Participation encouraged in public consultations on Manitoba’s Worker Recruitment and Protection Act (WRAPA)

The Government of Manitoba is currently conducting a public consultation on modernizing the Worker Recruitment and Protection Act (WRAPA).

WRAPA is Manitoba’s principal legislation governing the regulation of foreign worker recruiters, employer compliance obligations in the recruitment and employment of foreign workers and protections for foreign workers in the province. Employers who access international talent, recruiters and foreign workers themselves are directly affected by its requirements. Changes to the legislation may therefore have significant implications for labour mobility, workforce planning, compliance obligations and the protection of vulnerable workers.

The consultation represents an important opportunity for employers, human resources professionals and other stakeholders to provide input on how WRAPA can be updated to better serve Manitoba’s evolving labour market while protecting foreign workers.

The deadline for submissions is September 6, 2026. We encourage all stakeholders to participate before this date. Those interested can review the consultation materials here and submit their feedback through the Engage MB platform here.

Key issues that stakeholders may wish to consider addressing in their submissions include:

Topics raised on the Engage MB website

The government has indicated that its review will focus on questions relating to foreign worker protections and enforcement. In particular, the government is asking stakeholders to look at questions regarding:

• Understanding issues facing foreign workers and supporting agencies in Manitoba
• Improving protections for foreign workers by addressing gaps in the legislation, aligning with best practices and current policy direction
• Increasing innovation and partnerships for more effective implementation and compliance
• Improving clarity and accessibility of the legislation

Stakeholders should review the specific questions posed on the Engage MB platform and consider how the current legislative framework has impacted their operations, workforce planning or experience as a foreign worker in the province. While the consultation focuses on specific questions, the legislative review process does allow stakeholders to provide their thoughts on issues not specifically asked in the survey. To the extent that stakeholders find the survey too restrictive, stakeholders can reach out directly to Manitoba’s Department of Labour and Immigration.

Eligibility to act as a foreign worker recruiter

Under the current framework, only lawyers and licensed immigration consultants are permitted to act as foreign worker recruiters in Manitoba. Stakeholders may wish to consider whether this restriction should be expanded to include other regulated professionals. For example, members of CPHR Manitoba, who are governed by the Chartered Professionals in Human Resources Act, possess relevant expertise in recruitment and workforce planning. The consultation provides an opportunity to consider whether such professionals should have a pathway to become licensed foreign worker recruiters and what safeguards would need to accompany any expansion of eligibility.

Robustness of licensing requirements for foreign worker recruiters

A fundamental purpose of WRAPA is to protect foreign workers from exploitation by unscrupulous recruiters. Stakeholders should consider whether the current licensing requirements for foreign worker recruiters are sufficiently rigorous to deter illegal and unethical actors from operating in Manitoba’s recruitment market. This may include consideration of enhanced background checks, financial security requirements, continuing education obligations or other measures that would strengthen the integrity of the licensing regime while remaining proportionate and accessible to legitimate recruiters.

Modernization of the employer compliance regime

WRAPA imposes compliance obligations on employers who recruit and employ foreign workers in Manitoba. These obligations exist alongside – and sometimes overlap or contradict  – the Federal employer compliance regime under the Immigration and Refugee Protection Act (IRPA) and its regulations. Stakeholders may wish to consider whether WRAPA’s compliance framework should be updated to harmonize with the federal regime, reducing duplication and the potential for contradictory outcomes.

For example, under IRPA’s employer compliance framework, an employer facing a non-compliance finding may advance a defence based on “reasonable justification” or demonstrate that it exercised due diligence. However, there may not be equivalent defences under WRAPA. This could produce a situation where an employer is found compliant under one regime but non-compliant under the other for substantially similar conduct. Aligning the standards and defences across both regimes would promote fairness, predictability and administrative efficiency for Manitoba employers and put Manitoba employers on a level playing field with employers elsewhere in Canada.

At the same time, stakeholders may wish to consider whether Manitoba-specific requirements remain necessary to address local labour market concerns and worker protection objectives.

Scope of foreign workers covered by WRAPA

Stakeholders may wish to comment on whether the categories of foreign workers currently protected under WRAPA remain appropriate or whether the scope should be expanded or contracted. Consideration may be given to whether certain categories of temporary foreign workers – such as those in higher-skilled occupations or those who enter Canada under international trade agreements – require the same level of protection as workers in more vulnerable positions, and conversely, whether emerging categories of foreign workers are inadequately covered by the current framework. The policy rationale for any changes should balance the protective objectives of the legislation with the practical realities of Manitoba’s labour market.

Penalty regime for violations

WRAPA establishes penalties for employers and recruiters who violate its provisions. Participants may have differing views on whether the current penalty regime is adequate to deter non-compliance and whether penalties should be increased, decreased or restructured. This includes consideration of whether monetary penalties are set at levels that are proportionate to the seriousness of the violation, whether there is sufficient differentiation between minor and serious contraventions and whether the penalty framework effectively achieves WRAPA’s protective objectives without imposing undue burdens on employers who are making good-faith efforts to comply.

Employment standards violations and compliance findings

Under WRAPA, certain employment standards violations can trigger an employer non-compliance finding. Stakeholders may wish to consider whether the range of employment standards violations that may give rise to a WRAPA compliance finding is appropriately calibrated. In particular, consideration may be given to whether minor or technical infractions of employment standards legislation – which do not reflect a genuine failure to protect or properly employ a foreign worker – should be excluded from the scope of violations that can trigger a WRAPA non-compliance finding. Limiting the triggering violations to more serious offences may better align the compliance regime with WRAPA’s protective purpose while reducing the risk of disproportionate consequences for employers.

We encourage employers, human resources professionals,  and all other interested stakeholders to review the consultation materials on the Engage MB platform and submit their feedback before the deadline of September 6, 2026. Public consultations such as this provide a valuable opportunity to shape the legislative framework that governs Manitoba’s foreign worker recruitment and protection landscape.

The MLT Aikins Immigration team regularly engages with governments, employers and industry stakeholders on immigration policy and workforce mobility issues. Participation in consultations such as this reflects the firm’s ongoing commitment to providing practical, business-driven perspectives that support Manitoba’s economic growth and competitiveness. If you have questions about WRAPA compliance, the consultation process or how the proposed changes may affect your organization, please contact the MLT Aikins Immigration team for guidance.

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