Do You Need an Opinion Request Submission for a Canadian Work Permit?

Understanding Opinion Request Process for Canadian Work Permits

What they are, who can submit them, and how they support your immigration strategy.

When applying for a work permit under Canada’s International Mobility Program (IMP) or at a Port of Entry (POE), some situations involve more than simply submitting standard forms and documents. In certain cases, especially when it’s unclear whether an LMIA (Labour Market Impact Assessment) or even a work permit is required, employers or authorized representatives may submit what is known as an opinion request submission to the International Mobility Workers Unit (IMWU).

Why Is It Useful?

Getting this opinion in advance helps determine whether:

• A work permit is required

• The foreign worker is eligible for an LMIA exemption

This clarification can help avoid delays, reduce the risk of refusals, and give employers confidence in moving forward with the hiring process. It's especially helpful in urgent or time-sensitive cases, where certainty in the process is essential.

But what exactly is an opinion request submission? Who can submit one? And how does it support your hiring or immigration strategy?

Let’s explore.

What Is an Opinion Request?

An opinion request submission is a formal explanation, usually prepared by an employer, licensed immigration consultant, or legal representative, asking an immigration officer to assess specific elements of a case.

It’s typically used to:

• Justify the use of an LMIA exemption code (e.g., C10, C11, C12, or C16)

• Clarify complex or discretionary cases

• Support a work permit application at a Port of Entry

• Determine if a work permit is required at all

Although this submission is not a final decision from Immigration, Refugees and Citizenship Canada (IRCC), it can serve as an important supporting document in the overall application strategy.

Who Can Submit an Opinion Request?

Only employers (or their authorized representatives) can submit an opinion request application to the IMWU, and only under specific conditions:

• The foreign national must be outside Canada

• Must be a citizen of a visa-exempt country

If these two criteria are not met, an opinion request cannot be submitted, and the application must go through regular channels. The IRCC officer processing the work permit will then decide whether the applicant qualifies for an LMIA exemption.

When Is an Opinion Request Submission Useful?

These submissions are helpful in scenarios where:

• An employer wants confirmation that a work permit is required

• The application involves LMIA-exempt categories under the IMP

• The situation involves a discretionary exemption, such as:

  • Significant Benefit (C10)

  • Entrepreneurs or self-employed individuals (C11)

  • Intra-company transferees (C12)

  • Francophone Mobility (C16)

  • The Canada, United States and Mexico Agreement - CUSMA, formerly called NAFTA (exemption codes T34, T35, T36, T37, T38)

  • Reciprocal program (C20)

• There’s a need to clarify the nature of the employment offer or the applicant’s role before submitting the full application

In these cases, a well-prepared submission, supported by documentation, can guide the officer through the reasoning and increase the application's clarity and consistency.

Can an Opinion Request Improve Your Chances?

While an opinion request application does not guarantee approval, it can certainly help:

• Provide clarity around eligibility and exemption codes

• Demonstrate professional preparation and transparency

• Reduce processing risks by confirming elements before submission

• Strengthen the credibility of your work permit application

On the other hand, a vague or inaccurate submission can create confusion and delay the process. That’s why seeking professional support is highly recommended.

How Immigria Can Help?

At Immigria, we specialize in guiding employers and foreign workers through the nuances of LMIA-exempt work permit applications and opinion request submissions.

Our certified immigration consultants will:

• Determine whether an opinion request submission is appropriate for your situation

• Select the right LMIA exemption code and provide policy-backed reasoning

• Draft a clear and persuasive submission aligned with your immigration goals

• Ensure your documents are correctly prepared for IRCC or POE submission

We are here to help you navigate the process with confidence and strategy.

📩 If you're planning to hire a foreign worker or apply for a work permit in Canada, let our team guide you through the opinion request process.

👉 Book a consultation with Immigria

Is an Opinion Request Right for Your Case?

Not every work permit application requires an opinion request, but in cases where clarity around LMIA exemptions or work permit requirements is needed, it can be a highly effective tool. Whether you're an employer looking to hire internationally or a worker preparing to apply at the border, strategic preparation makes all the difference.

Let Immigria support you in evaluating your case, drafting a strong submission, and navigating Canadian immigration requirements with confidence.

📌 Disclaimer

This blog reflects the most accurate information available as of the date of publication. Immigration laws and policies are subject to change by the Government of Canada. Always consult a licensed immigration consultant or official sources for the latest updates.