Canada’s Bill C-9, enacted in June 2018, quietly but decisively reshaped how the country approaches labour mobility, particularly in relation to the Temporary Foreign Worker (TFW) Program. It’s a piece of legislation that, while perhaps lacking the headline-grabbing profile of more contentious policy changes, has had a deep impact on the agricultural and technology sectors. The years 2021 and 2022 offer a useful vantage point to assess how the bill has influenced labour supply chains—especially as employers grappled with both pandemic recovery and shifting regulatory expectations.
In agriculture, the reliance on temporary foreign labour is well established. What has changed post-Bill C-9 is the increased attention to how these workers are sourced, deployed, and managed within supply chains. The legislation, by streamlining aspects of labour mobility, aimed to reduce administrative friction for employers while introducing measures intended to protect worker rights and strengthen transparency. In practice, however, this has created a tension between efficiency and accountability. Employers now find themselves having to demonstrate, with greater rigour, that their recruitment practices meet both the letter and the spirit of the law.
One tool that has gained significance in this context is the open data published by Immigration, Refugees and Citizenship Canada (IRCC) on TFW program allocations. This dataset—once perhaps consulted mainly by researchers and advocacy groups—has become an increasingly valuable resource for agri-enterprises seeking to benchmark their own recruitment practices. The data provides granular insight into where temporary foreign workers are being deployed across provinces, sectors, and even, to some extent, specific occupations. For employers, this offers an opportunity to assess whether their labour sourcing patterns are in line with sectoral norms—or whether they might be exposing themselves to reputational or compliance risks by appearing as outliers.
It’s important, though, not to overstate what IRCC’s open data can deliver on its own. The figures tell us where TFWs are allocated, but they don’t, for instance, reveal the qualitative dimensions of recruitment: the conditions under which workers were hired, the transparency of the process, or the extent to which ethical recruitment standards were upheld. That’s where many firms are now being pushed—whether by regulators, buyers, or increasingly vocal segments of the public—to go beyond compliance and provide clearer, more detailed accounts of their labour sourcing practices.
Publishing recruitment process transparency reports is one avenue through which agri-enterprises can respond to these pressures. The process for producing such reports needn’t be overly burdensome, but it does require thoughtful design. At a basic level, a firm should begin by mapping its recruitment channels: which agents, agencies, or internal resources are involved in sourcing foreign labour? From which countries are workers recruited, and under what contractual terms? This information, though sensitive in parts, forms the backbone of any credible transparency report.
The next step involves connecting this internal map to the external reference points provided by IRCC’s open data. Are the firm’s TFW allocations consistent with national trends? Are there concentrations that warrant closer examination—say, a heavy reliance on workers from a particular region where labour rights have been flagged as a concern? These are not always easy questions, and the answers may be uncomfortable. But surfacing them is key to producing a transparency report that offers more than platitudes.
When it comes to the mechanics of publishing, firms should consider embedding their recruitment transparency disclosures into existing reporting structures. For example, integrating these reports into sustainability or corporate responsibility sections of their websites can ensure that the information is visible and accessible. Alternatively, dedicated microsites or stand-alone reports—linked prominently from the main corporate page—can signal a more serious commitment to transparency. The format matters less than the substance, though firms would do well to ensure that reports are easy to navigate and updated on a regular cadence—annually, at minimum.
The technology sector, while less frequently associated with the TFW Program in the public imagination, has not been untouched by Bill C-9’s influence either. As high-skill labour mobility became a greater focus for Canadian tech firms, particularly in the context of global talent competition, the need for clear, transparent recruitment and onboarding processes has grown. Open data from IRCC can similarly assist these firms in understanding broader trends and identifying any anomalous patterns in their use of temporary foreign labour. There is, however, an added complexity in tech: the interplay between TFWs and other labour mobility pathways, such as the Global Talent Stream, makes for a more intricate compliance landscape.
One challenge that surfaces across both agriculture and technology is that transparency, once initiated, can raise as many questions as it answers. A firm that publishes recruitment data might find itself pressed for further disclosures—on wages, living conditions, or long-term pathways to permanent residency for workers. There is no simple script here. Each enterprise must navigate these waters according to its own values, risk appetite, and stakeholder expectations. What’s clear, though, is that the environment is shifting. Passive compliance is increasingly insufficient. The direction of travel is towards proactive, documented, and publicly accessible reporting that goes beyond the minimum legal requirements.
Bill C-9, in this respect, may have done more than simply alter administrative procedures. It has catalysed a broader rethinking of labour supply chain transparency in sectors where reliance on foreign workers is deeply embedded. And as firms adapt, the tools they choose—whether open datasets, new reporting structures, or more robust internal audits—will shape not only their regulatory standing, but also their social licence to operate.