October 2026 Outbound Immigration and Global Mobility Recap | Americas

Clark Hill’s Outbound Immigration & Global Mobility practice guides corporate clients and individuals through complex global immigration challenges worldwide.  We pride ourselves on creative, compliant, and people-centered solutions – looking at global mobility from a holistic perspective in an ever-changing immigration environment. Our team assists with short-term assignments, long-term relocations, consular processing, document procurement, document legalizations/apostilles, and business visas in 100+ countries worldwide.

Below is an overview of the major updates from October 2026 in the Americas region.

Americas

Canada:

IRCC Clarifies Medical Exam Exemption

Immigration, Refugees and Citizenship Canada (IRCC) have clarified eligibility requirements for applicants seeking to rely on a previous Immigration Medical Examination (IME) instead of completing a new medical examination as part of a Canadian immigration application. The clarification specifically confirms that applicants must be residing in Canada to benefit from the temporary public policy allowing certain individuals to reuse a prior medical examination.

On September 22, 2026, IRCC updated its operational guidance for permanent residence applications, including Express Entry applications, to explicitly state that applicants must be physically residing in Canada to qualify for the medical examination exemption.

The clarification resolves uncertainty regarding applicants who previously lived, worked, or studied in Canada but have since relocated abroad. Such individuals are generally not eligible to rely on the exemption and will be required to undergo a new immigration medical examination as part of their application.

Qualification for the Exemption:

Applicants may be exempt from completing a new immigration medical examination if they meet all the following conditions:

• They are applying for permanent residence or temporary residence in Canada.
• They are currently residing in Canada.
• They completed a previous Immigration Medical Examination within the last five years.
• Their previous medical assessment indicated a low or no risk to public health or public safety.

Applicants seeking to utilize a prior medical examination should include their IME number or Unique Medical Identifier (UMI) with their application.

Who Does Not Qualify:

Applicants generally will not qualify for the exemption if:

• They are residing outside of Canada at the time of application.
• Their previous medical examination was completed more than five years ago.
• Their prior medical assessment does not meet the eligibility criteria established under the temporary public policy.

In these circumstances, applicants should expect to complete a new immigration medical examination.

The temporary public policy was originally introduced in 2022 to reduce processing delays and eliminate unnecessary repeat medical examinations. IRCC has extended the policy through October 5, 2029, although it may be modified or withdrawn at any time.

Incoming Quebec Government Proposes Lowering Immigration Targets

Following the Parti Québécois (PQ) victory in Quebec’s October 5, 2026, provincial election, the incoming government has proposed significant changes to the province’s immigration system, including lower immigration targets, reductions in temporary resident populations, and stricter French-language requirements. The proposals are not yet in effect and will require further government action before implementation.

The PQ intends to reduce Quebec’s non-permanent resident population from more than 500,000 individuals to between 250,000 and 300,000 over the course of its four-year mandate. This category includes temporary foreign workers, international students, and other temporary status holders.

The proposal would reduce the number of workers under the Temporary Foreign Worker Program to approximately 40,000, compared to current estimates exceeding 80,000 workers. The plan also contemplates tighter selection criteria, and regional or sector-based work permits rather than permits tied to a single employer.

The incoming government has proposed reducing the number of international students in Quebec to approximately 50,000, down from more than 120,000 currently. Additional measures may include changes to university funding models and increased support for French-language educational institutions.

The PQ has proposed reducing annual permanent immigration admissions from approximately 45,000 to 35,000 individuals, representing a reduction of nearly 22%. The plan also calls for a moratorium on selecting economic immigrants directly from outside Quebec, with a greater emphasis on transitioning temporary residents already living in the province to permanent residence.

A central component of the proposed immigration policy is a stronger emphasis on French-language proficiency. The incoming government intends to prioritize French-speaking candidates and may introduce stricter language requirements across immigration programs.

Express Entry Candidates Face New CRS Rules Beginning November 3, 2026, Prioritizing High-Wage Occupations

Immigration, Refugees and Citizenship Canada (IRCC) announced significant changes to the Express Entry Comprehensive Ranking System (CRS) that will take effect on November 3, 2026. The new rules introduce additional points for candidates with Canadian work experience or job offers in designated high-wage occupations and remove the Labor Market Impact Assessment (LMIA) requirement for qualifying job offers used to obtain CRS points.

A new Labor Market Integration factor will award additional CRS points to candidates with qualifying Canadian work experience or job offers in eligible high-wage occupations.

Candidates with Canadian Work Experience in High-Wage Occupations may receive:

• 20 additional points for eligible occupations meeting the minimum high-wage threshold
• 40 additional points for higher wage-tier occupations
• 70 additional points for the highest wage-tier occupations

These points are added to existing CRS points earned for Canadian work experience, allowing some candidates to receive up to 150 points under this factor.

Candidates with qualifying job offers in eligible high-wage occupations (depending on the occupation’s wage classification) may receive:

• 50 CRS points
• 70 CRS points
• 100 CRS points

Candidates cannot combine points from both a qualifying job offer and Canadian work experience. IRCC will automatically award whichever option results in a higher score.

Beginning November 3, 2026, qualifying job offers will no longer require a Labor Market Impact Assessment (LMIA) to establish eligibility for additional CRS points. This change is expected to simplify the process for many employers and applicants.

IRCC will automatically recalculate the CRS scores of all existing Express Entry profiles when the changes take effect. During this recalculation period, invitation rounds may be paused for up to two weeks. Candidates with qualifying job offers should ensure their Express Entry profiles are fully updated before November 3 to maximize potential points under the new system.

The changes are expected to benefit candidates working in high-paying, high-demand occupations by increasing their competitiveness in the Express Entry pool. Candidates in occupations that do not meet the high-wage criteria may experience little or no change to their CRS scores.

Employers may also benefit from the removal of the LMIA requirement for qualifying job offers, making it easier to support foreign national employees pursuing permanent residence through Express Entry.

Canada Introduces Tougher Penalties for Immigration Fraud

The Government of Canada has introduced new penalties aimed at strengthening the integrity of the immigration and citizenship system by targeting unauthorized representatives and fraudulent immigration service providers. The changes are intended to better protect applicants from misleading advice, dishonest practices, and unauthorized individuals who offer immigration or citizenship services without proper authorization.

Under the new measures, individuals and organizations found to be providing unauthorized immigration or citizenship advice for compensation may face increased fines, stricter enforcement actions, and potential criminal penalties. The government also expanded its ability to investigate suspected misconduct and take action against individuals who exploit foreign nationals and prospective immigrants.

Under the new regulations, IRCC may issue the following penalties:

• CAD 5,000 for providing paid immigration or citizenship advice or representation without proper authorization
• CAD 15,000 for knowingly submitting false or misleading information on behalf of an applicant or assisting an applicant in doing so
• Additional penalties where an immigration or citizenship application is approved based on false or misleading information
• Increased penalties for repeat or multiple violations, with total penalties reaching up to CAD 1.5 million

The measures apply to a wide range of representatives, including:

• Licensed immigration consultants
• Lawyers and other authorized representatives
• Individuals providing paid immigration or citizenship services without authorization
• Representatives operating both within and outside Canada.

These enhanced enforcement provisions reinforce the importance of using only authorized representatives, including licensed immigration consultants, lawyers, and notaries who are legally permitted to provide immigration and citizenship services in Canada. Applicants are encouraged to verify the credentials of any representative before engaging their services and to remain cautious of promises relating to guaranteed approvals or expedited processing.

Argentina:

Argentina Announces Details of New Citizenship by Investment Program

Argentina has officially released details of its new Citizenship by Investment (CBI) Program, with applications expected to open before the end of 2026. The program will provide qualifying foreign investors and their eligible family members with a pathway to Argentine citizenship without being subject to Argentina’s standard two-year residence requirement.

Investment Options:

Applicants may qualify through one of the following investment routes:

• USD $350,000 non-refundable contribution to the Argentine National Treasury
• USD $800,000 investment in a government bond created specifically for the program

Eligible Family Members:

The principal applicant may include the following dependents for additional contributions:

• Spouse: USD $100,000
• Unmarried child (ages 18-25, without children): USD $100,000
• Child under 18 years of age: USD $25,000

Application Review and Compliance:

Applicants will be subject to extensive due diligence and background screening, including:

• Identity verification
• Source-of-funds review
• Criminal background checks
• Immigration history review
• Financial and reputational screening
• Anti-money laundering and counter-terrorism financing compliance requirements

Applications will be reviewed by Argentina’s newly established Agency for Citizenship by Investment Programs, with final adjudication by the National Immigration Directorate.

Contact Clark Hill

For additional information, please contact the Americas Immigration team at Americas@ClarkHill.com.

For further information on any of the updates in this bulletin, reach out to one of the members of our Outbound Immigration & Global Mobility team.

To view October’s updates for the EMEA and APAC regions, click the respective region.

This publication is intended for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. The information in this publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this information without seeking professional legal counsel. The views and opinions expressed herein represent those of the individual author only and are not necessarily the views of Clark Hill PLC. Although we attempt to ensure that postings on our website are complete, accurate, and up to date, we assume no responsibility for their completeness, accuracy, or timeliness.