ANALYSIS: How Canada reversed the US immigration playbook

Canada and the United States (US) both scaled back on immigration in 2025, but did so in dramatically different ways.

US immigration policy under Donald Trump took a more protectionist approach, cutting back on foreign workers across the board with the view that such workers displace Americans from the US labour market.

In contrast, Canada scaled back on immigration in a targeted fashion, shaping permanent residence (PR) and work permit pathways to target foreign nationals in specific sectors to meet key labour market needs and fuel economic growth.

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Nowhere is this more evident than in the openings and closures of PR pathways by each nation.

In January 2025, Canada launched two new pathways to PR to fill labour market needs in remote communities. And in November, Canada announced the launch of a new temporary to permanent residence pathway intended to transition existing work permit holders in Canada to permanent status.

The US, in contrast, suspended its Diversity Visa Program, which has historically provided opportunities for permanent residence to foreign workers from underrepresented immigration source countries, and established the “Gold Card,” a million-dollar ticket to PR aimed at wealthy entrepreneurs from abroad.

Canada’s two new PR pathways, the Rural Community Immigration Pilot (RCIP) and Francophone Community Immigration Pilot (FCIP), are employer-driven programs focused on fulfilling labour market needs in select communities.

Although these programs are federal PR pathways, they distribute decision making to the regional level: to qualify, a foreign national needs a job offer from a local employer, and both the employer and the job offer must be supported by the region’s local economic development organization, thereby empowering rural and remote regions to bring in permanent residents as workers to fulfill the labour needs of local businesses.

The Gold Card, in contrast, requires no work experience whatsoever, but instead aims simply to sell PR status to high net worth foreign nationals from abroad, regardless of where they choose to settle, and is aimed at entrepreneurs and business owners, with the intention that they will establish and grow businesses and pay taxes in the US.

The Gold Card’s pay-to-play approach to permanent residency can be considered the antithesis of the “level playing field” that had previously been provided to underrepresented foreign nationals in the US’s Diversity Visa Program, which operated on an equal opportunity lottery system.

Over 2025, Canada also reoriented its strategy to prioritize skilled workers in specific, high-demand fields. In February, 2025, the Canadian federal government created new pathways to permanent residence for foreign workers in select in-demand occupations in healthcare, social services, education, and trades, and in December of 2025, created a special pathway to permanent residence for physicians with Canadian work experience.

Meanwhile, the US government announced plans for a “Trump Platinum Card” with a five million USD price tag. It gives holders the ability to spend up to 270 days in the US without being subject to US taxes on non-US income.

In offering an expensive ticket to tax-exempt US residency for wealthy business owners living abroad, Trump’s Platinum Card is the polar opposite of the Carney government’s TR to PR pathway, announced in November of 2025, an upcoming program aimed at transitioning to permanent residence up to 33,000 foreign workers “who are already living in Canada and paying taxes”.

What changed for foreign workers in Canada and the US in 2025?

Approaches to work authorization for foreign nationals also reflected the US’s broad cuts across the board against foreign labour, versus Canada’s more surgical approach aimed at selectively issuing permits to provide the labour needed to fuel economic growth.

In September, 2025, the US announced a $100,000 fee for employers applying to sponsor foreign workers overseas for the H-1B visa, US employers’ go-to program for hiring skilled foreign workers for in-demand occupations requiring advanced degrees, such as those in healthcare, engineering, and tech. As of the time of writing, it is estimated that there are approximately 700,000 H-1B visa holders working in the US. After the proclamation on September 21, 2025, registrations for H-1B lottery fell 27% (2026 versus 2025).

Canada, in contrast, selectively scaled back on work permits. The Canadian federal government ceased the issuance and renewal of permits under its go-to employer-driven work permit program, the Temporary Foreign Worker Program (TFWP), specifically for lower-paid jobs in regions of high unemployment, and restricted the issuance of spousal open work permits (SOWPs) to spouses of cream-of-the-crop international students and foreign workers.

The prohibitive 100k filing fee for US employers applies to petitions for all workers overseas, without regard to the roles being hired for or for local labour markets, whereas Canada’s moratorium on low-wage TFWP positions and the stricter criteria on SOWPs apply equally to workers both inside and outside Canada.

On the heels of the US H-1B fee proclamation, Canada announced upcoming plans for both work permit and permanent residence pathways aimed at capturing foreign talent displaced from US employers on account of the fee hike. In November, 2025, the federal budget promised an accelerated pathway to Canadian permanent residence for foreign nationals holding US H-1B visas.

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