Clarification on ‘implied status’ for work permit extensions

Applicants applying to extend their work permit in Canada have been receiving letters from IRCC that state the following:

“Please attach this letter to your present work permit Number [application number] as proof that you are authorized to continue working with the same conditions (ie: employer and occupation) until [date] or until a decision is made on your application, whichever is first. This extended period of work is authorized as per subsection 186(u) of the Immigration and Refugee Protection Regulations. If you leave Canada before a decision is made on your application, you will no longer be authorized to continue working.”


We have received the following clarification directly from IRCC by email on the new wording and when ‘implied status’ ends:

“The status in not ‘implied’ but maintained if the application is submitted prior to the expiry of their existing status….the [Immigration and Refugees Protection] Regulations state that the period of authorized stay is extended until a decision is made and that a person who is applying to renew their work permit will have authority to work under R186(u) until a decision is made unless they leave Canada.

The letter is provided to applicants as proof that they have continued authority to work and the date is added to give employers and other stakeholders a more concrete period of time of authorized work. IRCC has found in the past that employers and stakeholders are reluctant to accept an unknown period such as ‘until a decision is made’.  Should the application not be processed within the date on the letter clients may contact IRCC using the IRCC Webform to request continued proof.  In addition, there is no requirement that the applicant must present this letter to anyone it is only provided as a service to the client.

For greater clarity: “the applicant may continue working until a decision is made if they meet all the requirements of R186(u) regardless of the date in the letter.  The letter is simply a document to provide surety to employers and other stakeholders that the applicant may continue working.”