Residential camp counsellors [R205(b)] (LMIA exemption code C20) – International Mobility Program

This section contains policy, procedures and guidance used by Immigration, Refugees and Citizenship Canada staff. It is posted on the Department’s website as a courtesy to stakeholders.

As of March 1, 2017, camp counsellors working at residential camps during the summer season are exempt from the Labour Market Impact Assessment (LMIA) requirement pursuant to paragraph 205(b) of the Immigration and Refugee Protection Regulations (IRPR) (reciprocal LMIA exemption code C20). Canadians are given the opportunity to work as camp counsellors in various countries around the world. Given the existence of global opportunities for Canadians, proof of reciprocity is not required for individual applications.

Officers should distinguish between residential camps and day camps:

  • A residential camp is one where the campers and the camp counsellors stay overnight at the camp. All residential camp counsellor applications should be processed under LMIA exemption code C20, even for applicants going to faith-based camps. The normal work of a camp counsellor (whose primary duties consist of supervising children and leading sports, crafts, games and other recreational activities) is not typically considered religious in nature. Therefore, LMIA exemption code C50 (Canadian interests – Charitable work) should not be used. Guidance about the applicable fees can be found below.
  • A day camp is one where the campers go back home every day. Counsellors at day camps require an LMIA for a work permit and must pay all applicable fees.

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Documentary evidence

The onus is on the applicant to provide evidence that they meet the requirements of the work being sought. Documentary evidence may include:

  • a letter from the employer in Canada outlining
    • the organization’s purpose and mission, to help officers determine if a fee exemption applies (this information can also be specified in the offer of employment)
    • the applicant’s status with the company
    • the purpose of the foreign national’s visit to Canada
  • evidence demonstrating that they have knowledge and skills that will support their intended position as a camp counsellor (for example, curriculum vitae)

Note: Camp counsellors do not require a high school diploma.

Fees

The employer is not exempt from paying the employer compliance fee unless the foreign national applying to become a camp counsellor is fee exempt.

Charitable and religious organizations

A fee exemption applies [R299(2)(f)] if the camp counsellor is able to satisfy an officer that they meet both of the following conditions:

  • they are unpaid
  • they work for a charity or religious organization

Organizations registered as a charity with the Canada Revenue Agency (CRA) should have a registration number. Consult the CRA registration number webpage for more information.

For organizations not registered as a charity with the CRA, officers will need to determine if the organization falls within the CRA definition of a charitable organization. In general, for an organization to be considered charitable, its purposes must fall into one or more of the following 4 categories:

  • relief of poverty
  • advancement of education
  • advancement of religion
  • other purposes that benefit the community

Refer to the instructions on charitable work for more information regarding fees and guidance on how to determine if an organization is charitable in the absence of a CRA registration number.

Remuneration

To be fee exempt under paragraph R299(2)(f) (work permit fee exemption code E02), the foreign national cannot receive remuneration other than a stipend for living expenses, which should be, if monetary, below the minimum wage under the applicable federal, provincial or territorial law. Otherwise, the foreign national should receive only non-monetary benefits (for example, accommodation and health care).

Note: Foreign nationals who are provided with free room and board and receive a stipend may still qualify for a work permit processing fee exemption provided that the room and board are both

  • integral to the foreign national’s ability to perform the work according to the terms set out in their employment arrangement (meaning on-site residency is a requirement of the job)
  • non-monetized (for example, it has little or no market value, is not provided in a monetary form like allowance, does not constitute a taxable benefit, cannot be converted into an economic payout). For example, a room in a residential summer camp is considered to be of no market value in that it generally isn’t an option available to the public, and even if the employer were to advertise it, it’s not a “real” rental option, and it’s highly unlikely that someone genuinely looking for housing would be interested.

This assessment of remuneration should be used to determine fee exemptions for both initial work permit applications and any subsequent work permit applications. Note that a camp counsellor working at a residential camp is often “working” 24 hours a day as they are in charge of and responsible for the campers beyond a normal 7.5-hour work day. Officers should take this into account when considering hourly wage, minimum wage and fee exemptions.

Examples of charitable camps

In the context of determining if a sports camp may meet the definition of a charitable organization, sports activities should be ancillary and incidental to the main purpose, which means that only a small portion of the organization’s total resources (personnel, funds, and property) are devoted to the sports activities in question. For example:

  • Summer camps for low-income participants may qualify under the relief of poverty category even if there is a sports component.
  • Sports as part of an educational program, such as a school curriculum or even youth groups (for example, Guides and Scouts), may qualify under the advancement of education category.
  • Sports activities offered in addition to the main activity of religious instruction may fall under the advancement of religion.
  • Sports activities as part of a youth program may fall under the fourth category, purposes beneficial to the community, when they are designed to
    • build self-esteem
    • prevent addictions
    • provide therapy or rehabilitation (for example, wheelchair sports programs for people with spinal cord injuries, therapeutic riding programs for persons with disabilities, martial arts programs for people with attention deficit disorders)

Camps providing summer camp experiences to less fortunate children and youth may also be considered to be charitable organizations, for example, camps for:

  • low-income families
  • children affected by terminal illnesses
  • children facing physical, mental, emotional or social challenges

Immigration medical examination

Potential camp counsellors will be required to undergo an immigration medical examination only if they have resided or stayed in a designated country for 6 consecutive months at any time during the 1-year period immediately preceding the date they seek entry to Canada or submit their application.

Work permit duration

Officers may issue an LMIA-exempt work permit that is valid for the duration of the offer of employment or until the expiry of the travel document, whichever is earlier. If the foreign national is exempt from the travel document requirement (for example, they are a United States citizen), the work permit should be issued for the full duration of the offer of employment.

Note: The eligibility of camp counsellors under exemption code C20 is specific to seasonal camps as there is a demonstrable and established international reciprocity for this type of time-limited situation.

Port of entry application process

Individuals who are otherwise eligible to make an application at a port of entry (POE) may apply for a work permit when seeking entry to Canada. All regular processes and required documentation outlined above also apply to applications made at POEs.

Work permit issuance in the Global Case Management System (GCMS)

Under the “Application” screen, officers should confirm the following:

Case Type: 52.

Important: When the applicant selects the work permit type “Exemption from Labour Market Impact Assessment” on the application, the “Case Type” field in GCMS is set automatically to “52.” This case type should not be changed to anything else for employer-specific, LMIA-exempt work permit applications that require an offer of employment. No other case type will allow the correct linking in GCMS. Changing the case type to anything other than “52” will negatively impact the integrity of financial and program data in GCMS and may result in blocking the department’s ability to inspect employers.

Location: the city and province of destination entered by the applicant should match the address of employment in the LMIA-exempt offer of employment. This information is under the “Employment Details – LMIA Exempt” tab.

LMIA Exemption Code: C20 – this code is auto-populated from the LMIA-exempt offer of employment.

NOC: The National Occupation Classification (NOC) code is auto-populated from the LMIA-exempt offer of employment. It should be code 5254.

Intended Occupation: job title.

Employer: business operating name. This information will be auto-populated from the LMIA-exempt offer of employment.

Note: If the employer is authorized to use an IMM 5802 form instead of completing the offer of employment through the Employer Portal, please see Employer-specific work permits with Labour Market Impact Assessment (LMIA) exemptions (International Mobility Program).

Spouses and children of camp counsellors

For instructions related to spouses and children, refer to

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