Canada: Ontario Implements Key Reforms to the Immigrant Nominee Program

Discretionary in-person interview requirement. The OINP now has the discretion to require in-person interviews with employers, through a designated representative, and/or foreign national applicants, introducing a new procedural element that was not previously part of the application process.

·       This measure is intended to enhance the program’s ability to verify the credibility and authenticity of applications.

·       Employers and applicants should anticipate the possibility of in-person meetings during the adjudication process, which may involve logistical challenges and travel-related expenses.

·       Affected parties are encouraged to consult with their immigration professionals to help stay informed and better positioned to respond to potential program inquiries.

Authority to return applications before nomination.

·       The OINP now has expanded discretion to return applications at any point before a nomination certificate is issued. If an application is returned, the applicant and/or their authorized representative will be notified, and the full application fee will be refunded.

·       Previously, applications were typically only returned in cases of clear ineligibility or significant errors. Under this new authority, however, the program may return applications based on broader considerations, such as reaching the annual nomination allocation, shifting alignment with Ontario’s evolving labour market priorities, or concerns related to program integrity. This means that even applications that meet all formal eligibility criteria could still be returned if they no longer align with the program’s current objectives.

• Update – November 7, 2025: Ontario has expanded the criteria under which OINP applications awaiting a final decision may be returned, effective immediately. The revised framework allows the province to consider a wider range of policy, infrastructure, and applicant factors when considering returning applications prior to rendering a decision. These include federal and provincial policy priorities, regional unemployment rates, housing availability, and Ontario’s capacity to deliver health and social services, as well as individual factors such as work authorization, current employment in Ontario, job offers, language proficiency, education, wage history, and Canadian work experience.

·       This creates a heightened level of uncertainty for applicants, as meeting all requirements at the time of submission does not guarantee continued processing or nomination. If an application is returned for any of these reasons, the individual would need to re-enter the candidate pool and await a future invitation to apply, with no assurance of when or if that invitation will come.

·       Applicants should be aware of this added layer of discretion and consider it when planning timelines and managing expectations under the OINP.

New submission timelines.

·       The OINP has revised its application timelines to allow more structured and transparent coordination between employers and applicants. Once an employee’s Expression of Interest (EOI) is selected, both parties will be notified by email. The employer now has 14 calendar days to submit the job offer through the employer portal. After that, the employee has up to 17 calendar days from the date of the invitation to submit their application, including payment.

·       This marks a shift from the previous 14-day window for applicants and introduces clearer sequencing of responsibilities.

This change allows employers dedicated time to complete their portion and gives applicants a brief extension. However, if either party misses their deadline, the opportunity is withdrawn, and a new EOI and job offer must be submitted for future consideration. Timely coordination between employers and applicants will be critical.