IMPACT – MEDIUM

What is the change? Norway has increased its minimum salaries for foreign nationals seeking residence permits for work purposes.

What does the change mean? The new thresholds are 391,800 Norwegian kroner (about US$48,200 or €41,141) per year (pretax) for positions requiring a bachelor’s degree and 421,700 kroner per year (pretax) for positions requiring a master’s degree.

  • Implementation time frame: July 2018 through June 2019.
  • Visas/permits affected: Residence permits for work purposes.
  • Who is affected: Employers sponsoring foreign employees for residence permits for work.
  • Business impact: The increases are about 1.5 percent above last year’s thresholds.

Background: Foreign employees working in Norway must not only be paid the salary minimums listed above, but must also be provided the same working conditions as Norwegian nationals. Foreign nationals also must be paid the salaries required by collective bargaining agreements if they are applicable to the work the foreign employee will be doing.

BAL Analysis: Employers should make sure they are in compliance with the new salary minimums.

This alert has been provided by the BAL Global Practice group and Stiegler WKS located in Norway. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) announced today that it has returned all fiscal year 2019 H-1B cap-subject petitions that were not selected in the computer-generated lottery.

Employers are reminded that it may take up to two weeks to receive all the returned petitions. A total of 190,098 H-1B cap-subject petitions were received during this year’s filing period. Data entry of all the H-1B cap petitions selected in the lottery was completed May 15. The agency then started to return rejected petitions.

BAL Analysis: Employers who submitted H-1B cap petitions during the April 2-6, 2018, filing period should receive either a receipt notice or a returned petition for their sponsored employees by Aug. 13. BAL has not yet received all returned petitions or receipts. As such, employers should continue to work with BAL if they have not received a receipt or a returned petition. In the meantime, BAL will continue to work with employers on possible alternatives for foreign workers who were not selected in the lottery.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) announced today that it will temporarily delay implementation of a recent policy change that would initiate removal proceedings against foreign nationals who fall out of status when their immigration petitions are denied.

Key points: 

  • The policy memorandum, issued June 28, directs USCIS to issue a Notice to Appear (NTA) when an individual is no longer in lawful immigration status following the denial of an immigration petition or application. The NTA is the document that formally initiates removal (deportation) proceedings. The policy effectively means that foreign nationals in nonimmigrant status who are denied an extension or change of status will be placed in deportation proceedings if they have no other underlying immigration status.
  • Today’s announcement means that the policy will be delayed until operational guidance is issued, which the agency said is pending. The policy memo directed USCIS components to issue guidance within 30 days of the June 28 publication (July 28), but the agency did not meet that deadline.

BAL Analysis: This announcement confirms that USCIS is not currently implementing the new NTA policy and will not begin implementation until operational guidance is issued. The delayed implementation gives businesses and foreign employees some additional time to prepare. The agency will be releasing operational guidance, which should make the impact of the policy memo clearer. Sources within the agency have indicated that officers are likely to be directed to grant a 30- or 45-day grace period before issuing NTAs to allow time for foreign nationals to appeal or leave the U.S. before the notice is issued. BAL is closely following this and other policy changes and will update clients as soon as information becomes available.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The number of H-1B visa denials and Requests for Evidence, or RFEs, rose sharply soon after President Trump issued the “Buy American and Hire American” Executive Order in April 2017, according to a new report by the National Foundation for American Policy.

Key figures:

  • H-1B denials increased by 41 percent from the third quarter to the fourth quarter of fiscal year 2017.
  • In the fourth quarter of fiscal 2017, 69 percent of H-1B cases received RFEs, more than double the rate in the third quarter, and a huge surge compared with only 17 percent of H-1B cases receiving RFE’s during the final quarter under the Obama administration.
  • Denial rates for L-1A applicants rose significantly from 12.8 percent in the first quarter of fiscal 2017 to 21.4 percent in the fourth quarter, and denials for L-1B petitions increased from 21.7 percent to 28.7 percent during the same period. The number of denials continued to remain high into the first half of fiscal year 2018 with a 30 percent average denial rate over the first two quarters.

The full report may be viewed here.

BAL Analysis: These figures released by U.S. Citizenship and Immigration Services confirm that recent policy initiatives are impacting adjudications of high-skilled immigration petitions. It should be noted that while all companies have experienced an overall increase in RFEs, the rates vary across industries, with IT consulting companies being particularly targeted for RFEs and H-1B denials.  

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The allocated quota for Tier 2 Restricted Certificates of Sponsorship has been exhausted for July. Requests from applicants with fewer than 41 points and with a salary below £41,000 per year were rejected. Employers will need to resubmit these requests in August.

What does the change mean? While the quota was exhausted for the eighth consecutive month, the points and salary cutoff was significantly lower than it was in May and June. This is likely a sign that demand for Tier 2 Restricted Certificates of Sponsorship is easing up, especially after the U.K.’s recent announcement that National Health Service doctors and nurses were removed from the quota.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Tier 2 (General).
  • Who is affected: Companies applying for Restricted Certificates of Sponsorship (RCoS) for non-EEA skilled migrants under the Tier 2 (General) category.
  • Impact on processing times: Rejected applications will need to be resubmitted in August, assuming that the resident market test remains valid.
  • Business impact: Companies sponsoring Tier 2 workers below the minimum salary level may need to delay work start dates. In some cases, employers may need to readvertise the positions.

Background: The annual quota for Tier 2 (General) visas is 20,700, allocated into monthly quotas with more visas allocated for the high-demand months of April through September. U.K. Visas and Immigration removed doctors and nurses from the quota in June, a move that appears to have already had a positive impact on the quota. The quota has been reached every month since December 2017; however, the points and salary cap dropped significantly compared with recent months. The points cutoff, for example, was 46 in April, 51 in May and 60 in June.

BAL Analysis: Pressure on Tier 2 quotas continues to pose challenges for employers recruiting non-EU workers. However, the removal of NHS doctors and nurses from the Tier 2 caps was met with approval from businesses and the backlog that built up over a period of months may be easing. BAL will follow matters in the U.K. to see if the drop this month becomes a long-term trend.

This alert has been provided by the BAL Global Practice and our network provider located in the United Kingdom.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

Several changes in how Turkish authorities are processing resident permit applications are causing backlogs and some inconsistencies in procedures.

Key points:

  • All initial resident permit applications filed in Istanbul are currently being transferred to the main office of the Migration Directorate in Vatan regardless of the branch where they are filed. This is causing a backlog and delays as supporting documents for all cases must be physically transferred, logged into the Vatan system and reviewed for final approval.
  • Applicants who need to travel outside Turkey while their resident permit is pending are generally unable to obtain an exit permit on the same day they file their resident permit application, as the case must be transferred and approved by the Vatan office before an exit permit can be issued. Because of the transfer of the files, issuance of exit documents is taking one week or longer.
  • Initial resident permit applicants must first log in their application and then wait for the Migration Directorate to respond with an appointment date. There does not appear to be a queue, and the wait time for appointments is highly inconsistent.
  • Applications to renew resident permits by mail may be denied if they are signed while the foreign national is not physically present in Turkey.
  • Short-term tourist resident permit applications are experiencing high denial rates due to applicants failing to prove sufficient financial resources and the concern that they will resort to working illegally in Turkey.

BAL Analysis: Resident permit applicants should factor in delays in the current unpredictable processing environment. Procedural changes may continue to be implemented or withdrawn with little notice and based on discretionary authority. Employers and foreign nationals should work with their BAL professional to adapt to these changes in individual cases.

This alert has been provided by the BAL Global Practice group and our network partner Bener located in Turkey. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Social security authorities in Budapest have reorganized their processing of social security numbers and issuance of certificates for foreign assignees.

What does the change mean? The government agency will now process requests for social security numbers in eight business days (instead of one day) and will issue the certificates by mail.

  • Implementation time frame: Immediate.
  • Visas/permits affected: Social security certificates.
  • Who is affected: Foreign nationals who are required to register and obtain a social security number. The change in processing is currently only affecting applicants in Budapest and those applying for their initial social security number (not renewals).
  • Impact on processing times: Eight business days for processing of the social security certificates and a few additional days for delivery of the certificate by mail.

Background: Previously, social security authorities in Budapest processed and issued social security numbers within one day, but offices outside the capital took eight days and sent the certificates via post. All offices in Budapest are now adopting the longer processing time.

BAL Analysis: Employees are generally not permitted to work until they are registered with social security authorities. Employers should factor in the additional processing time for new foreign employees’ social security numbers and may need to adjust work start dates accordingly. BAL is working with Hungarian officials to allow a workaround so that employees may start work while their social security number is pending. Employers should discuss these options with their BAL professional in individual cases.

This alert has been provided by the BAL Global Practice group and our network provider Inter Relocation in Hungary. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Russian immigration authorities have rejected applications filed by employers for registration of foreign nationals—even in cases where the employer is the “host party” for foreign registration purposes.

What does the change mean? The pattern follows the implementation this month of new regulations for the registration of foreign nationals. Local immigration authorities have refused registration applications from employers in a number of offices, including the Presnensky office and others in Moscow. Some offices are accepting registration applications from employers, but implementation is inconsistent.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Registration of foreign nationals.    
  • Who is affected: Foreign nationals and host parties completing registration in Russia.
  • Impact on processing times: Registration procedures may be delayed in some cases even when employers are the appropriate entity to register their employees.

Background: The new rules took effect July 8 and changed the requirements of the “host party” responsible for completing registration.

Parties of Lease Agreement Party Responsible for Registration Address of Registration
Landlord and employer; i.e., employer rents accommodation for foreign national. Employer. Address of accommodation.
Landlord and foreign national; i.e., foreign national rents accommodation directly from landlord. Landlord. Address of accommodation.

Since the regulations took effect, implementation has been inconsistent from office to office. In some cases, authorities have rejected applications from employers even when employers are renting accommodations on behalf of foreign nationals and, therefore, are responsible for completing registration.

BAL Analysis: In recent days, local office have begun to accept more registration applications from employers, though enforcement is still inconsistent. Employers are encouraged to work closely with BAL to ensure they are completing registration procedures.

Intermark Relocation, BAL’s network partner in Russia, continues to work with authorities, asking that they provide written clarification about the new regulations. It is not clear, however, how long the current enforcement trends will continue.

This alert has been provided by the BAL Global Practice group and our network provider located in Russia. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

Employment permit applicants are facing lengthy processing delays of several weeks due to a high volume of applications.

Key points:

  • Standard applications are being processed in 13 weeks; Trusted Partner applications are being processed in six weeks.
  • In addition to the delays for new employment permits, existing employees are experiencing delays in renewals and should apply for a temporary stamp from the Garda National Immigration Bureau to avoid any gaps in their residency permission. GNIB wait times for booking an appointment are also experiencing delays.
  • The Department of Business, Enterprise and Innovation has said that it is working to reduce the delays. However, the delays are likely to continue for several more weeks as authorities work through the backlog of applications.

Additional information: Processing delays are common during the summer vacation period, but the delays have grown worse this year. According to Jane Pilkington, a partner with Mason Hayes & Curran in Dublin, any employer who can qualify for Trusted Partner status should consider that option, because even though processing is slower than usual, the Trusted Partner queue is faster than standard processing.

BAL Analysis: Irish employers and foreign nationals should be aware of the delays and may need to adjust work start dates and travel schedules for new employees. Existing employees in Ireland who need a temporary stamp to prevent a lapse in residence permission should plan to book their GNIB appointment as far in advance as possible.

This alert has been provided by the BAL Global Practice group and our network partner Mason Hayes & Curran in Ireland. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Employers in need of work permits for foreign workers in quota-subject job categories are reminded that they should file their quota applications by July 31.

What does the change mean? Companies that have not already done so should submit their applications by the deadline.

  • Implementation time frame: Between now and July 31.
  • Visas/permits affected: Work permits. 
  • Who is affected: Companies seeking work permits for quota-subject foreign workers in 2019.
  • Business impact: Failure to file a quota application may prevent a company from being able to hire foreign workers.

Background: Filing a quota application is an annual requirement for companies that rely on foreign workers in job categories where quotas apply.

BAL Analysis: Companies should be sure to meet the July 31 deadline and should note that quota applications must be filed in any region where the company will have foreign labor needs in 2019. Companies that do not file the applications cannot apply for work permits if quotas expire.

This alert has been provided by the BAL Global Practice group and our network provider located in Kazakhstan. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.