the Temporary Foreign Worker Program Canada as a vital response to “acute labour shortages.” They highlight inspections, penalties, and LMIA restrictions as proof of responsible management.

10.2 The Conservative Critique

By contrast, the Conservative Party, under Opposition Leader Pierre Poilievre, has taken an unequivocally critical stance. The Conservative position is that the TFWP has expanded well beyond its intended scope and is now directly undermining opportunities for young Canadians and domestic workers. Conservatives argue that the program has become a vehicle for wage suppression, systemic exploitation, and in some cases, outright fraud. They further contend that the Liberal government has turned a blind eye to abuses, prioritizing employer demands and political optics over the constitutional duty to protect Canadian citizens’ access to employment.

The Conservatives frame the TFWP not as an economic necessity but as a political convenience: a mechanism that allows Liberals to claim economic growth while masking structural unemployment and underemployment among Canadians. Pierre Poilievre has explicitly called for the program to be wound down or fundamentally restructured, arguing that Canada’s future prosperity depends on training, mobilizing, and incentivizing Canadian workers, not importing cheap, vulnerable labour from abroad.

10.3 A Conservative-Supportive Conclusion

On the balance of evidence and in light of legal and economic considerations, the Conservative position is compelling. While the Liberal defense rests on the argument of business necessity, this argument collapses when confronted with the realities of rising unemployment, wage stagnation, and systemic abuse of migrant workers. It is inconsistent with both the Charter principles of equality and fairness and with the government’s statutory obligations under labour and employment law to protect its own citizens first.

The TFWP, in its current form, is no longer serving a temporary or supplementary function; it has become a structural distortion of the Canadian labour market. This distortion benefits employers seeking to maximize profits but does so at the expense of Canadian workers, particularly youth, newcomers, and those seeking stable employment.

Accordingly, adopting the Conservative approach, whether through dismantling or radical restructuring of the TFWP, represents the legally sound, economically rational, and morally defensible pathway. Canada was indeed built on immigration, but immigration must remain a lawful and permanent pathway to nation-building, not a revolving door of temporary, exploitable labour.

Let Woodhaven Immigration help you craft a strategy to secure your future in Canada. Contact us today—your new life, career, and community await!

by Simon Deek

The Immigration System Facing a Crisis: Temporary Foreign Worker Program Canada Under Scrutiny – Legal, Economic, and Social Implications