Working in Canada Without LMIA: ICT, CUSMA, GTS & Exemptions Explained

If you want to work in Canada, you often hear about the Labour Market Impact Assessment, or LMIA. Many people assume an LMIA is always required. That is not true. Canada allows several work permit routes that do not need an LMIA under the International Mobility Program. These include Intra Company Transfers, certain Free Trade Agreement categories such as CUSMA, significant benefit and reciprocal employment cases, and several open work permit options. In this guide, I will explain how LMIA-exempt categories work, what documents you need, where GTS fits in, and how an LMIA-exempt job offer can even help your PR later.

Phantom Immigration is led by a regulated Canadian immigration consultants. That matters because policy details change and your strategy must match the rules and your profile. The notes below are based on current IRCC and ESDC guidance, paired with the practical way we help clients prepare clean, decision-ready files.

LMIA vs LMIA-exempt in plain language

• LMIA lives under the Temporary Foreign Worker Program. The employer proves there is no Canadian or PR available, then applies for an LMIA. If approved, the worker uses it to apply for a work permit.
  
• LMIA-exempt is part of the International Mobility Program. Instead of an LMIA, the employer submits an offer of employment through IRCC’s portal and pays the employer compliance fee. The worker then applies for a work permit that is exempt from LMIA because it serves a broader Canadian interest such as trade agreements, company transfers, or public policy.
  

Key point. You still need a valid job offer and a proper work permit application. LMIA-exempt does not mean paperwork-free. Employers also have compliance duties once you arrive.    

Route 1. Intra Company Transfer work permits 

Who it is for
Employees of a foreign company that has a qualifying relationship with a Canadian entity. Typical roles are executive, senior manager, functional manager, or specialized knowledge professional.

Core requirements

• A qualifying corporate relationship between the foreign and Canadian entities.
  
• You have been employed by the foreign entity for at least one year in the last three years, usually in a similar role.
  
• You will transfer to work in Canada in an executive, managerial, or specialized knowledge position.
  
• You meet wage and licensing expectations for the role in Canada.
  

Documents that strengthen your file

• Corporate structure chart, share registers, and proof of common ownership or control.
  
• Detailed job descriptions showing managerial control or advanced proprietary knowledge.
  
• Pay stubs and employment letters covering the one year of prior employment.
  
• Evidence of the Canadian operation’s activities, leases, and payroll plan.
  

Processing insight
IRCC updated and clarified ICT guidance in late 2024, with more emphasis on proving genuine managerial control or specific, company-unique knowledge. Strong role descriptions and internal evidence reduce back-and-forth.  

Outcome
ICTs are LMIA-exempt and issued under the International Mobility Program. The employer still uses the Employer Portal and pays the compliance fee.  

Route 2. CUSMA professionals and other free trade agreement categories  

Canada has trade agreements that allow certain business persons to work in Canada without an LMIA. CUSMA covers citizens of the United States and Mexico. Similar pathways exist under other agreements such as GATS and several bilateral FTAs.    

Common CUSMA categories 

• Professionals. You have a pre-arranged job in an occupation on the CUSMA list and meet education or licensing rules.
  
• Intra company transferees. Similar to ICT above, but grounded in the trade agreement.
  
• Traders and investors. You carry on substantial trade in goods or services, or you direct and develop operations into which you or your firm have invested.   
  

Why this helps
These routes are LMIA-exempt. The employer uploads an offer through the Employer Portal and you apply for a work permit with proof you fit the specific category.    

Tip
If your nationality falls under another FTA such as CCFTA for Chile or similar agreements, check whether your occupation is covered under a professionals list and whether licensing is needed before you start.  

Route 3. Significant benefit to Canada, code C10 

Some applicants can obtain an LMIA-exempt work permit by showing that their work will bring clear economic, social, or cultural benefits to Canada. Think founders with a record of innovation, artists with national profiles, or specialists whose work advances public interest. The bar is high, so strong evidence matters. 

What officers look for 

• Unique expertise that is hard to source in Canada.
  
• Endorsements, press, patents, grants, or industry awards.
  
• Letters from Canadian institutions or associations explaining the public interest.
  

Route 4. Reciprocal employment, code C20 

C20 allows LMIA-exempt work where Canadians receive similar opportunities abroad. This often applies to exchange programs, sports and entertainment seasons, or sectors with structured reciprocity.You still need a genuine offer, program documents, and proof of reciprocity.

Where open work permits fit 

Open work permits do not tie you to one employer. Many of them are LMIA-exempt under the International Mobility Program. Examples include Post-Graduation Work Permits, some spousal open work permits tied to study or PR, and International Experience Canada categories for youth from partner countries. Processing targets and eligibility can change by season, so plan ahead. 

Where the Global Talent Stream fits 

The Global Talent Stream is often confused as an LMIA-exempt program. It is not. GTS requires an LMIA under ESDC. The difference is speed and structure. Employers follow strict wage and benefit rules and submit a Labour Market Benefits Plan. The processing fee is 1,000 CAD per position and timelines are usually faster than regular LMIAs. If you qualify for GTS, it is a powerful LMIA route, but it is still an LMIA.    

LMIA-exempt work permits and your PR strategy 

An LMIA-exempt job offer can help your permanent residence plan. Under Canada Express Entry, a valid job offer can count even if it is LMIA-exempt when it is issued under an international agreement such as CUSMA or GATS, or under a federal-provincial agreement. You must have worked for the employer for at least one year and meet other rules. This is a useful bridge from work permit to PR.    

Step by step: employer actions under the International Mobility Program 

1. Confirm you qualify for an LMIA-exempt category.
   
2. Create or use your Employer Portal account.
   
3. Submit the offer of employment and pay the employer compliance fee.
   
4. Receive the offer of employment number.
   
5. Give that number to the worker so they can apply for their work permit.
   
6. Maintain records and comply with inspections and conditions after the worker arrives. Penalties apply for non-compliance.   
   

Step by step: worker actions for a clean application 

1. Gather identity documents, education proof, licenses, and letters that match the category.
   
2. Prepare job descriptions that clearly map to your code, duties, and seniority.
   
3. Add proof of past employment and pay that shows you meet the role level.
   
4. Include corporate relationship evidence for ICT, or category-specific proof for CUSMA, C10, or C20.
   
5. Upload the offer of employment number from your employer.
   
6. Plan for biometrics and medicals where required.
   
7. If in doubt about eligibility, seek a pre-clearance opinion from the International Mobility Workers Unit. IMWU opinions are helpful but not binding, which means the officer who decides your case can still reach a different conclusion.   
   

Evidence checklists by category 

ICT checklist 

• Employment letter that confirms role, start date, and continuous full-time status.
  
• Proof of one year of prior employment within three years.
  
• Detailed role description showing executive control, managerial span, or specialized knowledge.
  
• Corporate documents proving the qualifying relationship.
  
• Canadian payroll plan and location details.
  

CUSMA professional checklist

• Proof of citizenship from the United States or Mexico.
  
• Job offer in an eligible profession with required education or license.
  
• Letters from regulators if pre-licensing is required.
  

C10 significant benefit checklist

• Portfolio of achievements, patents, grants, awards, or media.
  
• Letters from Canadian bodies describing the benefit to Canada.
  
• Market analysis or economic impact notes if relevant.
  

C20 reciprocal employment checklist

• Program or league rules showing reciprocity.
  
• Evidence that Canadians receive similar spots abroad.
  
• Contracts and season schedules.   
  

Common mistakes that lead to refusals

• Mismatched duties and NOC. Titles are not enough. Officers read duties line by line.
  
• Thin corporate proof for ICT. A short letter without hard evidence of the relationship is risky.
  
• CUSMA without licensing. If your profession needs a license, bring proof or show realistic steps.
  
• C10 without a clear benefit story. You need concrete evidence, not vague claims.
  
• Assuming GTS is LMIA-exempt. It is not. It is fast but still an LMIA.  
  

Timelines and what to expect

Processing times change by visa office and season. LMIA-exempt routes often move faster than regular LMIA files because there is no labour market test, yet the quality of your evidence still drives outcomes. GTS LMIA can be fast once the plan is approved, but you should still plan for the work permit stage after the LMIA.   

Why work with Phantom Immigration

Phantom Immigration provides strategy, file preparation, and submission for LMIA-exempt and LMIA routes. Your file is handled by a Regulated Canadian Immigration Consultant, with a focus on compliance and clarity. If you are a founder transferring to your Canadian startup, a professional coming through CUSMA, or a specialist on a C10 case, we build a file that is easy for an officer to read and verify.

How we help

• Confirm the right category and eligibility.
  
• Draft role descriptions and map duties to the correct code.
  
• Build a complete set of corporate and personal evidence.
  
• Guide the employer through the portal steps.
  
• Prepare you for biometrics, medicals, and post-arrival compliance.
  

Quick FAQ

Is a visitor in Canada allowed to apply for a work permit inside Canada
There are limited in-Canada application options that change over time. Check the latest IRCC updates before you plan a switch. If you need a fast start, you may consider a border or consulate filing depending on your eligibility and travel history. When rules are in flux, it is safer to plan the category first and file from the correct location.

Can an LMIA-exempt job offer help my Express Entry profile
Yes, if the offer is issued under an international agreement such as CUSMA or GATS or under a federal-provincial agreement and you have one year of full-time work with that employer, it can meet the valid job offer test used for extra points in Express Entry.   

Is Global Talent Stream faster than LMIA-exempt routes
Sometimes.GTS aims for speed but it is still an LMIA with strict wage and benefits rules plus a Labour Market Benefits Plan. Compare both options before choosing.

Final word

Working in Canada without an LMIA is possible through routes like ICT, CUSMA, significant benefit, reciprocal employment, and certain open work permits. Each option has precise rules. If you are unsure where you fit, get a clear assessment and a document plan before anyone submits forms in the portal. That single decision saves time and protects your future PR options.