Staffing Agency Compliance Requirements: Worker Documents

This article is provided for information only and is not legal advice. Regulatory references are accurate as of its publication date (October 2026) and cover federal rules plus Ontario and Quebec examples. Consult employment and immigration counsel for any decision about an individual worker file.

A Canadian staffing agency must confirm that each worker is legally entitled to work, collect the tax and payroll records the Canada Revenue Agency expects, and, in some provinces, hold a licence to operate at all. Immigration is federal. Employment standards are provincial. That split is why a national agency cannot run a single checklist. This article sets out the federal baseline, shows how Ontario and Quebec layer on top, and explains what each check compares so your team can validate files faster.

What documents must a Canadian staffing agency collect?

An agency must verify that the worker is a citizen, permanent resident or foreign national with a valid work permit, and must collect a Social Insurance Number (SIN) within three days of the start of employment. The Service Canada SIN guidance explains that SINs beginning with 9 belong to temporary residents and expire with their permit, so the agency has to record the expiry date and stop the worker from continuing after it.

Under the Immigration and Refugee Protection Act and its Regulations, an employer must not employ a foreign national who is not authorized to work or whose permit conditions bar that employment. Permit conditions matter: an employer-specific permit does not allow work for a different employer, and an open permit may restrict occupation or location. Immigration, Refugees and Citizenship Canada publishes the conditions that apply to each permit type.

How does provincial law change the rules for agencies?

In Ontario, temporary help agencies and recruiters have needed a licence since July 1, 2024, and the Employment Standards Act, 2000 gives assignment employees specific rights, including written information on the assignment and protection against some client-imposed fees. The text is on the Ontario e-Laws site. Operating without a licence exposes the agency to enforcement, and clients have been told to confirm the licence status of the agencies they use.

Ontario also forbids employers from holding a worker's passport or work permit, which affects how scans are collected and returned. An agency should ask for a copy, never retain originals.

Quebec runs a separate regime. The Act respecting employment agencies and agencies for recruiting foreign temporary workers requires a permit from the CNESST, and the Act respecting labour standards sets equal-pay rules for agency employees. Foreign workers in Quebec generally need a Quebec acceptance certificate (CAQ) in addition to the federal permit. Alberta and British Columbia have their own employment-standards rules, but neither licenses temporary help agencies in the Ontario way. Check each province where you place workers.

What are the consequences of employing an unauthorized worker?

The Immigration and Refugee Protection Act makes it an offence to knowingly employ a foreign national without authorization, with penalties that include fines and imprisonment, and the federal government can also impose administrative monetary penalties and bar an employer from the Temporary Foreign Worker Program. Inspections under the program can review pay, working conditions and whether the employer kept records. For agencies that supply workers under a Labour Market Impact Assessment, that review reaches agency files directly.

Records matter on both sides: payroll records, Records of Employment (ROE) and tax filings are held under CRA rules, described on the CRA website. Keep identity and permit copies for the period your provincial standards and CRA rules require.

Which cross-document checks can an agency automate?

A cross-document check compares the same fields across several documents in one file and flags mismatches before the worker is dispatched. Our platform supports more than 3,200 document types and OCR extraction in 24 languages across 32 jurisdictions, so passports, PR Cards, work permits and provincial licences go through one flow.

The check compares fields and dates. It does not prove that a document is authentic, and it supports, not replaces, a human decision to accept the file.

What do agency coordinators ask most often?

Three questions recur on HR and staffing forums. First: can I accept a digital copy of a work permit? Employers commonly keep copies, but they should confirm status on the permit's face and its conditions, and should never hold the original. Second: what do I do when a worker's SIN starts with 9? Record the permit expiry date, calendar a follow-up, and confirm a valid extension or new permit before the date passes. Third: do I need a licence? In Ontario, yes for temporary help agencies and recruiters; in Quebec, a CNESST permit; elsewhere, check the provincial rules.

How should worker data be protected?

Federal PIPEDA governs private-sector handling of personal information in most provinces, Quebec's Law 25 applies in Quebec, and Alberta and British Columbia have their own private-sector acts. The Office of the Privacy Commissioner of Canada publishes guidance on collecting identity documents. The general rule is to collect only what you need and to limit SIN use to payroll and tax reporting. Our security page explains how CheckFile handles uploaded documents.

From a pile of scans to a validated worker file

Validate in three passes: completeness, validity, consistency. Confirm every required document is present, that dates cover the assignment and that shared fields agree. Our industry verification guide applies this method to high-turnover sectors, and the article on temp worker document verification before a first assignment covers the first-assignment case.

When file volume outgrows manual review, the staffing solution compares these fields and dates automatically and queues mismatches for a person to resolve. See pricing to size your usage.

Frequently Asked Questions

Who checks work eligibility, the agency or the client?

The agency, as employer, verifies that the worker is authorized to work and that the permit conditions allow the assignment. A client that knowingly uses unauthorized labour can face its own consequences.

When must an agency collect the SIN?

Within three days of the start of employment. If the SIN starts with 9, record the permit expiry date and make sure the worker does not continue past it without a valid extension.

Do staffing agencies need a licence in Canada?

It depends on the province. Ontario licenses temporary help agencies and recruiters, and Quebec requires a CNESST permit. Check the rules in each province where you place workers.

Does an automated check prove a work permit is genuine?

No. It compares fields and dates and flags mismatches. Confirming status and accepting the file remain human decisions.