A New Layer of Transparency: Retain or Reject Applicants
Previously, Job Bank allowed employers to download applicant résumés as part of their mandatory LMIA recruitment efforts. Now, a new feature goes further: employers can retain or reject applicants directly within the platform.
This change adds a structured evaluation step, essentially transforming Job Bank from a simple job-posting portal into a basic applicant-tracking system.
Visible Decision-Makers: Who Retained or Rejected?
One of the most notable additions is that Job Bank will now display the name of the person who retains or rejects each applicant.
This means employers will need to ensure that:
- The correct representative is managing applications
- Decisions are documented within Job Bank
- The process is transparent and traceable
This level of visibility suggests a shift toward greater accountability in recruitment efforts—especially for employers seeking LMIA approvals.
Directional Push: Employers Must Review Applicants Themselves
While Job Bank hasn’t officially stated the reason behind these new controls, the intent is easy to read: they want actual employers—not consultants—to open, review, and evaluate résumé submissions from Canadian applicants.
For years, ESDC has emphasized that employers must make genuine efforts to hire Canadians before turning to foreign nationals. This update appears designed to enforce that expectation more strictly.
By tracking both the action (retain or reject) and the identity of the reviewer, ESDC may now verify:
- Whether the employer reviewed each application
- How each Canadian applicant was assessed
- Whether recruitment was genuine and meaningful
What This Means for LMIA Applications Going Forward
Employers should expect this feature to become a mandatory component of LMIA recruitment compliance.
It is highly likely that:
- Officers will request proof of retained/rejected applicants
- The Job Bank decision history will be reviewed during LMIA assessments
- Recruitment efforts may be questioned if consultants—not employers—appear as decision-makers
- Failure to use the new feature properly could delay or jeopardize LMIA approvals
This puts added responsibility on employers to manage or oversee the recruitment process directly, even when working with authorized representatives.
How Employers Should Prepare
To stay ahead of the change:
- Ensure employers—not consultants—log in and review all Canadian applicants
- Document recruitment reasoning carefully
- Keep consistent records across Job Bank and internal systems
- Train HR staff or designated hiring managers on the new feature
- Prepare to demonstrate genuine efforts to hire Canadians during the LMIA assessment
Please contact our firm if you have any additional questions.
