LATEST UPDATE FROM IRCC: INTERNATIONAL MOBILITY PROGRAM – INTRA-COMPANY TRANSFEREES

On October 3, 2025, Immigration, Refugees and Citizenship Canada (IRCC) announced an expansion and consolidation of policies related to Intra-Company Transferees (ICT) under section 205(a) of the Immigration and Refugee Protection Regulations (IRPR).

🔍 Key Highlights of the Update

IRCC has revoked the previous guidance under the Temporary Foreign Worker Program (TFWP) titled Canadian interests – Significant benefit – Intra-company transferees – International agreements [R205(a)], which used the exemption code C12.

In its place, all current ICT-related instructions have been integrated into the International Mobility Program (IMP) under new exemption codes: C61, C62, and C63.

These changes follow the major regulatory overhaul on October 1, 2024, which sought to clarify the criteria of “Significant Benefit”—that is, the degree to which a transferred employee contributes to Canada’s economic and strategic interests.

⚙️ Practical Implications for Businesses and Applicants

• Multinational enterprises transferring staff to Canadian branches or subsidiaries must now update the applicable Labour Market Exemption Code when submitting IMP applications.

• Applications using the old C12 code are no longer accepted and must instead comply with the new C61–C63 framework.

• The “Significant Benefit” test has been tightened, with IRCC now requiring clearer evidence of:
  • The unique technical or professional expertise of the transferee.

  • The positive impact on investment, innovation, or technology transfer in Canada.

Companies leveraging ICTs to support their expansion into the Canadian market should review any pending or draft applications to ensure alignment with the updated criteria and avoid refusals due to outdated references.

🧭 SICON’s Recommendation

As these updates directly affect corporations with operations in Canada, businesses should reassess their legal structure, employment contracts, and job descriptions of ICT employees before filing new applications.

SICON can assist companies in developing compliant and strategic intra-company transfer plans, particularly in demonstrating Significant Benefit and the unique qualifications of transferred personnel under the revised IMP framework.