Work Permit Expiry Follow-Up for Canadian Employers

A work authorization expiry follow-up in Canada means checking, before a foreign national's work permit or Social Insurance Number (SIN) expires, that the person can still lawfully work for you. An employer who keeps a worker on after the permit lapses, without evidence of maintained status or a new permit, risks penalties under the Immigration and Refugee Protection Act (IRPA), even if the permit was valid at hire.

This article covers the Canadian federal position as of October 2026. It describes what a follow-up check compares: permit conditions, dates and SIN records. It does not claim that a check proves a document is genuine. Provincial rules, including Quebec's, add requirements.

What do Canadian employers have to check, and when?

Employers must not employ a foreign national who is not authorized to work, and that duty applies for as long as the person works for you. Section 124 of the Immigration and Refugee Protection Act makes it an offence to employ a foreign national who is not authorized to work or to work outside the permit's conditions. The Immigration and Refugee Protection Regulations set the permit rules in detail.

A SIN beginning with 9 is issued to temporary residents and carries an expiry date tied to the permit; the employer must obtain the updated SIN when it expires (Service Canada, Social Insurance Number). Track the SIN date alongside the permit date, because they can differ.

What is maintained status and how does it affect follow-up?

Maintained status means a worker who applies to extend a work permit before it expires may continue working under the same conditions while the application is processed. It comes from section 183(5) of the Immigration and Refugee Protection Regulations and is explained by IRCC.

For an employer, the practical point is evidence. IRCC does not give employers a lookup tool, so you rely on the worker's proof of the in-time application, such as the submission confirmation. Keep a dated copy. If the application is refused, authorization ends and so must the work, unless the worker restores status or holds another permit.

How do you follow up step by step?

Run one follow-up routine for everyone with an end date, the same way each time.

1. Record the permit end date, SIN expiry date and permit conditions at hire.
2. Set reminders at 120, 90 and 30 days before the earlier of the two.
3. Ask the worker for the new permit or for proof of an in-time extension application.
4. Compare employer name, job title, location and end date on the new permit with the role.
5. Obtain the updated SIN if the SIN expiry was reached.
6. Save dated copies and note who ran the check.
7. Diary the next end date.

Do not wait for the worker to raise it. Many are unaware that the employer carries the exposure, and some hesitate to mention processing delays.

What are the penalties and record-keeping duties?

Section 124 of the IRPA carries fines and, for more serious cases, imprisonment, and the Canada Border Services Agency and IRCC can inspect employers. Employers hiring under the Temporary Foreign Worker Program must keep records for six years and may face administrative monetary penalties, ineligibility to hire foreign workers and public listing on the list of employers who have been non-compliant, according to the rules published by Employment and Social Development Canada.

Confirm current penalty amounts on those government pages, because they are adjusted. Treat the six-year record rule as the planning minimum for permit-based workers.

Employment standards and privacy

The check must be applied to all new foreign workers in the same way, and an employer cannot use it to treat workers differently on the basis of national origin, which would breach the Canadian Human Rights Act or provincial codes. Immigration records are personal information governed by PIPEDA for federally regulated and many private employers, and by provincial laws such as Quebec's Law 25 where they apply. Limit access, state the purpose and keep only what is necessary.

What do HR teams and staffing agencies ask?

"The permit expired last week but the worker says they applied to extend. Can they keep working?" Only with proof of an in-time application and the same conditions. A verbal assurance does not protect you.

"Do I need to recheck every worker each year?" No, but each worker with an end date must be tracked to it. Citizens and permanent residents need no follow-up.

"Who checks for agency placements?" The agency as employer. Our guide to work permit checks for temporary workers covers the first check, though it is written for the UK.

Keeping the file consistent

Most problems are mismatches, not forgeries: a name spelled differently on the permit and the bank form, a date of birth in the wrong order on the T4 set-up, a UCI copied with one digit wrong. Our platform compares the same field, such as full legal name and date of birth, against every document in the file at once, so a reviewer sees which field differs.

For expiry, the check flags documents whose end date falls inside a chosen window, so the follow-up list builds itself. Wider duties are covered in the employer right to work compliance guide, and the industry verification pillar guide places this check in context.

How early should the extension application start?

The extension application should be filed well before the permit ends, because processing times vary by program and can run for months. For the employer, that means the first reminder belongs 120 days before the end date, not 30. Ask the worker for the submission confirmation and record the day the application was filed. That date is the evidence that the application was in time, and it is the date an inspector or a later dispute will turn on.

In larger workforces, keep a short escalation list: workers within 60 days of expiry who have not yet shown proof of an extension application. A named person should contact each one and note the result, instead of relying on automated emails alone.

Follow-up checklist

• One end date per worker, taken from the permit
• SIN expiry tracked separately
• Reminders at 120, 90 and 30 days
• Proof of in-time application saved with date
• Conditions compared with the current role
• Records kept for at least six years for permit-based workers

Agencies and HR teams with many time-limited workers can use CheckFile's temporary staffing solution to validate completeness, expiry dates and cross-document consistency in one pass. Our security page explains data handling and pricing lists volume plans.

This article is general information, not legal advice. Rules change; confirm current requirements with IRCC or immigration counsel. Reviewed by the CheckFile editorial team, October 12, 2026.

Frequently Asked Questions

Can a worker keep working while a permit extension is pending?

Yes, if the application was submitted before expiry and the worker has maintained status, on the same conditions as before. Keep proof of the in-time application.

What happens if a SIN expires?

The employer should ask the worker for an updated SIN and a valid permit. A SIN starting with 9 reflects temporary status and an expiry date.

How long do I keep permit records?

Employers in the Temporary Foreign Worker Program keep records for six years. Use that as a planning minimum.

Does the follow-up differ in Quebec?

Quebec adds requirements such as the Quebec Acceptance Certificate for many workers and Law 25 privacy duties. Confirm with the provincial ministry.

What if the permit is refused?

Authorization ends, and the employer must stop the work unless the worker holds another valid permit.