A staffing arrangement can look straightforward until someone asks who actually employs the person doing the work. One business recruits, another supervises and a third handles the payroll. For Canada's Temporary Foreign Worker Program, putting an employer's name on an application doesn't settle the question. In guidance updated September 18, 2026, Employment and Social Development Canada explains that Service Canada looks at the working relationship when it assesses a Labour Market Impact Assessment application. The assessment considers who benefits from the work, controls duties and working hours, pays wages, manages performance and has the authority to dismiss the employee. It also considers whom the worker recognizes as their employer and who signs the employment agreement. That approach matters when organizations use related companies, agencies or shared administrative arrangements. The federal guidance says staffing and employment agencies that recruit workers for other businesses aren't themselves considered employers for this purpose.
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