U.S. Citizenship and Immigration Services announced today that is has updated its Policy Manual to reduce the maximum validity period for which USCIS will grant Employment Authorization Documents (EADs) for certain categories of foreign nationals.

Key Points:

  • Maximum validity periods for initial and renewal EADs will be reduced from five years to 18 months for foreign nationals with employment authorization applications pending or filed on or after Dec. 5, 2025, based on one of the following categories:
    • Foreign nationals admitted as refugees
    • Foreign nationals granted asylum
    • Foreign nationals granted withholding of deportation or removal
    • Foreign nationals with pending applications for asylum or withholding of removal
    • Foreign nationals with pending applications for adjustment of status under INA 245
    • Have pending applications for suspension of deportation, cancellation of removal or relief under the Nicaraguan Adjustment and Central American Relief Act
  • According to the announcement, “The reduced maximum validity periods for certain categories will result in more frequent vetting of aliens who apply for authorization to work in the United States.”
  • Changes to EAD validity periods made by reconciliation bill H.R. 1 signed into law on July 4, 2025, have also been incorporated into the updated Policy Manual. The legislation provided that the validity period for initial and renewal EADs will be one year or the end date of the authorized parole period or duration of Temporary Protected Status (TPS), whichever is shorter, for certain classifications. Those new maximum validity period requirements apply to any Form I-765, Application for Employment Authorization, pending or filed on or after July 22, 2025.

Additional Information: BAL will continue to monitor related policy developments and provide updates.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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 Department of Homeland Security received emergency approval on Nov. 19 from the Office of Management and Budget (OMB) to implement Form I-140G, the immigrant petition for the Gold Card program.

Key Points:

  • The OMB approval marks an important step toward the program’s implementation, expected in mid-December.
  • According to Form I-140G instructions, “Form I-140G is the first step in the Gold Card process. Once the petition is approved and there is an immigrant visa number available in the requested employment-based classification, you must complete consular processing with the U.S. Department of State at an embassy or consulate to get an immigrant visa and travel to the United States to be admitted as a lawful permanent resident.”
  • The form consolidates key eligibility criteria and documentation requirements to simplify adjudication.
  • The fee for Form I-140G is $15,000 per person. Both the form and instructions for completing the form can be found on the designated “Immigrant Petition for the Gold Card Program” OMB web page.
  • Employers and applicants should expect further guidance on filing instructions and compliance requirements in the coming weeks.

Additional Information: BAL will continue to monitor related developments and provide updates. Interested employers and individuals can connect with BAL’s Gold Card team.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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 Department of Homeland Security (DHS) published a Federal Register notice (FRN) on Nov. 28, 2025, “newly terminating” the Temporary Protected Status (TPS) for Haiti effective Feb. 3, 2026.

Key Points:

  • According to the FRN, “After reviewing country conditions and consulting with appropriate U.S. Government agencies, the Secretary determined that Haiti no longer meets the conditions for the designation for Temporary Protected Status. The Secretary, therefore, is newly terminating the Temporary Protected Status designation of Haiti as required by statute.”
  • Until the Feb. 3, 2026, expiration date, the FRN automatically extends the validity of certain Employment Authorization Documents (EADs) previously issued under the designation. The FRN states that “as proof of continued employment authorization through Feb. 3, 2026, Temporary Protected Status beneficiaries can show their EADs that have the notation A-12 or C-19 under Category and a ‘Card Expires’ date of Feb. 3, 2026; Aug. 3, 2025; Aug. 3, 2024; June 30, 2024; Feb. 3, 2023; Dec. 31, 2022; Oct. 4, 2021; Jan. 4, 2021; Jan. 2, 2020; July 22, 2019; Jan. 22, 2018; or July 22, 2017.”
  • After Feb. 3, 2026, Haitian nationals and “aliens having no nationality who last habitually resided in Haiti” previously granted TPS under Haiti’s designation will no longer have TPS or work authorization.
  • This determination to terminate the TPS designation for Haiti supersedes the determination announced in the July 1, 2025, FRN, which was later vacated in federal court.

Additional Information: BAL will continue to monitor related developments on this matter and provide updates.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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 State Department updated its webpage, U.S. Visa and Travel Information for FIFA World Cup 26 Fans, with preliminary information on the FIFA Priority Appointment Scheduling System (PASS).

Key Points:

  • According to the webpage, “FIFA World Cup ticket holders who have not yet scheduled their visa appointment and are applying in a location where the next available appointment (as shown in the wait times on our website) falls after kick-off should wait to apply until FIFA PASS appointments become available in early 2026. FIFA World Cup ticket holders who already have a visa appointment scheduled before kick-off should proceed with that appointment.”
  • The FIFA PASS was initially announced by the White House Task Force on the FIFA World Cup 2026 on Nov. 17.
  • The State Department says further information regarding FIFA PASS will be forthcoming in early 2026.

Additional Information: The State Department advises that “all visitors traveling to the United States are required to be in possession of passports that are valid for six months beyond the period of their intended stay in the United States, unless they are a citizen of an exempt country.”

Canadian and Bermudan passport holders do not require any additional authorization for U.S. entry as tourists.

Foreign visitors from any of the 42 countries who participate in the Visa Waiver Program can apply using the Electronic System for Travel Authorization (ESTA). Visitors from all other countries are required to have a valid B-1/B-2 visitor visa.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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 Department of Homeland Security published notice of the termination of the designation of Burma (Myanmar) for Temporary Protected Status (TPS), effective Jan. 26, 2026.

Key Points:

  • DHS has determined that “while certain extraordinary and temporary conditions may remain [in Burma], such conditions no longer hinder the safe return of aliens who are nationals of Burma to the country.”
  • In addition, DHS has determined that terminating Burma’s designation of TPS is required because “it is contrary to the national interest to permit Burmese nationals to remain temporarily in the United States.” The published notice specifically refers to the rate of Burmese overstay rates, which were over 15 times higher for B-1/B-2 visas and over 17 times higher for F, M and J visas in fiscal year 2024 than the average visa overstay rates of all countries in that time.
  • Through the Nov. 25 Federal Register notice, DHS automatically extends the validity of certain Employment Authorization Documents (EADs) previously issued under the TPS designation of Burma through Jan. 26, 2026. As proof of continued employment authorization through Jan. 26, 2026, TPS beneficiaries can show their EADs that have the notation A-12 or C-19 under Category and a “Card Expires” date of Nov. 25, 2025; May 25, 2024; or Nov. 25, 2022.
  • After Jan. 26, 2026, Burmese nationals (and nonimmigrants having no nationality who last habitually resided in Burma) who have been granted TPS under Burma’s designation will no longer have TPS.
  • BAL continues to monitor related legal developments.

Additional Information: DHS estimates that there are 3,969 current approved beneficiaries under the designation of Burma for TPS.

Burma was initially designated for TPS on May 25, 2021, based on extraordinary and temporary conditions. Following the initial designation, the existing designation was extended and newly designated for TPS in 2022, and again from May 26, 2024, to Nov. 25, 2025.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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 State Department updated global visa wait times on Nov. 20, 2025.

The average wait times reported do not guarantee a visa applicant will get an appointment within a specific time. U.S. embassies and consulates regularly release additional appointment slots. Applicants who want an earlier appointment slot after initially scheduling their interview should check back frequently and move their appointment to another slot if available.

November 2025 global visa wait times chart highlights

Excerpted below are chart highlights from the latest global visa wait times of some of the cities/posts that historically have the most visa issuances. Work visa (H, L, O, P, Q) and student/exchange visitor visa (F, M, J) wait times for next available interview appointments mostly remained the same month over month across these highlighted cities/posts. However, New Delhi saw a substantial reduction in F, M and J visa next available appointment wait times from 2 months to 0.5 months. Next available appointment wait times for Shanghai H, L, O, P and Q visas nearly tripled from <0.5 months to 3 months compared with the October global visa wait time report.

Chennai (Madras) saw interview-required B-1/B-2 average wait times move from 5 months to “N/A” and interview-required next available appointments decreased from a 5-month wait to a 3-month wait compared with the October report. New Delhi also saw wait times for B-1/B-2 interview-required visas halved from 6.5 months to 3.5 months compared with the October report.

City/Post Interview required B-1/B-2 visas average wait times Interview required B-1/B-2 visas next available appointment Interview required F, M, J visas next available appointment Interview required petition-based H, L, O, P, Q visas next available appointment
Beijing N/A <0.5 months  <0.5 months 1.5 months
Chennai (Madras) N/A 3 months 2 months 1 month
Ciudad Juarez 7.5 months 16 months <0.5 months <0.5 months
Guatemala City 3 months 2.5 months N/A <0.5 months
Hermosillo 6.5 months 9 months <0.5 months <0.5 months
Ho Chi Minh City N/A <0.5 months <0.5 months <0.5 months
Hong Kong N/A <0.5 months N/A <0.5 months
Hyderabad 4 months 5 months 2.5 months 2 months
Mexico City 10 months 10 months N/A 1 month
New Delhi 3.5 months 10 months 0.5 months N/A
Shanghai N/A 3 months 1 month 3 months

The cities/posts with the longest average wait times for B-1/B-2 interview required visas are Toronto (16.5 months), San Jose (13 months), Lagos (12.5 months), Merida (11.5 months) and Ottawa (11 months).

Although wait times for next available appointments for petition-based work visas requiring an interview overall range from less than 0.5 months to 3 months, there are some outliers. Canada’s cities/posts had some of the longest average wait times for “interview-required petition-based next available appointments for work visas” (H, L, O, P, Q) for this report’s time period: Ottawa (4.5 months), Quebec (4.5 months) and Vancouver (4 months).

Additional Information: More details on the different visa categories referenced in the table can be found here. Wait times are calculated in months in 30-day increments and half-months in 15-day increments. Average wait times are provided for B-1/B-2 visas only in cases where the next available appointment is more than three months away.

Applicants are reminded that post-specific instructions are available on the website of the U.S. embassy or consulate where the applicant schedules their interview. Links to U.S. embassies and consulates can be found here. Applicants should be aware there may be limitations on how many times they can reschedule an appointment. Appointment calendar access for a specific post may not be accessible until the DS-160 visa application has been submitted and the required fee has been paid. (The fee is typically nontransferable across countries.)

Embassies and consulates may waive the in-person interview requirement for eligible applicants. Wait times for these appointments are not reflected in the visa wait timetables. Please check the individual U.S. embassy or consulate website to find out if a waiver of the in-person interview is available. Interview waiver eligibility was last updated on Sept. 18 and became effective Oct. 1.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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 announced inflationary adjustments to certain immigration-related fees mandated under the H.R. 1 Reconciliation Bill (H.R. 1), aka One Big Beautiful Bill Act, for fiscal year (FY) 2026. The Federal Register Notice (FRN) published today outlines the adjusted fees and their effective date on or after Jan. 1, 2026.

Key Points:

  • These changes are mandated by H.R. 1, which was signed into law on July 4, and reflect annual inflationary increases published in the July 22 FRN announcing the implementation of certain H.R. 1 immigration-related fees.
  • The new fee adjustments will apply to immigration benefit requests postmarked on or after Jan. 1, 2026.
  • Any filing submitted on or after this date without the correct fee will be rejected.
  • A complete list of the new fees increasing due to the FRN can be found here. Notable employer-related adjusted fee increases include but are not limited to:
    • Form I-765, Application for Employment Authorization – Initial Asylum Applicant Employment Authorization Document (EAD) (increased to $560)
    • Form I-765, Application for Employment Authorization – Initial Parole EAD (increased to $560)
    • Form I-765, Application for Employment Authorization – Renewal or Extension of Parole EAD (increased to $280)
    • Form I-765, Application for Employment Authorization – Initial Temporary Protected Status (TPS) EAD (increased to $560)
    • Form I-765, Application for Employment Authorization – Renewal or Extension of TPS EAD (increased to $280)
  • According to the USCIS announcement, the following form types will not be subject to a fee increase for FY 2026:
    • I-589 Asylum Fee (initial fee for aliens filing an application for asylum)
    • I-765 Renewal or Extension of Asylum Applicant EAD
    • I-360 Special Immigrant Juvenile Fee

Additional Information: BAL will continue to monitor related developments and provide updates as more details become available.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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.

Pursuant to a Nov. 12, 2025, ruling by a federal district court, while further litigation is pending, U.S. Citizenship and Immigration Services will accept certain EB-5 visa program fees that were in effect until March 31, 2024, emphasizing, “Petitioners and applicants should pay fees according to the ‘Current Fee’ schedule, not the higher ‘Previous Fee’ schedule.”

Key Points:

  • In Moody v. Noem, No. 24-cv-00762-CNS (D. Colo.), the United States District Court for the District of Colorado issued a decision on Nov. 12, 2025, preventing the Department of Homeland Security from adjusting certain EB-5 visa program fees codified in the 2024 fee rule.
  • Effective immediately, USCIS will accept certain EB-5 visa program fees listed in the “Current Fee” schedule with applicable forms and fees that can be found here.
  • USCIS will also accept payment of the “Previous Fee” for EB-5 program items postmarked Nov. 26, 2025, or earlier.
  • According to USCIS guidance, “For items postmarked after [Nov. 26, 2025], USCIS will reject petitions or applications that are accompanied by the ‘Previous Fee.’”
  • Requests should be submitted on the current version of the relevant form.

Additional Information: DHS and USCIS stated they “believe the Court’s decision is incorrect but are working to implement it.”

BAL will continue to monitor related developments and provide updates.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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.

Today, the Department of Homeland Security published a notice of proposed rulemaking (NPRM) in the Federal Register that proposes to “rescind the 2022 public charge ground of inadmissibility regulations.”

Key Points:

  • According to the NPRM, DHS aims to restore to immigration officers a “broader discretion to evaluate all pertinent facts” in their public charge determinations in adjustment of status adjudications.
  • DHS proposes to eliminate the 2022 rule, which it describes in the NPRM as “inconsistent with congressional intent” and “unduly restrictive.”
  • DHS states in the NPRM that the agency “intends, after the removal of these regulations, to formulate appropriate policy and interpretive tools that will guide public charge inadmissibility determinations while empowering officers to consider: (1) the mandatory statutory factors in section 212(a)(4)(B) of the INA … (2) all individualized case-specific factors and circumstances relevant to an alien’s case; and (3) any empirical data relevant to an alien’s self-sufficiency.”
  • In a summary of the Trump administration’s immigration policies for the year to date published on Nov. 13, 2025, in reference to the NPRM, USCIS states that foreign nationals “have the burden of proof in demonstrating that they are not likely at any time to become primarily dependent on the government for subsistence.”
  • The NPRM also addresses breach and cancellation procedures for public charge bonds under 8 CFR 103.6.
  • According to the NPRM, “DHS is not proposing to substantively change the collection of information related to the statutory minimum factors but will continue to request information in a manner that maximizes practical utility of the information collection and relevance to the totality of the circumstances analysis.”
  •  Public comments can be submitted here on or before Dec. 19, 2025.
  • The State Department has separately issued guidance to consular officers regarding public charge determinations but has not yet published guidance on the issue.

Additional Information: Under President Trump’s first administration, in 2019 DHS made sweeping changes to public charge inadmissibility determinations that were later vacated in court. Under the Biden administration, on Sept. 9, 2022, DHS published a final rule to codify pre-2019 guidance related to the “public charge” ground of inadmissibility.

Publication of the NPRM is the first step in the formal rulemaking process. Changes will not take effect until DHS issues a final regulation with a specified effective date. The agency is required to consider comments from the public in formulating the final rule. BAL will continue to monitor related developments and provide updates.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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 U.S. State Department has released the December 2025 Visa Bulletin. U.S. Citizenship and Immigration Services announced filings for employment-based visa preference categories must use the Dates for Filing chart in the December bulletin, which continues to show no movement across all EB visa categories, an expected outcome impacted by the government shutdown from Oct. 1 to Nov. 12, 2025.

The Dates for Filing chart indicates who is eligible to submit their application and supporting documents for further processing, even if the green card itself is not available. Review BAL’s employer’s guide to reading the Visa Bulletin to better understand this monthly report.

Dates for Filing chart category movement:

EB-1 visa

  • China EB-1 visa Dates for Filing remain the same, with a cutoff date of May 15, 2023.
  • India EB-1 visa Dates for Filing remain the same, with a cutoff date of April 15, 2023.
  • For all other countries under the EB-1 visa category, including Mexico and the Philippines, Dates for Filing will remain current.

EB-2 visa

  • China EB-2 visa Dates for Filing will remain the same, with a cutoff date of Dec. 1, 2021.
  • India EB-2 visa Dates for Filing will remain the same, with a cutoff date of Dec. 1, 2013.
  • For all other countries under the EB-2 visa category, including Mexico and the Philippines, Dates for Filing will remain the same, with a cutoff date of July 15, 2024.

EB-3 visa

  • China EB-3 visa Dates for Filing will remain the same, with a cutoff date of Jan. 1, 2022.
  • India EB-3 visa Dates for Filing will remain the same, with a cutoff date of Aug. 15, 2014.
  • For all other countries under the EB-3 visa category, including Mexico and the Philippines, Dates for Filing will remain the same, with a cutoff date of
  • July 1, 2023.

EB-5 visa (unreserved)

  • China EB-5 visa Dates for Filing will advance 21 days, with a cutoff date of July 22, 2016.
  • India EB-5 visa Dates for Filing will remain the same, with a cutoff date of April 1, 2022.

Dates for Filing Chart for Employment-Based Visa Applications

Preference Category All chargeability areas except those listed China – mainland born India Mexico Philippines
EB-1 visa Current May 15, 2023 April 15, 2023 Current Current
EB-2 visa July 15, 2024 Dec. 1, 2021 Dec. 1, 2013 July 15, 2024 July 15, 2024
EB-3 visa July 1, 2023 Jan. 1, 2022 Aug. 15, 2014 July 1, 2023 July 1, 2023
EB-5 visa (unreserved) Current July 22, 2016 April 1, 2022 Current Current

Additional Information: Final Action cutoff dates for issuance of an immigrant visa or approval of an adjustment of status application for the December Visa Bulletin can be found here.

Regarding when it will designate the use of either the Dates for Filing chart or the Final Action Dates chart per each monthly Visa Bulletin, USCIS states, “If USCIS determines there are more immigrant visas available for a fiscal year than there are known applicants for such visas, we will state on this page that you may use the Dates for Filing chart. Otherwise, we will indicate on this page that you must use the Final Action Dates chart to determine when you may file your adjustment of status application.

“However, if a particular immigrant visa category is ‘current’ on the Final Action Dates chart or the cutoff date on the Final Action Dates chart is later than the date on the Dates for Filing chart, applicants in that immigrant visa category may file using the Final Action Dates chart during that month.”

The State Department guidance on designating the Dates for Filing chart states, “The chart reflects dates for filing visa applications within a timeframe justifying immediate action in the application process. Applicants for immigrant visas who have a priority date earlier than the application date in the chart may assemble and submit required documents to the Department of State’s National Visa Center, following receipt of notification from the National Visa Center containing detailed instructions.

“The application date for an oversubscribed category is the priority date of the first applicant who cannot submit documentation to the National Visa Center for an immigrant visa. If a category is designated ‘current,’ all applicants in the relevant category may file, regardless of priority date. The ‘C’ listing indicates that the category is current, and that applications may be filed regardless of the applicant’s priority date. The listing of a date for any category indicates that only applicants with a priority date which is earlier than the listed date may file their application.”

Diversity Visa Lottery 2026 (DV-2026) and 2027 updates: The December Visa Bulletin provides DV-2026 program allocated cutoff numbers per region for December and January. It reports that certain regulatory amendments will “further reduce the DV-2026 annual limit to approximately 52,000. DVs are divided among six geographic regions. No one country can receive more than seven percent of the available diversity visas in any one year.”

According the Bulletin, “Entitlement to immigrant status in the DV category lasts only through the end of the fiscal (visa) year for which the applicant is selected in the lottery. The year of entitlement for all applicants registered for the DV-2026 program ends as of September 30, 2026.” DV-2026 Entrants are encouraged to keep their confirmation number until at least September 30, 2026.

Prior Bulletins have stated that “Dates for the DV-2027 program registration period will be widely publicized in the coming months. Those interested in entering the DV-2027 program should check the Department of State’s Diversity Visa web page in the coming months.”

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2025 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.