How far the proposal has advanced: from a 2025 planning entry to the edge of pre-publication
IRCC first added this regulatory initiative to its Forward Regulatory Plan on July 2, 2025. At that stage, the listing described the policy objective but offered little detail on timing or next steps. The current page, dated April 7, 2026, reflects three significant developments. First, the target for pre-publication of the proposed amendments in Part I of the Canada Gazette is now set for spring or summer 2026. Second, broad consultations with provinces and territories were completed in February 2025, and private-sector stakeholders were consulted in November 2025. Third, a 30-day public comment period will follow pre-publication in the Canada Gazette, giving applicants, employers, immigration professionals, and the public a structured opportunity to provide feedback. In short, this is no longer a preliminary item in a federal planning document — it has moved through two rounds of stakeholder engagement and is approaching the formal regulatory publication stage.
What IRCC is proposing: authority to require third-party language test results
The official title of the initiative is "Regulations amending the Immigration and Refugee Protection Regulations, language testing requirements for certain work permit applicants under the International Mobility Program," and its enabling legislation is the Immigration and Refugee Protection Act. Through the amendment, IRCC would gain authority to require applicants to submit language proficiency test results from a designated third-party organization, demonstrating that they meet applicable language proficiency requirements.
The International Mobility Program is a temporary workers program managed by IRCC that facilitates the entry of individuals in support of Canada's broad economic, social, and cultural objectives. IRCC has said the amendment is intended to improve the reliability, transparency, and efficiency of language assessments under the IMP, and to help ensure that only those best positioned to integrate into the labour market — and potentially transition to permanent residence — obtain a work permit.
Why this is not a final rule yet
It is important to underline that the proposed amendment has not been published in the Canada Gazette, and no regulatory text is publicly available. Pre-publication in Part I of the Canada Gazette is a consultation step, not the final enactment of the rule. After pre-publication, the public has 30 days to submit written comments on the proposed regulations. IRCC reviews those comments and may revise the proposal before final publication in Part II of the Canada Gazette, which is the point at which the regulation would officially come into force.
This means the current proposal could still be modified, delayed, or narrowed based on feedback received during the comment period. Anyone following this development should understand that, as of now, no applicant is required to submit language test results as a result of this proposal.
Which work permits could be affected: spousal open work permits seen as the focus
The official regulatory initiative page describes the affected group as "certain work permit applicants under the International Mobility Program" and references "certain IMP streams," but it does not list specific work permit categories. The IMP includes both employer-specific and open work permit categories, and its streams span a wide range of permits — including post-graduation work permits (PGWPs), spousal open work permits, working holiday visas, bridging open work permits, intra-company transferees, reciprocal employment permits, and permits issued under free trade agreements.
Among these, spousal open work permits are expected to be the category most significantly affected by the new rule. The final list of affected streams, however, will not be known until IRCC publishes the regulatory text in the Canada Gazette.
What the language test requirements might look like
IRCC's proposal refers to language proficiency test results from a designated third-party organization, but the exact accepted tests, minimum scores, affected streams, exemptions, and implementation date all remain unknown.
Other Canadian immigration programs already use designated third-party English and French language tests for eligibility and selection. Express Entry applicants, for example, currently submit results from tests such as IELTS General Training, CELPIP General, TEF Canada, or TCF Canada to demonstrate their Canadian Language Benchmark (CLB) or Niveaux de compétence linguistique canadiens (NCLC) levels. Post-graduation work permit applicants who graduated on or after November 1, 2024 are already required to meet a minimum of CLB 5 or CLB 7, depending on their program type.
It is reasonable to expect that IRCC may draw on a similar framework of designated tests for the IMP language requirement, but no test name, score level, or validity period has been confirmed for this specific proposal. Applicants should not assume that any particular test or score threshold applies to them until IRCC publishes the regulatory details.
What it means for open work permit applicants
Some open work permits under the IMP could be affected if they are included in the final regulatory text. IRCC, however, has not confirmed which open permit categories would be covered by the proposed language testing requirement.
Open work permits account for a substantial share of the IMP's annual admissions. Under Canada's 2026–2028 Immigration Levels Plan, the admissions target for IMP work permits in 2026 is 170,000 — the bulk of the year's total target of 230,000 new work permit holders, with roughly 60,000 of the remainder coming through the Temporary Foreign Worker Program (TFWP). At the same time, hundreds of thousands of work permits are already expiring across the country, intensifying demand for extensions and transitions.
Any open work permit holder with a valid permit, or anyone planning to apply, should closely monitor the Canada Gazette pre-publication to see whether their specific permit category is named. Until the regulatory text is published, no open work permit applicant is required to take a language test as a result of this proposal.
What it means for spousal open work permit applicants
Spousal open work permits are part of the broader open work permit conversation. Previous analysis published in Immigration News Canada's 2025 coverage discussed the possibility that SOWPs could be included. The official regulatory initiative page dated April 7, 2026, however, does not specifically name spousal open work permits; IRCC's language refers only to "certain work permit applicants under the International Mobility Program" and "certain IMP streams."
Even so, SOWP applicants should treat this as a development worth monitoring closely, as the signs that the rule would apply to them appear relatively clear. SOWP eligibility rules have already been significantly tightened in recent years. Since January 21, 2025, SOWPs have been available only to the spouses of workers in TEER 0, TEER 1, and specific designated TEER 2 or TEER 3 occupations; most TEER 2 and TEER 3 occupations in fields such as business, finance and administration, sales and service, and manufacturing — together with TEER 4 and TEER 5 occupations — are no longer eligible to support a spousal OWP application. In addition, the principal applicant must now have at least 16 months remaining on their work permit at the time the spouse submits the application. Whether language testing becomes an additional eligibility requirement for SOWP applicants will depend entirely on what IRCC includes in the Canada Gazette pre-publication.
Why it matters for temporary residents seeking permanent residence
IRCC has indicated that stronger official language proficiency could support worker retention by improving the ability of workers to transition from temporary to permanent residence. This aligns with Express Entry's existing emphasis on language ability, which is one of the most heavily weighted factors in the Comprehensive Ranking System (CRS).
If language testing becomes a requirement at the work permit stage, temporary residents may need to demonstrate English or French proficiency earlier in their immigration pathway than current rules require. For temporary workers already planning to apply for permanent residence through Express Entry or a Provincial Nominee Program (PNP), holding valid language test results could serve a dual purpose. IRCC believes the proposed rule could also encourage temporary residents to invest in language preparation sooner, strengthening both their career prospects and their long-term settlement outcomes.
It is worth noting that the federal government is continuing to adjust the composition of Canada's temporary population, with a goal of reducing temporary residents to below 5% of the total population by the end of 2027. At the same time, Canada has opened a new permanent residence pathway for more than 33,000 foreign workers who have "established strong roots" in their communities between 2026 and 2027. Front-loading language ability at the work permit stage is unfolding against this broader policy backdrop.
What IRCC still has not confirmed
Despite the progress reflected in the April 7, 2026 update, several critical details remain unconfirmed.
| Issue | What IRCC has confirmed | What is still unknown |
|---|---|---|
| Language testing | IRCC may be authorized to require designated third-party language test results | Which exact IMP streams will be affected |
| Timing | Canada Gazette pre-publication targeted for spring/summer 2026 | The final implementation date |
| Comment period | A 30-day comment period will follow pre-publication | Whether the proposal will be revised after comments |
| Consultations | Provinces, territories, and private-sector stakeholders were consulted in 2025 | How feedback shaped the final draft |
| Open work permits | Some IMP work permit categories could be affected if included | Whether specific open permit categories, including SOWPs, will be named |
As of the April 7, 2026 page update, the following items remain officially unconfirmed by IRCC: which IMP streams will be affected; whether specific open work permit categories will be included; whether spousal open work permits will be included; the accepted language tests; the minimum language score levels; exemptions for any category or group of applicants; transitional rules for applicants with pending applications; and the final implementation date.
What applicants and employers should watch next
| Group | What the update could mean |
|---|---|
| IMP work permit applicants | Some may need language test results if their stream is included |
| Open work permit applicants | Should monitor updates, though inclusion is not confirmed |
| SOWP applicants | Not specifically named by IRCC, but should watch for Canada Gazette details |
| Employers | Candidate pools could narrow if testing becomes an eligibility criterion |
| Temporary residents seeking PR | Language ability may become more important earlier in the pathway |
| RCICs and immigration lawyers | Should prepare to review the Canada Gazette draft during the comment period |
Practitioners broadly advise that applicants should not rush to book a language test on the strength of this proposal alone. The more prudent step is to monitor the Canada Gazette for the pre-publication text and to follow official IRCC communications for any updates on timing or scope. Employers who hire through the IMP should discuss the potential impact with their immigration advisors once the regulatory text is available. Immigration consultants and lawyers, meanwhile, should prepare to review the draft and advise clients during the 30-day comment period — the most effective window for stakeholder input.
What comes next
IRCC's proposal to require language test results from certain International Mobility Program work permit applicants is no longer a preliminary planning item. The initiative has moved through provincial, territorial, and private-sector consultations and is now approaching the Canada Gazette pre-publication stage. The spring or summer 2026 target means the regulatory text could appear within the coming weeks or months.
Once it is published, applicants, employers, and immigration professionals will get their first look at which IMP streams are affected, what language proficiency levels are required, and what exemptions may apply. Until then, every claim about specific affected categories, required tests, or minimum scores remains speculative. The 30-day comment period after pre-publication will be the public's first formal opportunity to shape the final version of the regulation. This is a regulatory development that touches a wide range of people in Canada's immigration system — and at a time when major legislative changes are already reshaping how the government manages temporary and permanent resident pathways, staying informed remains the most effective form of preparation.
