IMP Job Offer: Can a Missing A-Number Be Added Later?

An IMP job offer must usually be in place before a foreign national submits an LMIA-exempt employer-specific work permit application. The employer normally submits the offer through IRCC’s Employer Portal. The employer also pays the compliance fee when required. IRCC then issues an offer of employment number, commonly called the A-number. But what happens when the foreign national submits the work permit application first?

Can the employer create an offer later, pay the compliance fee, obtain an A-number, and send it to IRCC via web form?

For practitioners, this question requires more than an examination of IRCC’s computer system. The Immigration and Refugee Protection Regulations impose specific timing requirements. Those requirements create a serious obstacle to retroactive correction. The answer also depends on what actually happened before filing. A forgotten A-number presents a different problem from an offer that never existed.

This article reflects the law and published IRCC guidance available on August 31, 2026.

What Is an IMP Job Offer?

An IMP job offer is not simply an employment letter. For many employer-specific work permits under the International Mobility Program, the Canadian employer must use the Employer Portal. The employer enters the prescribed information about the business, the foreign national, the position, the wages, the benefits, and the LMIA exemption.

The employer then submits the offer and pays the $230 employer compliance fee, unless an exemption applies. After successful submission, IRCC generates an offer of employment number. That number begins with the letter A followed by seven digits.

The employer gives the A-number to the foreign worker. The worker then enters it in the work permit application.

IRCC’s Employer Portal guide confirms this sequence. It also states that the worker needs the A-number to submit the work permit application. This process matters because the Employer Portal forms part of the IMP compliance regime. The offer does more than support eligibility. It records the employer’s commitments for possible future inspection.

The IMP Job Offer and IRPR 200

The legal analysis starts with IRPR 200.

Subparagraph R200(1)(c)(ii.1) applies where a foreign national intends to perform work described in sections 204 or 205 and has an offer of employment.

The officer must also assess whether the offer is genuine.

R200(5) sets out four factors for that genuineness assessment. The officer considers:

1. whether the employer actively engages in the relevant business;
2. whether the offer reflects reasonable employment needs;
3. whether the employer can reasonably fulfil the terms; and
4. the employer’s past compliance with applicable employment and recruitment laws.

These requirements matter once the employer has properly created the offer. However, another provision addresses what must happen before the worker applies.

That provision is R200(3)(f.1).

R209.11 Requires the Employer to Act First

Subsection 209.11(1) creates a clear timing requirement.

An employer who makes an offer to a foreign national under R200(1)(c)(ii.1) must provide prescribed information to the Minister electronically.

Most importantly, the employer must do this before the foreign national applies for a work permit.

The wording matters.

209.11 (1) An employer who has made an offer of employment to a foreign national referred to in subparagraph 200(1)(c)(ii.1) must, before the foreign national makes an application for a work permit in respect of that employment, provide the following information to the Minister using the electronic means that is made available or specified by the Minister for that purpose…

R209.11 does not say that the employer may provide the information before the officer decides the application. It does not say that IRCC may request the information later. Instead, the regulation identifies a specific deadline. The employer must provide the information before the worker applies. For most affected employers, the Employer Portal provides the designated electronic system.

The Compliance Fee Has the Same Timing Requirement

Section 303.1 of the IRPR deals with the employer compliance fee.

The current fee is $230.

Under R303.1(2), the employer must pay that fee before the foreign national applies for the work permit. The same rule applies to a work permit renewal. Several exemptions exist. Practitioners must therefore determine whether the employer or foreign national qualifies for one. However, where the fee applies, the chronology matters. The employer cannot simply treat the fee as another processing charge that can be applied to the application. The Regulations expressly require prior payment.

Payment of fees

303.1(2) The fee referred to in subsection (1) is payable before the foreign national to whom the offer of employment is made makes an application for a work permit or an application for renewal of the work permit.

Why R200(3)(f.1) Creates the Main Problem

R200(3)(f.1) connects these requirements directly to work permit issuance. R200(3) states that an officer shall not issue a work permit in the circumstances listed in that subsection. Paragraph (f.1) captures foreign nationals under R200(1)(c)(ii.1). It applies where the employer has not paid the R303.1 fee or provided the R209.11 information before the foreign national applies. This provision creates the central difficulty with a late A-number.

Suppose a worker applies on June 1. At that time, the employer has not submitted anything through the Employer Portal. The employer has not paid the compliance fee either. On August 1, the employer realizes the mistake. It submits an offer, pays $230, and receives an A-number. The employer has now complied with the portal process. However, it did not comply before June 1. The August submission cannot change the chronology.

IRCC Gives the Same Warning

IRCC’s Employer Portal guide takes an equally clear position. The guide tells employers to submit the offer and pay the required compliance fee before the foreign national submits the work permit application. IRCC then gives a direct warning. If the employer fails to do those things before the worker applies, IRCC says it will refuse the work permit.

IRCC’s work permit instructions provide the same sequence. For an LMIA-exempt employer-specific application, the employer submits the offer first. The portal generates the A-number. The worker then uses that number when applying. The outside-Canada application guide goes even further. It tells employers to provide the A-number and pay the compliance fee before the worker starts the work permit application. The legislation and IRCC’s published instructions therefore point in the same direction.

Can You Send a New A-Number by Webform?

Technically, an applicant can send information to IRCC while an application remains pending.

A practitioner could therefore take the following steps:

1. create a new Employer Portal offer;
2. pay the compliance fee;
3. obtain an A-number;
4. submit that number through the IRCC webform; and
5. ask the processing office to associate it with the pending application.

The real question is whether this cures the legal defect. I have not located public IRCC documentation that explains every technical function available to officers in GCMS or related systems. An officer may have the technical ability to view or associate information received after filing. However, technical capability does not resolve the regulatory problem. The portal records the offer submission date. IRCC also knows the work permit application date.

A later system association cannot make the employer’s earlier non-compliance disappear.

A Missing A-Number Is Not Always the Same Problem

Practitioners should identify exactly what went wrong. Consider two very different situations.

Scenario 1: The offer already existed

• The employer submitted a valid IMP job offer on May 20.
• The employer also paid the compliance fee on May 20.
• IRCC issued A1234567.
• The foreign national filed the work permit application on May 25. However, the applicant accidentally omitted the A-number or entered it incorrectly.
• This case involves a possible identification or matching problem.
• The employer may already have complied with R209.11 and R303.1 before filing.

A practitioner could therefore have a reasonable basis for sending the existing A-number to IRCC and explaining the error. The practitioner should provide proof of the original submission date and payment.

Scenario 2: No offer existed

• Now change the facts.
• The worker filed on May 25. The employer had never submitted an Employer Portal offer.
• The employer first created the offer on June 15.

That situation presents a much more serious problem. The employer did not satisfy the pre-filing requirement. A webform cannot change that fact.

How to Investigate a Missing IMP Job Offer

Before advising the client, obtain evidence.

• Do not rely solely on the client’s statement that they “forgot the job offer.”
• Ask the employer to log in to the Employer Portal.
• Then determine whether an offer existed on the filing date.

Review:

• the offer of employment number;
• the Employer Portal submission date;
• the compliance fee receipt;
• the offer status;
• the work permit submission date;
• any employment agreement;
• any portal screenshots or confirmation records; and
• the application forms actually filed with IRCC.

This review often determines the entire strategy. An existing A-number with an earlier submission date may support a request for correction. A newly created A-number does not establish earlier compliance.

IRCC Uses a Matching System

• The Employer Portal uses the concept of matching.
• After the employer submits an offer, the portal initially displays it as submitted.
• Once IRCC matches the offer to a work permit application, the queue changes its status to matched.
• This helps explain the role of the A-number.
• The number allows IRCC to connect the employer’s portal information with the foreign national’s work permit application.

However, matching does not replace the timing rules. R209.11 still requires the employer to submit the information before the worker applies. Therefore, practitioners should not confuse a potential matching solution with substantive compliance.

What Happens When an Employer Needs a New Offer?

IRCC’s instructions on changing submitted offers provide useful guidance. Before matching, an employer may have options to withdraw, update, or replace an offer.

The situation changes after the worker files the work permit application. If the employer needs to submit a new offer after the worker has already applied, IRCC instructs the worker to withdraw the work permit application. The worker then applies again using the new offer number. That instruction is significant. IRCC does not tell the employer to create a replacement A-number and send it by webform.

Instead, IRCC preserves the proper sequence:

Employer Portal offer first. Work permit application second.

That sequence mirrors R209.11 and R303.1.

One A-Number Cannot Support Multiple Applications.

IRCC also limits each A-number to one work permit application. The current inside-Canada and outside-Canada instructions both state that applicants can use an offer of employment number only once.

For a future application, the employer needs a new number. This rule applies when a previous application was refused. An employer cannot simply recycle the old A-number for the next application. The Federal Court addressed that issue directly in Famugbode v. Canada (Citizenship and Immigration), 2026 FC 348.

Famugbode v. Canada, 2026 FC 348

In Famugbode, the applicant submitted another work permit application after an earlier refusal. The applicant relied on an LMIA-exempt offer number from a previous application. The applicant also failed to provide a new employer compliance fee for the later application. The officer refused.

The Federal Court dismissed the judicial review application. The Court accepted that IRCC matches an offer number to a specific work permit application. Once IRCC decides that application, the applicant cannot reuse the same number for another application.

A new work permit application requires a new offer and the appropriate compliance fee. Famugbode therefore confirms the importance of the connection between the Employer Portal offer and the specific work permit application.

Federal Court judgment in Famugbode, 2026 FC 348

What Famugbode Does Not Decide

Practitioners should not overstate Famugbode. The case did not involve an employer creating a completely new A-number after filing and asking IRCC to add it to the same pending application.

Instead, the applicant reused a number from an earlier application. Therefore, Famugbode does not directly answer the late-offer question. Its reasoning still matters. The decision confirms that the A-number does not function as a free-standing document. IRCC connects the number with a specific work permit application. The decision also reinforces the applicant’s responsibility to satisfy the applicable regulatory requirements. Most importantly, R200(3)(f.1) already addresses the timing issue directly. Practitioners do not need to stretch Famugbode beyond its facts.

Does Procedural Fairness Require IRCC to Ask for the A-Number?

Usually, an applicant must establish eligibility through the application record. An officer does not normally need to alert an applicant to every deficiency that arises directly from the statutory or regulatory criteria. Famugbode supports that principle in the Employer Portal context. The Court rejected the applicant’s procedural fairness argument concerning the deficient offer number and fee.

This point becomes even stronger when no offer existed at the time of filing. An officer could ask for evidence that an employer submitted an offer before the application date. That evidence might resolve a matching problem. However, an officer’s request cannot change history. If the employer first submits the offer after filing, the applicant still faces R200(3)(f.1).

Could Officer Discretion Save the Application?

Practitioners should approach this argument cautiously. R200(3) uses mandatory language. It says that an officer shall not issue a work permit where the listed circumstances apply. R200(3)(f.1) then expressly refers to the timing of the fee and employer information.

I have not identified a general provision that authorizes an officer to deem a late Employer Portal submission timely. Nor does published IRCC guidance suggest such discretion. Different considerations may arise where the employer actually complied before filing, but a technical problem prevented proper matching. Government error could also create a different record. Those situations require their own analysis. They should not be confused with an employer who never submitted the offer before the worker applied.

Work Permit Extensions Follow the Same Principle

The issue also arises in extension applications. Some practitioners may assume that an existing employer-specific permit removes the need for a new Employer Portal submission. That assumption can cause serious problems. R303.1 specifically refers to applications for renewal. When the employer compliance fee applies, the employer must pay it before the foreign national submits the renewal application. IRCC also tells applicants that a future work permit application requires a new offer number. Therefore, a practitioner preparing an LMIA-exempt employer-specific extension should complete the employer-side process first. Do not wait until after filing to create the new offer.

Be Careful Before Withdrawing a Pending Application

A defective application does not automatically mean that immediate withdrawal serves the client’s interests. The practitioner must first review the client’s immigration status. This issue becomes particularly important for an applicant inside Canada.

For example, consider whether:

• the current work permit remains valid;
• the applicant filed before its expiry;
• the applicant currently benefits from maintained status;
• the applicant remains in Canada;
• another application can be filed immediately;
• the applicant can continue working;
• restoration may become necessary; and
• withdrawal could affect the applicant’s current authorization.

The best immigration strategy may therefore differ from the cleanest Employer Portal strategy. A practitioner should complete the status analysis before recommending withdrawal.

Open Work Permits Are Different

This analysis does not apply to every LMIA-exempt work permit. Open work permits generally do not require an Employer Portal offer. IRCC expressly confirms that an employer does not submit an offer of employment for an open work permit applicant.

Other exemptions also exist. For example, certain employers fall outside the ordinary Employer Portal requirements. Therefore, practitioners should first identify the exact work permit category. Do not assume that every LMIA exemption requires an A-number. At the same time, do not assume that LMIA exemption means exemption from the Employer Portal. Many employer-specific IMP applications require both the portal offer and the compliance fee.

The IMP Job Offer Also Creates Compliance Obligations

Practitioners should remember why the Employer Portal exists. The portal does not merely help IRCC process the work permit. The employer provides information about the occupation, wages, working conditions, and other employment terms.

IRCC may later inspect the employer. During an inspection, IRCC can compare the employer’s actual conduct with the commitments recorded in the portal. The Employer Portal guide tells employers to provide accurate and verifiable information. It also warns employers to retain supporting documents. That compliance function explains why practitioners should resist casual attempts to create retroactive records. The information should describe a genuine prospective employment arrangement. The expected employment start date cannot simply rewrite past events.

Practical Decision Tree for Practitioners

When a client presents a pending application with an A-number problem, use a simple sequence.

Step 1: Identify the work permit category

• Confirm that the application requires an employer-specific LMIA-exempt offer.
• Check the relevant section of the IRPR and IRCC’s program delivery instructions.

Step 2: Establish the filing date

• Obtain the IRCC submission confirmation.
• Do not rely on memory.

Step 3: Check the Employer Portal

• Determine whether the employer submitted an offer before the work permit application.
• Record the exact submission date.

Step 4: Verify the fee

• Confirm whether the employer paid the compliance fee before filing.
• If an exemption applied, obtain proof.

Step 5: Determine the nature of the error

• If the offer already existed, consider supplementation.
• If no offer existed, recognize the R200(3)(f.1) problem.

Step 6: Review status before withdrawal

• Assess maintained status, restoration, work authorization, and current location.

Step 7: Decide whether to reapply

• Where appropriate, create a compliant offer first and file a properly constituted new application.

Can a Missing IMP Job Offer Be Fixed?

The answer depends on what “missing” means. If the employer properly submitted the offer before filing, the applicant may have a correctable identification problem. A practitioner could send the existing A-number and proof of pre-filing compliance to IRCC.

The practitioner should explain the chronology clearly. However, if no Employer Portal offer existed when the worker applied, the problem becomes substantive.

• R209.11 requires prior submission.
• R303.1 generally requires prior payment.
• R200(3)(f.1) prohibits issuance where the employer failed to complete those steps before the application.

A newly created A-number cannot change the original filing date.

Conclusion

An IMP job offer should never become an afterthought in an employer-specific LMIA-exempt work permit application. The employer should complete the Employer Portal process first. Where required, the employer should also pay the $230 compliance fee. Only then should the foreign national submit the work permit application. When a practitioner discovers an A-number problem after filing, the chronology becomes critical.

If the employer submitted the offer before the application, supplementation may provide a reasonable solution. If the employer created no offer until after filing, the case presents a much more serious problem under R200(3)(f.1).

A practitioner can certainly send a new A-number to IRCC and ask the officer to consider it. However, no published authority establishes that this step retroactively cures the regulatory defect. In many cases, a properly prepared new application will create a cleaner legal record.

Before taking that step, practitioners must also examine status, work authorization, maintained status, and the consequences of withdrawing the pending application. The difference between a missing number and a missing pre-filing offer may determine the entire case.

Authorities and Resources

Immigration and Refugee Protection Regulations, s. 200, including R200(1)(c)(ii.1), R200(3)(f.1), and R200(5):
Justice Laws, IRPR section 200

Immigration and Refugee Protection Regulations, s. 209.11, Employer Portal information before filing:
Justice Laws, IRPR section 209.11

Immigration and Refugee Protection Regulations, s. 303.1, employer compliance fee and timing:
Justice Laws, IRPR section 303.1

IRCC Employer Portal User Guide, including offer submission, matching, changes, and compliance requirements:
IRCC Employer Portal User Guide

IRCC Work Permit Requirements for Applications Inside Canada, including A-number requirements:
IRCC work permit forms and document requirements

IRCC Work Permit Requirements for Applications Outside Canada, including the one-use rule for A-numbers:
IRCC work permit forms and document requirements outside Canada

Guide 5487, including the requirement to obtain the offer number and address the compliance fee before applying:
IRCC Guide 5487

Famugbode v. Canada (Citizenship and Immigration), 2026 FC 348, concerning reuse of an Employer Portal offer number and the employer compliance fee:
Federal Court judgment

Disclaimer

This article provides general information for Canadian immigration practitioners. It does not constitute legal advice. Practitioners should review the current IRPA, IRPR, IRCC program delivery instructions, Employer Portal records, and the client’s complete immigration history before advising on a specific application.