GCMS Notes for Work Permit — LMIA & PGWP

The legal test for a work permit

Section 200 of the Immigration and Refugee Protection Regulations requires an officer to issue a work permit if the applicant applied properly, will leave Canada by the end of the authorized period, either falls into a permitted category or has a job offer the officer has determined to be genuine (with a labour market impact assessment or an exemption from one), and passes a medical examination where required.^[1] IRCC's applicant guidance adds that you must show enough money for yourself and your family and to return home, include all required documents, provide any further documents an officer asks for, and "show that you will leave Canada before your work permit expires".^[2]

Section 200(3) then lists situations in which a work permit "shall not" be issued. Two matter most in refused files: where "there are reasonable grounds to believe that the foreign national is unable to perform the work sought", and where the applicant worked or studied without authorization and six months have not passed since they stopped, unless an exception applies. The same subsection bars permits where the employer is ineligible or owes administrative penalties, and, for Quebec, where a required Certificat d'acceptation du Québec is missing.^[1] A refusal under 200(3) is mandatory, so the GCMS notes will show which paragraph the officer relied on.

The four genuineness factors on an employer-specific permit

For an employer-specific work permit, the officer assesses the job offer itself under subsection 200(5). IRCC's manual sets out the four factors: the offer must "be made by an employer who is 'actively engaged' in the business", "be consistent with the reasonable employment needs of the employer", "have terms the employer is reasonably able to fulfill", and come from an employer or recruiter "who has shown past compliance with federal and provincial or territorial laws that regulate employment or recruitment".^[3] The manual's own examples of offers that fail the test include a hair salon hiring a management consultant and a new home-based business that cannot show the funds to pay the stated wage.^[3]

Two practical consequences show up in GCMS notes. First, "if the offer of employment is incomplete or has 'See attached' in any field, the officer may not have sufficient information to assess the genuineness of the job offer".^[3] Second, "open work permits are not subject to the assessment of the genuineness factors in subsection R200(5), since there is no employer involved", so a refused spousal open work permit or PGWP was refused for a different reason, usually eligibility.^[3]

What the refusal letter says, and what the notes add

Post-graduation work permits in 2026

PGWP refusals are almost always eligibility refusals, and the criteria have changed several times. As of IRCC's current page, you must have completed a program "at least 8 months long (or 900 hours for Quebec programs)" at a PGWP-eligible designated learning institution, kept "full-time status as a student in Canada during each semester" (part-time is allowed only in the final semester), and applied "within 180 days of confirmation that you completed your program of study", with a study permit that "was valid at some point during the 180 days after you completed your program of study".^[4] Applicants who applied on or after November 1, 2024 must also meet a language requirement: CLB or NCLC 7 in all four abilities for university degree programs, and CLB or NCLC 5 for college and polytechnic programs; non-degree college and university graduates whose study permit applications were submitted on or after November 1, 2024 must also have studied in an eligible field.^[4] You are ineligible if you "already received a PGWP".^[4]

The GCMS notes on a PGWP refusal identify which of these the officer found unmet, and that decides whether the refusal can be fixed. A missed 180-day window cannot be repaired; a misread transcript or a language test that was not linked to the application can.

What a work permit file looks like inside GCMS

• Application summary: UCI, application number, the permit type (employer-specific, open, PGWP, extension), the LMIA number or exemption code recorded, the employer and occupation code on file, and the dates of receipt and decision.
• Assessment results: eligibility, security, information-sharing and medical results with dates.
• The officer's notes: a dated assessment covering your qualifications, the genuineness factors or the PGWP criteria, and the refusal ground. Parts may be redacted where the law protects other people or security methods.^[5]
• Employer information: what the employer submitted through the Employer Portal or with the LMIA, as it appeared to the officer.
• Earlier applications: previous permits, extensions, study permits and visitor applications under the same UCI, with their notes.
• Correspondence log: procedural fairness letters, document requests and the refusal letter, with dates.

See how to read GCMS notes and status codes for the abbreviations. If you entered Canada to work and were examined at the border, those records are held by CBSA; see IRCC vs CBSA notes.

Refused inside Canada: maintained status and restoration

If you applied to extend or change your work permit before it expired and stayed in Canada, you were on maintained status while IRCC processed the application and could keep working under your existing conditions.^[6] A refusal ends that status. From that point you generally must stop working, and you have 90 days from the date you lost status to apply to restore it and, at the same time, apply for a new permit; you cannot work while a restoration application is pending.^[7]

Because the 90-day clock runs from the refusal, order the GCMS notes immediately. IRCC has 30 days to respond and may extend that period,^[8] so the notes can still arrive in time to shape the restoration application, and they show whether the problem was a document, the employer, or an eligibility finding that a new application cannot cure.

After a refusal: re-apply or judicial review

There is no appeal for a refused work permit; the options are a new application or an application for leave and judicial review at the Federal Court.^[9] IRCC advises re-applying only with information you did not include before.^[10] For a work permit that usually means one of these, and the notes tell you which:

1. A corrected or new LMIA or offer of employment when the notes show a mismatch in wage, occupation, location or employer name.
2. Evidence you can do the job: verifiable reference letters with duties and dates, credentials, or a language result at the level the offer requires.
3. Employer evidence addressing the genuineness factor that failed, for example financial statements or proof of active operations.
4. A different permit type if the notes show the eligibility finding cannot change, for example a PGWP refused for timing.

Where the notes reveal that a concern was never put to you, or that the officer misread a document, judicial review may be the better route; IRCC notes that you should state you have not received the reasons when applying, so the Court can request the complete reasons.^[5] See GCMS notes after a refusal.

Ordering GCMS notes for a work permit

• What we need: your name and date of birth as on the application, your UCI or work permit application number, and the signed consent form we provide.^[11]
• Spouse on an open work permit: their permit is a separate application with its own file; add them to the same order.
• From outside Canada: no Canadian status is needed; we file from Canada as your representative.^[11] See requesting from outside Canada.
• Timeline: IRCC has 30 days and may extend; 4 to 6 weeks is typical.^[8]

Frequently asked questions

Do the notes show what my employer submitted?
Yes. The file records the offer of employment or LMIA details as they appeared to the officer, which is how mismatches between your application and the employer's submission are found.

My open work permit was refused. Was it the employer?
No. Open permits are not assessed on the genuineness factors, because there is no employer; the notes will show an eligibility or admissibility reason instead.^[3]

Can I order the notes while a restoration application is pending?
Yes, and you should. An access request does not affect the restoration or any other application.

Does a work permit refusal affect a later PR application?
The refusal and its notes stay on your UCI. A finding of misrepresentation or unauthorized work matters for PR; an ordinary refusal does not, provided the next application addresses the recorded concern.

Official sources

All information on this page is based on official Government of Canada publications:

1. Immigration and Refugee Protection Regulations, section 200 — Justice Laws Website
2. Work permit from outside Canada: Who can apply — Canada.ca
3. Assessing the genuineness of the offer of employment on a work permit application — IRCC operational manual
4. Post-graduation work permit: Who can apply — Canada.ca
5. Explaining application refusals: Officer decision notes — Canada.ca
6. Temporary residents: Maintained status during processing — IRCC operational manual
7. What to do if your work permit expires or is expiring — Canada.ca
8. How long does the Department have to respond? — IRCC
9. How do I get help if my temporary residence application is refused? — IRCC
10. If my immigration application is refused, do I have to wait before I apply again? — IRCC
11. Who can make a request under the Access to Information Act? — IRCC