Work Permit Renewal in Canada: What You Need to Know About Continued Authorization to Work (R186(u))
If you are a foreign national in Canada and have applied to renew your work permit before it expired, you may be able to keep working while Immigration, Refugees and Citizenship Canada (IRCC) processes your application. This authorization comes from a specific regulation: paragraph R186(u) of the Immigration and Refugee Protection Regulations (IRPR). This article explains everything you need to know about this rule, including who qualifies, how the interim work letter works, and what happens if you submit multiple applications.
- 01Work Permit Renewal in Canada: What You Need to Know About Continued Authorization to Work (R186(u))
- 02What is Paragraph R186(u)?
- 03Who Qualifies for Continued Work Under R186(u)?
- 04Important Distinction: R186(u) vs. Maintained Status
- 05Quick Reference Guide for R186(u)
- 06When Does R186(u) NOT Apply?
- 07Interim Proof of Work Letter (IMM 5988)
- 08Special Situations: IEC and PGWP Holders
- 09Subsequent Work Permit Applications: What Happens if You Apply Again While the First is Pending?
- 10Important Note About Withdrawals and Rejections
- 11Employer Compliance During R186(u) Period
- 12Frequently Asked Questions
What is Paragraph R186(u)?
Paragraph R186(u) is a provision in Canadian immigration law that allows certain foreign nationals to continue working without a work permit while their application to renew an existing work permit is being processed. This authorization is part of the International Mobility Program (IMP). It is important to understand that temporary resident status and the authorization to work are separate concepts under the Immigration and Refugee Protection Act (IRPA).
As of April 27, 2026, IRCC has updated its instructions to clarify this process. The key updates include a clear validity period for the interim proof of work letter and new guidance for subsequent work permit applications.
Who Qualifies for Continued Work Under R186(u)?
To benefit from paragraph R186(u), you must meet all of the following conditions:
- You applied to renew your work permit under section R201 before your initial work permit expired.
- You have remained in Canada (you have not physically left the country).
- You continue to comply with all conditions on your expired work permit, except for the expiry date itself.
For example, if you held an employer-specific work permit and applied for renewal, you must continue working for the same employer, in the same occupation, and in the same region as stated on that permit. If you held an unrestricted open work permit, you can work for any employer, in any occupation, and in any region while waiting for a decision.
Important Distinction: R186(u) vs. Maintained Status
Under subsection R183(5), foreign nationals who apply to extend their stay before their current status expires are granted "maintained status" (formerly known as implied status). This extends your authorized period of stay while the application is processed. However, maintained status alone does not authorize you to work. To continue working, you must separately meet the requirements of paragraph R186(u).
Quick Reference Guide for R186(u)
The following table summarizes when R186(u) applies based on your type of work permit and your application:
| Your Current Permit | You Are Applying to... | Does R186(u) Apply? | Key Condition |
|---|---|---|---|
| Employer-specific | Renew with same employer and conditions | Yes | Must continue with same employer, occupation, and region. |
| Employer-specific | Renew with same employer but different conditions | Yes | Must continue with original conditions until decision. |
| Employer-specific | Renew with a different employer | Yes, but with a restriction | Cannot start working for the new employer until application is approved. |
| Employer-specific | Renew as an open work permit | Yes, but with a restriction | Cannot work for a new employer until renewal is approved. |
| Employer-specific | Change to study permit or visitor record | No | Not applying under section R201. |
| Open work permit | Renew an open work permit | Yes | Open work permit conditions continue to apply. |
| Open work permit | Renew as an employer-specific work permit | Yes | Open work permit conditions continue while processing. |
| Open work permit | Change to study permit or visitor record | No | Not applying under section R201. |
When Does R186(u) NOT Apply?
R186(u) does not apply if you are applying for your first work permit from within Canada (an initial application under section R200). This includes spouses of international students or skilled workers who entered Canada as visitors, or foreign nationals already working under another section of R186. In these cases, you can only begin work when you receive the work permit, unless another regulation or temporary public policy allows it.
Interim Proof of Work Letter (IMM 5988)
When you submit an online work permit renewal application, IRCC’s Global Case Management System (GCMS) first sends a generic Temporary Resident Acknowledgement of Receipt (TR Acknowledgement of Receipt). Then, as of October 20, 2020, GCMS automatically sends a second letter (IMM 5988 - WP-EXT only except post-graduation work permit) indicating that you are authorized to work under paragraph R186(u), provided all conditions are met.
How long is the letter valid? The letter has a validity date of 365 days. However, the letter itself does not override the actual requirements of R186(u). If you leave Canada or a final decision is made on your application, the requirements of R186(u) are no longer met, and the letter is no longer valid.
What if the 365 days pass and my application is still being processed? If your work permit application has not been finalized by the date provided on the letter, you may continue to work as per R186(u) until a decision is made, provided you continue to meet the R186(u) requirements. You do not need to submit a request to IRCC for a second letter.
Special Situations: IEC and PGWP Holders
International Experience Canada (IEC) Participants
If you are participating in IEC and apply for a work permit renewal outside of the IEC program while your IEC work permit is still valid, R186(u) applies. The conditions of your IEC work permit are maintained until a decision is made. Importantly, this period does not count as an extension of your IEC participation.
Post-Graduation Work Permit (PGWP) Holders
The PGWP is not renewable. It is issued for a minimum of 8 months and a maximum of 3 years. However, if you hold a PGWP and apply for a work permit renewal outside of the PGWP (for example, under a different program), you may benefit from R186(u) while your new application is processed.
Subsequent Work Permit Applications: What Happens if You Apply Again While the First is Pending?
A new section in the April 27, 2026 update addresses situations where you submit a second work permit application while your first renewal application is still being processed. The outcome depends on the status of the first application.
Scenario 1: Initial work permit was still valid when both applications were submitted
| Outcome of First Application | What Happens? | Impact on Subsequent Application |
|---|---|---|
| Pending | You maintain status and work authorization until a decision on the first application. | You maintain status and work authorization until a decision on the subsequent application. |
| Approved | New permit sets new conditions. R186(u) no longer applies. | You may hold two permits. Period of authorized stay is the longest validity date. If subsequent application is refused, conditions from first approval continue. |
| Refused or withdrawn | Status and work authorization end when decision is made or application withdrawn. | You maintain status and work authorization from expiry of initial permit until decision on subsequent application. If subsequent application is refused, you may apply for restoration or leave Canada. |
| Returned as incomplete (R12) | Application considered never submitted. No R186(u) applies under first application. | Subsequent application meets R183(5) and R201. You maintain status and work authorization from expiry of initial permit until decision on subsequent application. |
Scenario 2: Initial work permit was valid when first application was submitted, but expired when subsequent application was submitted
| Outcome of First Application | What Happens? | Impact on Subsequent Application |
|---|---|---|
| Pending | You maintain status and work authorization until decision. | - |
| Approved | New permit sets conditions. R186(u) no longer applies. | You may hold two permits. Period of authorized stay is the longest validity date. |
| Refused or withdrawn | Status and work authorization end at time of refusal or withdrawal. | Subsequent application is a new application under R200, not a renewal. R186(u) does not apply after refusal/withdrawal. You must consult restoration guidance. |
| Returned as incomplete (R12) | Application considered never submitted. No R186(u) applies. | Subsequent application does not meet R183(5) or R201 because initial permit expired before this application. You are out of status. Application should be refused under R200. |
Scenario 3: Subsequent application received after the first renewal application was refused and after the initial work permit expired
In this case, you are out of status. You can apply for restoration if eligible, or leave Canada. The subsequent application is assessed as a new application under R200.
Important Note About Withdrawals and Rejections
When you withdraw a work permit application, it has the same effect as a refusal for in-Canada applicants. Your status and authorization end on the date of withdrawal. However, if your application is rejected under R12 (for incompleteness), it is as if you never submitted an application at all.
Employer Compliance During R186(u) Period
Employers should note that under subsection R209.2(2), the period of employment includes any time the temporary resident was authorized to work under paragraph R186(u) after their work permit expired. This means employers continue to be subject to conditions and may be subject to inspection until a decision is made on the renewal application.
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