A proposed regulatory change to Canada’s open work permit framework is moving closer to official publication. Immigration, Refugees and Citizenship Canada (IRCC) has updated its Forward Regulatory Plan to indicate that a proposed amendment — which would require language proficiency test results from certain work permit applicants under the International Mobility Program (IMP) — is now targeting a spring or summer 2026 pre-publication date in the Canada Gazette.
Critically, this is not yet a final rule. No open work permit applicants are currently required to submit language test results because of this proposal. Here is a clear summary of where the proposal stands and what it could mean when it does take effect.
What IRCC’s 2026 Update Says
IRCC first added this regulatory initiative to its Forward Regulatory Plan in July 2025. The most recent update, dated 7th April 2026, includes three significant developments:
- The target for pre-publication in the Canada Gazette, Part I, has been updated to spring or summer 2026
- Wide consultations with provinces and territories were completed in February 2025, and industry stakeholder consultations concluded in November 2025
- A 30-day public comment period will follow Canada Gazette pre-publication — providing applicants, employers, immigration professionals, and the public a formal opportunity to submit feedback
This is not a preliminary planning listing. The proposal has progressed through two rounds of stakeholder consultations and is now approaching the formal regulatory publication phase.
What IRCC Is Proposing
The formal proposal is titled: Regulations Amending the Immigration and Refugee Protection Regulations — language examinations, conditions for specific work permit candidates under the International Mobility Program.
IRCC is proposing an amendment that would allow the department to require applicants to submit language proficiency test results from an approved third-party institution. The stated goal is to improve the reliability, clarity, and efficiency of language assessments under the IMP — and to help ensure that only candidates well-positioned to integrate into the Canadian labour market and potentially transition to permanent residency receive open work permits.
Why This Is Not Yet a Final Rule
The proposed amendment has not yet been published in the Canada Gazette, and no regulatory announcement has been made. Pre-publication in Canada Gazette, Part I, is a consultation stage — not the final step. After pre-publication:
- The public has 30 days to submit written feedback on the proposed regulations
- IRCC reviews those submissions and may revise the proposal before finalising it
- The proposal only becomes law upon final publication in Canada Gazette, Part II
The current proposal could still be modified, delayed, or narrowed depending on feedback received during the comment period.
Which Work Permits Could Be Affected
IRCC has described the affected group as “specific work permit candidates under the International Mobility Program” — referencing “specific IMP streams” without naming them. The IMP covers a broad range of categories including:
- Post-Graduation Work Permits (PGWP)
- Spousal open work permits
- Working Holiday Visas
- Bridging Open Work Permits (BOWP)
- Intra-company transferees
- Reciprocal employment permits
- Permits issued under free trade agreements
Spousal open work permits are widely anticipated to be among the most significantly affected category. The full list of impacted streams will not be confirmed until IRCC publishes the regulatory statement in the Canada Gazette.
What Language Tests Could Be Required
The proposal references results from an approved third-party institution. The specific examinations, minimum score thresholds, applicable streams, exemptions, and enforcement dates are not yet publicly confirmed.
For context, Canada already uses approved language tests in other immigration streams. Express Entry candidates submit results from IELTS General Training, CELPIP General, TCF Canada, or TEF Canada. Post-Graduation Work Permit applicants who completed studies on or after 1st November 2024 must already meet a minimum of CLB 5 or CLB 7, depending on their programme level.
What This Means for Open Work Permit Applicants Right Now
Until the regulatory statement is formally published:
- No open work permit applicant is currently required to submit language test results as a result of this proposal
- Applicants who currently hold a valid open work permit are not affected by the proposal at this stage
- All applicants should monitor the Canada Gazette pre-publication for confirmation of which specific permit categories are listed as affected
Why This Matters for Temporary Residents Pursuing Permanent Residency
IRCC has indicated that strong official language skills can support employee retention and help temporary residents transition more effectively from temporary status to permanent residency. If language tests become a condition at the work permit stage, temporary residents may need to demonstrate English or French proficiency earlier in their Canadian immigration journey than current rules require.
For those already planning to apply for PR through Express Entry or a Provincial Nominee Program, having a valid language test result on file could serve a dual purpose — satisfying the work permit language requirement and providing the language scores needed for the PR application itself.
Conclusion
Canada’s proposed language test requirement for open work permit applicants is progressing through the regulatory process, with Canada Gazette pre-publication expected in the coming months. The proposal is not yet law, and no action is currently required from applicants. However, those holding or planning to apply for open work permits — particularly spousal open work permits — should watch for the Canada Gazette pre-publication closely, note the 30-day public comment window, and consider proactively taking an approved language test if a PR application is part of their longer-term plan.