Track the 90-day LMIA/CAQ deadline to keep in-Canada TFWP renewals authorized

The 90-day clock starts at IRCC receipt

When an in-Canada TFWP renewal is waiting on an LMIA or CAQ, the date that matters is 90 days from IRCC receipt. If the required LMIA or CAQ is not in the file by day 90, IRCC may refuse the extension as incomplete.

IRCC published the change extending the in-Canada TFWP work permit hold from 60 days to 90 days on August 21, 2026. The in-Canada TFWP concurrent-processing hold now gives applicants 90 days, not 60, to submit proof of a positive or neutral LMIA after filing a work permit application. The same 90-day deadline applies when the missing document is a CAQ for an in-Canada work permit extension.

The 90-day window is the filing deadline, not a guarantee that the extension will be approved. A positive or neutral LMIA is the document the hold is waiting for. For Quebec, the CAQ is the document that must be submitted within the same 90-day window. The extension from 60 days to 90 days does not change the consequence of an incomplete file.

For in-Canada TFWP renewals, the tracker should show the intake date, not the permit expiry date. Record the receipt date as soon as IRCC receives the application. The 90-day count runs from that date, not from the date the team prepares the file. The permit expiry date can still matter for the hold trigger, but it is not the filing deadline. That keeps the team from treating expiry as the real deadline.

The hold applies only to a ready file

The concurrent-processing hold is conditional. The file must already show the three LMIA trigger conditions before the 90-day window can protect the renewal. If one condition fails, the file can still move toward refusal.

Sufficient lead time is part of the condition, not a courtesy. The team should not assume a late LMIA filing will still qualify. The condition is about the state of the file when the hold is needed. The employer should not treat the 90-day window as time to fix a late or incomplete LMIA filing.

Keep the evidence in the same tracker as the receipt date. The employer should be able to show the LMIA filing confirmation and the status of the LMIA decision. The worker should be able to show the current permit and the extension application. Those documents are the evidence that the hold was available. The tracker should show whether the LMIA application was complete when filed.

If any trigger condition is not met, do not rely on the 90-day hold. Move to the stop-work plan early. The refusal risk is the same whether the file is late on the LMIA or the CAQ.

Run the day-90 checklist before the certificate is due

Use this list when the receipt date is 90 days away. Each item is a yes/no check. If any answer is no, the stop-work plan is the next step.

• Confirm the current permit expires in two weeks or less.
• Confirm the employer’s LMIA application is complete and was filed with enough lead time.
• Confirm no LMIA decision has been made yet.
• Calendar 90 days from the date IRCC receives the work permit application.
• For Quebec, confirm the CAQ will be submitted within 90 days of receipt.
• Prepare a stop-work and refusal plan if the LMIA or CAQ is not submitted in time.

The list is a control point, not a cure. A late certificate can still leave the file incomplete. Maintained status stops once the pending application receives a decision, including at the end of the 90-day hold. The worker must stop working at that point. The stop-work plan should be triggered by the missing certificate, not by a guess about the decision.

Keep the checklist in the same file as the receipt date, the permit expiry date, the LMIA filing confirmation, the LMIA decision status, and the stop-work owner. The owner should be able to show why the stop was made, when it was made, and which document was missing.

The refusal plan is part of the filing plan

Maintained status is the bridge that lets the worker keep working while the application is pending. It is tied to the pending application. It also does not survive a refusal.

A refusal plan should name the person who authorizes the stop, the date work stops, and the message to the worker. It should also say who updates payroll, access, and project assignments. The plan should be ready before the 90-day mark, not after the refusal. The refusal plan should be tied to the same receipt date used for the 90-day calendar.

The stop message should be short and factual. It should say the work stop is tied to the pending application and the refusal risk. It should not speculate about a future decision.

The employer’s exposure is separate from the worker’s status. Continuing to employ the worker without authorization after a refusal creates compliance risk under the TFWP. The cleanest control is a written stop instruction tied to the refusal or the end of the hold. The stop instruction should be written, not verbal.

The refusal plan should be tested before the deadline, not drafted after the fact. A short internal rehearsal is enough. The standard is a clear stop in writing. Keep the stop instruction with the refusal notice in the same folder. The owner should be able to show the stop was tied to the refusal or the end of the hold.