OINP suspensions
On Nov. 14, the Ontario government temporarily suspended the intake of applications to the Express Entry: Skilled Trades Stream under the Ontario Immigrant Nomination Program (OINP). At the same time, it was announced that all pending applications under that stream would be returned despite reports that some applications were being processed for more than a year.
These changes come on the heels of the provincial government making amendments to Regulation 421/17, which allows the OINP director to cancel application intakes and processing for a variety of reasons. One such reason is if the director detects “any systemic compliance or enforcement concerns” relating to the eligibility criteria for the stream. This was the reason cited in November when the province announced that it “identified systemic misrepresentation and/or fraud relating to Skilled Trades Stream eligibility criteria.” No further details have been provided yet with respect to what kind of systemic issues were identified.
For applicants and their families, this is clearly a challenging update: It interrupts a pathway they may have dutifully taken steps to be eligible for, creates uncertainty around the coordination of OINP applications and federal permanent residence applications, and raises questions about OINP stream reliability.
Bill C-12
The Ontario government is not alone in wanting to wield the power to manage application intake and processing integrity. At the federal level, Bill C-12—officially the Strengthening Canada’s Immigration System and Borders Act—is generating significant discussion. The bill is proposed to grant expanded powers to Immigration, Refugees and Citizenship Canada (IRCC) and related federal agencies. This includes the ability to pause, cancel, or restructure large classes of immigration applications—including those already in process.
Critically, the legislation introduces a public interest trigger—whereby the minister or governor in council might suspend or terminate applications if deemed necessary for operational reasons, backlog management or other broadly defined public-interest concerns. The ambiguity around public interest has raised alarm. Legal experts point to historical precedents where large application backlogs were cancelled en masse (e.g., 2012, 2014) and warn that Bill C-12 could facilitate a repeat. Previous mass application cancellations are being challenged in court and pending resolution.
For prospective Canadian immigrants, international graduates, workers, and families, this moment is one of uncertainty. The Ontario announcement and Bill C-12 are two sides of the same coin: One at the provincial level tightening eligibility and focusing on integrity (OINP); the other at the federal level revisiting the foundations of immigration-processing power (Bill C-12). Together, they underscore that the immigration environment in Canada is in transition, and that applicants may need to be more proactive, flexible, and vigilant in navigating their pathways.
Next steps
At this moment, it is critical that individuals who are about to submit provincial or federal immigration applications ensure that these applications are internally consistent, avoid all intentional and unintentional misrepresentation, and don’t include expired supporting documents. Guidance is also recommended for staying in status if applicants are already in Canada, given the potential unreliability of application processing. Plans for renewing one’s study or work permit status in Canada should be made early, especially in light of increasingly lengthening processing times and the limitations of being on maintained status.
At this critical time, should you have any questions about how the above initiatives can help you or your company, please contact BDO Law LLP’s Immigration Services team at [email protected].
The information in this publication is current as of November 21, 2025.
This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Canada LLP to discuss these matters in the context of your particular circumstances. BDO Canada LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.