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CERC Response to IRCC Consultations on Reforms to Express Entry’s Federal High Skilled Programs and Comprehensive Ranking System

The Canadian Employee Relocation Council (CERC) welcomes Immigration Refugee Citizenship Canada’s (IRCC) direction to modernize and simplify Canada’s Federal High Skilled (FHS) immigration programs. The proposed consolidation of pathways, recalibration of the Comprehensive Ranking System (CRS), and emphasis on economic outcomes represent important steps toward a more coherent and predictable system. Employers and globally mobile talent will benefit from clearer rules, reduced administrative complexity, and a selection model that reflects labour market needs.

Several elements of the proposal require clarification to avoid unintended consequences for temporary residents, regulated occupations, skilled trades, multinational assignees, and employers managing compliance obligations. CERC’s recommendations are intended to strengthen program integrity, enhance fairness, and support both attraction and long‑term retention of high skilled talent.

1. Direction to Simplify Federal High Skilled Programs

CERC supports the intent to simplify and streamline the FHS programs. Employers require predictability and assurance that high skilled workers can transition to permanent residence without unnecessary barriers. A unified program structure would reduce confusion, eliminate duplication, and improve consistency in processing.

CERC also supports the shift toward a simplified design that emphasizes integrity, economic outcomes, and operational efficiency. However, several areas require careful consideration:

• Avoiding overreliance on formal education. In many sectors, vocational training and experience are stronger indicators of labour market value than post‑secondary credentials. Adaptability factors should reflect the realities of skilled trades and technical occupations.
• Clarifying wage measurement. Employers require clear guidance on how wages will be assessed to avoid compliance risk and inconsistent interpretation.
• Recognizing licensure pathways. Obtaining Canadian licensure, particularly in regulated professions, can take several years. Partial points should be considered for candidates with licensure applications in progress.
• Supporting defence‑sector talent. A focus on Canadian Armed Forces recruitment should not exclude highly skilled civilian specialists who support Canada’s defence ecosystem.

Retention should be treated as a core policy objective. Employers experience turnover, recruitment cycles, and productivity losses when workers face PR insecurity, licensing delays, or unpredictable processing.

2. Impact on Client Experience and Operational Efficiency

Merging the CEC, FSWP, and FSTP into a single FHS program would improve client experience. A unified program would:

• Reduce confusion regarding eligibility
• Eliminate administrative duplication
• Provide employers with a more predictable framework
• Ensure consistent assessment of candidates

Simplifying the CRS to emphasize Canadian work experience, high wage employment, and valid job offers aligns selection with economic outcomes. Recognition of apprenticeship pathways and trade certifications would strengthen Canada’s ability to attract and retain skilled trades talent.

These changes would support more efficient resource allocation and faster selection of qualified individuals.

3. Opportunities and Challenges of Merging Programs

CERC supports consolidating the three federal programs, particularly given the introduction of category-based selection, which now fulfills many of the functions previously addressed through separate streams.

Key benefits include:

• A single eligibility framework
• Improved operational efficiency
• Greater certainty for employers supporting employees through Express Entry

CERC supports the proposed minimum thresholds: a Canadian high school credential or equivalent, CLB or NCLC 6, and one year of cumulative TEER 0 to 3 experience acquired in Canada or abroad.

IRCC should ensure the following:

• Full inclusion of TEER 2 and 3 occupations
• No unintended displacement of skilled trades candidates
• Clear transition guidance for current FSTP candidates

CERC Recommendations

• Publish transition guidance for candidates currently in the Express Entry pool
• Confirm full inclusion of TEER 2 and 3 occupations
• Monitor pool composition after consolidation to identify unintended impacts

4. Refocusing the CRS on Economic Outcomes

CERC supports aligning CRS factors with measurable economic outcomes. This approach can strengthen public confidence in the immigration system by demonstrating that immigration selection is orderly and economically beneficial.

Areas of Alignment

• Recognition of Canadian licensure
• Recognition of Canadian study
• Family related factors, including spouse and sibling in Canada

Areas Requiring Refinement

a. Rewarding Canadian employment in high wage occupations

Using occupation level average wages may distort selection. For example, a highly compensated specialist may fall below a threshold based on occupational averages, while a lower paid occupation may exceed it. Occupational averages do not reflect individual productivity or specialization.

Individual wages, supported by verifiable payroll or job offer documentation, provide a more accurate and integrity focused measure of economic contribution. They are also less susceptible to manipulation than job titles or NOC classifications.

Safeguards such as regional benchmarking, hourly wage normalization, minimum duration thresholds, and alignment with LMIA frameworks can address equity concerns.

b. French language policy

If category based French draws continue, CRS points for French proficiency should be removed to avoid double counting. French draws should be treated as a cultural and linguistic initiative rather than an economic selection factor.

c. Defining Canadian work experience

Excluding work experience paid by foreign sources would disadvantage multinational assignees who contribute to Canadian operations from their first day in Canada. Their experience should continue to count toward Express Entry.

5. Opportunities and Challenges in Refocusing the CRS

Opportunities

• Greater precision through individual wage metrics
• Stronger program integrity through reduced NOC manipulation
• Better alignment of language policy with economic objectives
• Broader recognition of genuine labour market participation

Challenges

• Equity considerations across regions and sectors
• Operational complexity in wage verification
• Need for clear definitions of eligible work experience
• Risks associated with employer-based point allocation

A CRS grounded in demonstrable economic outcomes, supported by clear definitions and verification mechanisms, would strengthen selection precision and public confidence.

Conclusion

CERC supports IRCC’s commitment to modernizing Canada’s economic immigration system. Simplification, integrity, and economic outcomes should guide the next generation of Express Entry reforms. A unified FHS program and a recalibrated CRS can create a more predictable and transparent system, provided that implementation details are designed to avoid unintended impacts on employers, regulated professions, skilled trades, and multinational assignees.

CERC encourages IRCC to prioritize clarity, transition planning, and retention focused policies that support long term labour market stability. By grounding reforms in labour market realities and employer experience, Canada can strengthen its position as a global leader in attracting and retaining high skilled talent.

CERC looks forward to continued collaboration with IRCC as these reforms advance.

Efficient cross‑border mobility is essential to North American competitiveness, innovation, and economic growth. However, many organizations continue to encounter administrative challenges that affect the movement of Business Visitors, Traders and Investors, and Intra‑Company Transferees.

Your participation in this brief survey is vital. The insights collected will directly shape the recommendations that CERC, WERC and our partners will present to both the U.S. and Canadian governments as part of a coordinated effort to modernize the administration of Chapter 16 and strengthen cross‑border mobility.

All responses are confidential. Individual organizations will not be identified, and only aggregate findings will be shared.

Click here to access the survey

Please complete the survey by May 31, 2026.

Amendments are being proposed to the Regulations to introduce a new federal high skilled immigration class with streamlined eligibility requirements, and repeal the existing Federal Skilled Worker Class, Canadian Experience Class and Federal Skilled Trades Class.

CERC met with IRCC officials earlier this week to learn more about the changes and share our views.

CERC welcomes IRCC’s overall direction to modernize and simplify Canada’s Federal High Skilled immigration programs. The proposed consolidation of pathways, recalibration of the Comprehensive Ranking System (CRS), and emphasis on economic outcomes represent meaningful steps toward a more coherent, predictable, and efficient system. Employers and globally mobile talent will benefit from clearer rules, reduced administrative complexity, and a selection model that better reflects real labour‑market needs.

At the same time, several elements of the proposal require further clarification to avoid unintended consequences—particularly for existing temporary residents, regulated occupations, skilled trades, multinational assignees, and employers navigating compliance obligations. Our feedback highlights opportunities to strengthen program integrity, enhance fairness, and ensure that modernization efforts support not only attraction but long‑term retention of high‑skilled talent.

CERC will continue to consult with about these proposed changes and how they may benefit our members. Your comments are welcome. Please email info@cerc.ca with "Express Entry Regulations" in the subject line.

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What is the Program?

The CERC Employee Relocation Management program is a three-level online certificate series designed for HR professionals and relocation practitioners at every stage of their career. Whether you're new to the industry or a seasoned mobility professional looking to formalize your expertise, the program offers a clear pathway to recognized credentials.

• Level I – Introduction to Relocation provides a broad overview of the relocation process and leads to the CERC Relocation Specialist™ designation.
• Level II – Essentials of Domestic Relocation deepens your knowledge of Canadian relocation practices and policy, leading to the CERP™ designation.
• Level III – Essentials of International Relocation covers the complexities of global assignments, compliance, and emerging mobility models, leading to the CGMP™ designation.

Courses are delivered fully online, with instructors available to support you throughout.

"This course provides the detail and substance that is needed for success in the industry! After the course I felt like I could run any relocation department!" — Sara Rocha, CRP, GMS-T, CERP™, Account Manager Lead, Runzheimer

Why Register?

Earning your CERC designation signals to employers and clients alike that you bring verified, industry-recognized expertise to the table. It's an investment in your professional credibility — and your career. Graduates consistently report that the program changes how they work.

"The program has allowed me to complete my role in a more efficient way. I am more equipped to deal with the movement of employees from one location to the other." — Dedra John-Henry, CGMP™, Assignment Manager, People Mobility, Accenture Inc.

And for those with an eye on the international side of mobility:

"After completing the CGMP™ program, you walk away not only more knowledgeable about mobility, but also general policy development and administration methodology." — Ann Stafford, CERP™, CGMP™, Regional Vice President, Client Services, Weichert Workforce Mobility Canada

Learn more: Professional Development Program - Canadian Employee Relocation Council (CERC)

Spots are limited and the May 26 registration deadline will be here before you know it. Visit Seneca College's website or contact them directly at online@senecacollege.ca or 416-491-5050 ext. 24140 to register.

The ongoing war in the Middle East has resulted in profound human suffering. Innocent civilians have lost loved ones, homes have been destroyed, and countless individuals and families have been displaced. The scale of this tragedy is deeply distressing, and our thoughts are with all those affected.

Please review the full statement here.

Letter to The Honourable Gregor Robertson
Minister of Housing and Infrastructure
and Minister responsible for Pacific Economic Development Canada

RE: Request for Regulatory Amendment – Prohibition on the Purchase of Residential Property by Non-Canadians Act

Please review the letter here.

Review details and recommendations here.

The Honourable David Piccini 
Minister of Labour, Immigration, Training, and Skills Development

Proposed Updates to the Ontario Immigrant Nominee Program (OINP) 

The proposed updates to the Ontario Immigrant Nominee Program (OINP) introduce welcome new permanent residency (PR) pathways for key skilled worker groups, including healthcare professionals and entrepreneurs. The creation of an exceptional talent stream is an encouraging step toward addressing gaps in the current system and expanding opportunities for individuals who may not qualify under existing federal programs. 

Review full letter here.

Canadian Business Leaders Urge Reinstatement of Express Entry Points for Arranged Employment

Toronto, ON — The Canadian Employee Relocation Council (CERC) is calling on the federal government to urgently reinstate Arranged Employment points within Canada’s Express Entry immigration system, citing growing concern over the loss of permanent residency pathways for senior international executives working legally in Canada.

In letters sent to the Honourable Lena Diab, Minister of Immigration, Refugees and Citizenship, CERC has outlined the unintended consequences of the policy change, which removed points for Arranged Employment in March 2025. To date, no response has been received.

Read the full media release and letter here.

Date: November 13, 2025

CERC Calls on Federal Government to Amend Housing Act to Support Talent Mobility

Toronto, ON — The Canadian Employee Relocation Council (CERC) is urging the Honourable Gregor Robertson, Minister of Housing and Infrastructure, to amend the Prohibition on the Purchase of Residential Property by Non-Canadians Act to better support workforce mobility and employer-sponsored relocations.

In a letter sent to Minister Robertson, CERC President and CEO Stephen Cryne outlined the unintended consequences of the Act, which restricts foreign-owned corporations and relocation service providers from purchasing residential properties as part of employee relocation programs.

Please review the full media release and letter here.

The Honorable Jamieson Greer 
U.S. Trade Representative
Office of the United States Trade Representative

Re: USTR-2025-0004, Request for Comments to the Operation of the Agreement Between the United States of America, Mexican States and Canada, sent VIA USTR portal: https://comments.ustr.gov/s/

Please review letter here.

Please review the letter here.

Please review CERC's recommendations for a targeted program to attract skilled talent impacted by U.S. H1B changes. 

Dear Minister Diab,

As you know the Canadian Employee Relocation Council (CERC) has worked constructively with your
department for over 15 years. Our organization, comprised of many of Canada’s leading employers, is
solidly aligned with Prime Minister Carneys vision for Canada’s immigration system to “Attract the best
talent in the world to build our economy.”

Continue reading the letter here.

July 2025

“Bridging the Gap” Report Unveils a Practical Path to Sustainability in Global Mobility

Groundbreaking report charts a clear, collaborative course for sustainability progress that creates business value across the global mobility industry

London, 15 July 2025 – A bold new vision for a more sustainable and connected global mobility industry has emerged from the latest report by The Coalition for Greener Mobility and sustainability consultancy JustOne. Released today, the Bridging the Gap report provides a practical blueprint to help global mobility companies embed sustainability into all aspects of business to future-proof the industry and ensure sustainability goals are met.

Please click here to view full press release.

Click here to continue reading.

Dear Minister Champagne,

On behalf of the members of the Canadian Employee Relocation Council (CERC), I extend our warm
congratulations on your recent appointment as Minister of Finance. We wish you great success in this
important and challenging portfolio.

Please continue reading the letter to the Minister here.

Continue reading the letter to the Minister here.

Continue reading here.