Based on ongoing input received by CIC and HRSDC from provinces and territories, employers, industries, labour representatives and worker advocates, some of the concerns most often raised include:

• Lengthy processing times and delays in relation to the entire process of hiring a temporary foreign worker. Employers and workers have also raised concerns related to the length of time that it takes to extend Labour Market Opinions (LMOs), and work permits for foreign workers that are already in Canada.
• Complexity in the process, particularly with regard to LMOs and LMO exemptions, noting that while there might be options for simplifying the overall process, there are certain requirements that need to be maintained by the government concerning labour market impacts, worker protections and program integrity.
• Insufficient worker protections. While federal and provincial governments have introduced measures to improve worker protection through legislation, regulation, service delivery and information provision, some stakeholders argue that gaps in worker protection remain.
• The limited options for low-skilled temporary foreign workers to transition to permanent residence. While workers and employers often advocate for additional pathways to permanent residence for low-skilled temporary foreign workers, issues around long-term labour market needs, adaptability of low-skilled temporary foreign workers, the optimum mix of future immigrants to Canada, and government capacity to support integration, all need to be considered.

Another concern is that while the Temporary Foreign Worker Program was created to fill temporary shortages, an increasing number appear to be used to address long-term, structural labour gaps. Some stakeholders have raised concerns that some employers are using the Temporary Foreign Worker Program as a substitute for necessary adjustments such as investments in capital and (re)-training workers or adjustments in wages. Temporary foreign workers are one source of labour to fill labour and skills shortages, but questions have been raised as to whether we are making enough effort to hire unemployed or underemployed Canadians and permanent residents.