PNP Work Permit Without an AOR: How to Keep Working Under IRCC Bulletin 699 (2026)

If you are a provincial nominee in Canada and your work permit is running out before your Acknowledgement of Receipt (AOR) has arrived, you may have a temporary option, depending on your status, your proof of PR submission, your nomination details, and the work permit category you are applying under. On June 9, 2026, IRCC introduced a temporary operational measure, Operational Bulletin 699, that allows eligible in-Canada Provincial Nominee Program (PNP) applicants to apply for certain work permits without an AOR.

This guide is written for the person living that problem right now. It explains, in plain English, whether you can keep working today, what actually changed, who this does and does not help, which work permit is yours (bridging open work permit, T13, or a spousal open work permit), what to file in place of an AOR, and the timing, travel and refusal risks that decide whether your application succeeds. It is based on IRCC’s own bulletin and current program pages. This is a temporary operational measure, not a permanent rule or a public policy, and IRCC makes all final decisions.

Immigration information reviewed for general informational purposes by Omer Khalil, RCIC

CICC Licence R710149 · MAK Canadian Immigration Services

Last reviewed: July 2026

Detailed Answer

From June 9, 2026 to December 31, 2026, IRCC allows eligible in-Canada PNP applicants for permanent residence (base or Express Entry) to submit alternative proof of PR submission instead of an AOR for three work permits: a PNP bridging open work permit (BOWP/A75), a PNP employer-specific work permit (T13) where the nomination has expired, and an eligible spousal open work permit for a partner of the PNP principal applicant. In place of the AOR, an officer may be satisfied by either your online portal email confirming you submitted your PR application plus proof you paid the PR fees, or IRCC’s own system confirmation that your PR application is received and pending. It applies to applications made from inside Canada only, it does not change the rest of the eligibility rules, and it does not guarantee approval. If your AOR has already been issued, you must use the AOR. And if you file your new work permit application before your current permit expires, you may be able to keep working under maintained status while IRCC decides.

Who this applies to

This measure is narrow and specific. To fall under it, generally all of these must be true:

• You are physically in Canada and applying from inside Canada.
• You have already submitted a permanent residence application under the Provincial Nominee Program (base PNP or Express Entry PNP), not just an Express Entry profile or a nomination on its own.
• You have not yet received your AOR.
• You are applying for one of the three covered work permits: a BOWP, a T13 where the nomination has expired, or an eligible spousal open work permit tied to the PNP principal applicant.
• You still meet all the normal eligibility rules for that work permit.

Who this does NOT help

Be honest with yourself about this list before you spend money on an application. This measure does not help:

• applicants who are outside Canada;
• applicants who already have an AOR and simply prefer not to upload it;
• people who have not actually submitted a PNP PR application;
• people who only hold a nomination but did not submit their PR application;
• applicants whose PR application was returned as incomplete;
• people who missed their work permit expiry and are no longer eligible to work on maintained status;
• non-PNP permanent residence applicants;
• PNP nominees whose nomination carries an employment restriction and who are seeking a BOWP;
• anyone applying after December 31, 2026, unless IRCC extends the measure.

If you are on this list, the alternative proof does not fix your situation. Get advice on what will.

Can you keep working right now? Maintained status

A key practical question is whether you can keep working while the new application is pending. If you applied for your new work permit (a BOWP, a T13, or a spousal open work permit) before your current work permit expired and you remain in Canada, you may be authorized to keep working under the same conditions while IRCC processes the new application. This is called maintained status, formerly known as implied status. The exact result depends on the type of application you filed and whether all maintained-status conditions are met.

The practical takeaway is simple but critical: file before your permit expires, not after. If you wait until after your permit expires, maintained status does not apply, you must stop working, and your route back is restoration of status (covered below). For an otherwise eligible covered in-Canada PNP work-permit application, Bulletin 699 may remove the AOR-proof barrier at filing when the AOR has not yet been issued. Maintained-status work authorization still depends on the applicable work-permit and status rules.

What Bulletin 699 changed

Before this bulletin, several in-Canada work permits required you to prove your PR application was already in process, and the standard proof was the AOR. No AOR meant no BOWP, no T13 where the nomination had expired, and no spousal open work permit tied to the PNP file. Because AORs were taking many months to arrive, otherwise eligible nominees were being refused and losing the right to work.

Operational Bulletin 699 changes that temporarily. For these three work permits, IRCC says officers may temporarily accept alternative evidence that your PR application was submitted and received, in place of the AOR. Nothing else about the program changes. Your eligibility, the completeness or eligibility review of your PR application, and the final decision all still apply. The bulletin only changes what can count as acceptable proof that your PR application is in the system. It took effect immediately and stays in place until December 31, 2026. Unless IRCC extends it, the standard AOR requirement returns after that date.

What an AOR is, and why it blocked your work permit

An AOR is the acknowledgement IRCC issues after the applicable PR intake or completeness stage. Under the ordinary PNP BOWP instructions, the AOR is required along with the applicable completeness or eligibility stage. Operational Bulletin 699 temporarily allows specified alternative proof of PR submission at the in-Canada work-permit stage when no AOR has yet been issued, but the alternative documents do not constitute or replace the R10 completeness or PNP eligibility assessment.

The problem through 2025 and into 2026 was delay. The checks that lead to an AOR stretched far beyond their normal timelines, so AORs were arriving many months after applicants filed. Because the AOR was the trigger for work permit eligibility, the delay created a trap: people who had filed complete PR applications were losing work authorization over a receipt IRCC had not yet issued. Bulletin 699 targets exactly that gap.

BOWP vs T13 vs spousal open work permit: which route is yours

The bulletin covers three different work-permit categories. Identify which category fits your situation, then confirm the underlying eligibility requirements before filing.

BOWP eligibility (Express Entry vs base PNP)

For the bridging open work permit route, IRCC’s eligibility rules still apply. Bulletin 699 temporarily changes the proof-of-PR-submission and AOR piece only. It does not remove the remaining BOWP requirements.

• You live in Canada and intend to live outside Quebec when you apply.
• You have valid temporary resident status and a valid work permit, or you have an expired work permit but maintained your status as a worker, or you are eligible to restore your status and get a work permit.
• You are the principal applicant on the PR application.
• Your provincial nomination has no employment restrictions.
• The ordinary BOWP decision stage still applies. For Express Entry PNP, the PR application must pass the completeness check. For base PNP (not through Express Entry), the PR application must pass the PNP eligibility assessment. Bulletin 699 allows alternative proof of PR submission when the AOR has not yet issued; it does not itself establish or waive those assessments.
• Under ordinary instructions, the AOR is required. Under Bulletin 699, when no AOR has been issued at the time of the in-Canada work-permit application, the portal submission email plus proof of applicable PR fee payment, or IRCC system confirmation that the PR application was received and remains pending, may be accepted instead. If the AOR has already been issued, you must submit it.

For PNP BOWP applicants, another important rule is that you must be in Canada with valid temporary resident status when IRCC decides your BOWP, or the application may be refused.

T13 eligibility and employer responsibilities

A T13 is different from a BOWP. It is an employer-specific, closed work permit, meaning it ties you to one named employer, job, location, and province. Because it is employer-specific, there are employer-side steps, not just applicant steps:

• Your employer will usually need to submit an offer of employment through IRCC’s Employer Portal and pay the employer compliance fee, unless an exemption applies.
• The permit is tied to that specific employer and role, so you cannot freely change jobs the way a BOWP allows.
• You should confirm the nomination status, any provincial support letter, and the employer and job details, because province-specific requirements vary.

For a T13 where the nomination has expired, the underlying T13 rule requires that IRCC received the PNP permanent residence application before the nomination expired. Bulletin 699 temporarily changes how an eligible in-Canada applicant can prove PR submission when the AOR has not yet issued; it does not remove the remaining employer-specific work-permit or provincial-support requirements. If those underlying requirements are not met, the alternative proof alone does not establish eligibility.

Spousal open work permit: read this before you assume you qualify

Bulletin 699 covers eligible spousal open work permits for spouses or common-law partners of PNP principal applicants. That is a real and valuable inclusion, but do not assume every spouse automatically qualifies. The spouse or common-law partner must still meet the separate family-member open-work-permit rules that apply to their situation. The bulletin removes the AOR-proof barrier tied to the principal applicant’s PR file. It does not replace the eligibility rules for the spouse’s own open work permit. Check the family-member open work permit criteria before filing, or have them reviewed.

What to upload instead of an AOR (document checklist)

Under Bulletin 699, an officer may be satisfied by either one of these in place of the AOR:

1. a copy of the email confirming you submitted your PR application through the online portal, together with proof you paid the applicable PR fees; or
2. IRCC’s own system confirmation that your PR application has been received and remains pending, including prospective applications visible in GCMS.

Either one may be enough, and where IRCC’s system confirmation exists, officers are told they can rely on it. In practice, build your work permit application package like this:

• the IRCC portal email confirming your PR submission (save the PDF);
• your PR fee payment receipt;
• your provincial nomination letter;
• a copy of your current work permit and evidence of your status;
• your completed application to change conditions or extend your stay as a worker, submitted online;
• for a T13, the employer-side offer of employment and any provincial support letter;
• a short cover letter noting that you are relying on the temporary facilitation in Operational Bulletin 699 because your AOR has not yet been issued.

Keep copies of everything in two places. Having your own proof ready helps prevent a delay or an avoidable refusal.

Fees you have to pay

The work permit fees are not changed by this measure. For an open work permit such as a BOWP or a spousal open work permit, you pay the work permit processing fee plus the open work permit holder fee (as of 2026, that is $155 plus $100, for $255 total), and biometrics may cost extra if you are asked to give them. For a T13, an employer compliance fee usually applies on the employer side unless exempt. Make sure all applicable fees are paid and confirm the current amounts on IRCC’s fee list immediately before you submit.

Timing and travel risk

Two deadlines matter, and they are not the same. First, your own permit expiry: file your new work permit application before your current permit expires so maintained status has a chance to protect your right to keep working. Second, the bulletin’s expiry: Bulletin 699 remains in place until December 31, 2026. If you rely on this temporary facilitation, submit the covered in-Canada work-permit application while the measure remains in effect, unless IRCC issues further instructions.

Should you travel while waiting? Be careful. If you leave Canada after your work permit expires, you may lose the ability to work until your new permit is approved. For a BOWP specifically, IRCC says you must be in Canada with valid temporary resident status when the BOWP decision is made, or the application may be refused. If travel is unavoidable, get advice on timing first so you do not accidentally undermine your own application.

If your work permit already expired: restoration

If your work permit has already expired and you did not apply before it lapsed, you do not have maintained status and you must stop working. You may still be able to apply to restore your status if you are within 90 days of losing it and you meet the requirements. Restoration is time sensitive and has its own conditions, so if you are already past your expiry date, treat it as urgent and get advice immediately rather than continuing to work without authorization.

If your work permit was refused before June 9

If your work permit was refused before June 9, 2026 because you did not have an AOR, the bulletin does not automatically reopen or reverse that refusal. Potential options may include filing a fresh application under the current measure, restoration if you are still eligible, or a legal review of the refusal reason. The right path depends on your status, the relevant dates, the exact wording of the refusal, and whether you still have authorization to work. Because a second refusal is costly, this is a situation where a file review before you act is worth it.

Practical risk checklist

Before you file, run through these:

• Alternative proof is not a completeness determination. If your PR application is later found incomplete and returned, the normal consequences apply, which can affect your future work permit eligibility. Make sure your PR application was genuinely complete.
• Maintained status only helps if you filed before your permit expired.
• For a PNP BOWP, IRCC requires you to be in Canada with valid temporary resident status when it makes the BOWP decision; the T13 and spousal routes have their own status and eligibility requirements.
• The measure is temporary and in-Canada only. Do not rely on it from outside Canada or after December 31, 2026.
• It does not change the underlying eligibility or admissibility requirements, which still must be met in full.
• It does not guarantee approval.

How MAK can help

MAK Canadian Immigration Services can confirm whether Bulletin 699 applies to your file, check your permit expiry and maintained-status timing, help you choose the right filing (BOWP, T13, spousal open work permit, or a combination), assemble the alternative-proof package correctly, and file a complete application that meets the usual eligibility and admissibility requirements. MAK Canadian Immigration Services provides immigration consulting services through licensed RCICs regulated by the College of Immigration and Citizenship Consultants (CICC), and we set realistic expectations for your situation. IRCC makes the final decision.

Frequently Asked Questions

Official Sources Reviewed

This article was reviewed against current official Government of Canada and IRCC sources. Official sources last checked: August 16, 2026.

• IRCC – Operational Bulletin 699 (June 9, 2026)
• IRCC – Bridging open work permit for permanent residence applicants
• IRCC – Maintained status (Help Centre)
• IRCC – Restore your status as a worker
• IRCC – Open work permits for family members (eligibility)
• IRCC – Employer Portal
• IRCC – Citizenship and immigration application fees (fee list)

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