The Office of Foreign Labor Certification (OFLC) recently announced solicitation of input for the annual determination of labor supply states (LSS) to enhance U.S. worker recruitment under the 2022 H-2A Final Rule.

Key Points:

  • The 2022 H-2A Final Rule (which became effective on Nov. 14, 2022) implemented a new process for the OFLC Administrator’s determination of LSS, which are additional states where an employer’s job order will be circulated and, if appropriate, where additional positive recruitment may be required of the employer.
  • The OFLC Administrator is soliciting public input about LSS and related recruitment mechanisms to make a determination that identifies whether there are areas of traditional or expected labor supply for each state with respect to the availability of qualified workers and the appropriate and effective means of recruiting those workers.
  • The determination can include specific geographic area(s) of the United States in which a significant number of qualified workers have been identified and who, if recruited through additional positive employer recruitment activities, would be willing to make themselves available for work in the state.
  • The OFLC Administrator requests information from the public regarding the availability of qualified workers and the appropriate, effective methods of contacting those workers.
  • OFLC will only consider electronic submissions to the email address H2ALaborSupply@dol.gov for making determinations as to LSS. Any submissions sent through the mail or other correspondence will not be accepted.
  • The solicitation period will be open for a period of 60 days through July 21, 2025.

Additional Information: The OFLC Administrator will also consider data and information about labor flow trends from the public to inform a determination regarding expanded interstate circulation of H-2A job orders by State Workforce Agencies on behalf of employers. These determinations are important for ensuring that agricultural job opportunities are more broadly available to qualified workers in the United States.

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 Office of Foreign Labor Certification (OFLC) recently announced it will permanently delete records for which a final determination was made more than five years ago from the decommissioned legacy Permanent Online System.

Key Points:

  • The system was officially decommissioned on Dec. 1, 2024.
  • Once the system was decommissioned, the records housed in it were no longer directly available to the public.
  • Case records for which a final determination was issued more than five years ago will be permanently deleted. These deletions will occur on a rolling basis as part of routine records management procedures.
  • OFLC will begin deleting records from the system to comply with its records disposition schedule, approved by the National Archives and Records Administration, effective July 1, 2025.

Additional Information: The FLAG System was implemented to replace the legacy Permanent Online System, improve customer service and modernize the administration of foreign labor certification programs. Employers and their representatives who wish to obtain any records from the legacy Permanent Online System must submit a Freedom of Information Act (FOIA) request no later than June 5, 2025. After this date, affected records will no longer be retrievable.

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. Customs and Border Protection (CBP) continues to roll out airport modernization enhancements to support the expected increase in international travel, including Enhanced Passenger Processing (EPP) and Seamless Border Entry (SBE) at certain U.S. airports.

Key Points:

  • CBP processed over 420 million travelers at ports of entry in fiscal year 2024, a 6.6% increase from the previous year.
  • EPP involves photographing travelers using auto-capture technology to provide a complete customs assessment (biometric confirmation, eligibility, enforcement) before they reach a CBP officer.
    • Currently, EPP is available to U.S. citizens at certain U.S. airports, including Orlando International Airport, Dallas Fort Worth International Airport, Denver International Airport, Charlotte Douglas International Airport, Seattle-Tacoma International Airport, Cross Border Xpress, Chicago O’Hare International Airport, Los Angeles International Airport, Hartsfield-Jackson Atlanta International Airport and Dublin Airport.
  • SBE combines the Department of Homeland Security’s Trusted Traveler Programs (TTP) framework with “On the Move” technology allowing Trusted Traveler Global Entry members to move through the inspection process with minimal interaction with a CBP officer (depending on officer discretion).
    • Currently, SBE is available at certain airports, including Los Angeles International Airport, Miami International Airport, Washington Dulles International Airport, Chicago O’Hare International Airport, Newark Liberty International Airport, George Bush Intercontinental Airport and Toronto Pearson International Airport.
  • CBP travel programs with mobile applications to help facilitate travel to the U.S. include:
    • The Global Entry program allows travelers to complete their entry processing on their phones before leaving the aircraft.
    • The NEXUS program expedites processing for prescreened travelers from Canada to the U.S.
    • The Mobile Passport Control program is intended for non-TTP members who are U.S. citizens, lawful permanent residents, certain Canadian citizens and Visa Waiver Program travelers to submit their passport and travel information in advance.
    • The Electronic System for Travel Authorization (ESTA) program allows non-U.S. citizens eligible to enter under the Visa Waiver Program the option of using the app to submit ESTA applications from their smart devices.

Additional Information: All CBP mobile apps are free and available through the Google Play Store and Apple App Store, or by visiting the CBP Mobile Apps Directory.

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.

Update on applications received for requested date of need from Oct. 1, 2024, through March 31, 2025 (fiscal year (FY) 2025 first half of the visa cap):

The Department of Labor (DOL) reported that as of May 17, a total of 5,944 cases were issued Final Decisions. Certified positions for this period were allocated for 111,019 workers.

In April, U.S. Citizenship and Immigration Services reached the additional H-2B visa cap made for returning workers for the early second half of FY 2025 with start dates from April 1 to May 14, 2025.

Update on applications received for requested date of need from April 1, 2025 (FY 2025 second half of the visa cap):

As of May 17, a total of 8,501 cases were issued Final Decisions. Certified positions for this period were allocated for 116,602 workers.

Additional Information: On May 15, the Office of Foreign Labor Certification published an updated Foreign Labor Recruiter List of names for the H-2B program as required by Temporary Employment of Foreign Workers in the United States federal regulations and to help ensure greater transparency the for the H-2B worker recruitment process and facilitate the interagency exchange of information within the U.S. government.

The list contains the name and location of persons or entities identified on Appendix C of Form ETA-9142B that were hired by, planning to engage or work on behalf of employers in the recruitment of prospective H-2B workers to perform the work described on their H-2B application and includes only those names and locations associated with H-2B applications that were processed or issued a Final Decision from Oct. 1, 2023, through March 31, 2025.

The H-2B Foreign Labor Recruiter List for Q2 FY 2025 can be downloaded here.

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.

Twelve BAL attorneys are named in the 2025 Lawdragon 100 Leading Immigration Lawyers list. The list recognizes lawyers who make a significant impact, specifically regarding recent matters handled and cutting-edge litigation, as well as those who are consistently turned to for guidance in trending immigration issues.

“It’s always an honor to be recognized by a prestigious publication like Lawdragon,” said Frieda Garcia, Managing Partner at BAL. “It’s even more rewarding to see so many BAL attorneys on the list. Our team strives to do impactful work in immigration law every day, and this recognition helps celebrate that effort.”

The following BAL attorneys were honored by Lawdragon this year:

In addition, Partner Emeritus Jeff Appleman was named to the Lawdragon Hall of Fame, recognizing outstanding lawyers who have made a remarkable contribution to the profession.

The full list of 2025 Lawdragon 100 Leading Immigration Lawyers can be viewed here.

U.S. Citizenship and Immigration Services alerted employers of a recent E-Verify technical issue with Social Security Administration and Department of Homeland Security mismatch cases. The agency urges employers to take action to resolve the issue.

Key Points:

  • The technical issue involves tentative SSA mismatch cases that were referred between April 9 and May 5, 2025, and dual SSA and DHS mismatches if the employee attempted to resolve the issue with SSA but not DHS.
  • Due to the system error, some of these cases may have incorrectly received a final nonconfirmation.
  • Employers are required to create a new E-Verify case for any cases that received a final nonconfirmation after a mismatch for cases referred from April 9 to May 5, 2025.
  • No further action is needed if the employer has already created a new E-Verify case and received an Employment Authorized result for an affected employee.

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 provided updates on the fiscal year (FY) 2026 H-1B cap process, noting a significant decrease in the total number of registrations submitted and eligible beneficiaries compared to FY 2025.

Key Points:

  • In March, USCIS received enough initial registrations to meet the FY 2026 H-1B cap, including the advanced degree exemption (master’s cap), selecting 118,660 unique beneficiaries and resulting in 120,141 selected registrations.
  • During the initial registration period there was a significant decrease in the total number of registrations submitted and eligible beneficiaries compared to FY 2025, including a decrease in the number of registrations submitted on behalf of beneficiaries with multiple registrations. Additional registration analysis found:
    • The number of unique employers for FY 2026 (approximately 57,600) was comparable to the number last year for FY 2025 (approximately 52,700).
    • The number of eligible unique beneficiaries for FY 2026 (approximately 339,000) was significantly lower than the number last year for FY 2025 (approximately 442,000).
    • The number of eligible registrations was also dramatically lower for FY 2026 (343,981) compared with FY 2025 (470,342) — a 26.9% reduction.
  • On average, each beneficiary only had approximately one registration submitted on their behalf, with an average of 1.01 registrations per beneficiary for FY 2026, compared to 1.06 for FY 2025.

Additional Information: The chart below shows registration and selection numbers for FYs 2021–26:

Cap Fiscal Year Total Registrations Eligible Registrations Eligible Registrations for Beneficiaries with No Other Eligible Registrations Eligible Registrations for Beneficiaries with Multiple Eligible Registrations Selected Registrations
2021 274,237 269,424 241,299 28,125 124,415
2022 308,613 301,447 211,304 90,143 131,924
2023 483,927 474,421 309,241 165,180 127,600
2024 780,884 758,994 350,103 408,891 188,400
2025 479,953 470,342 423,028 47,314 135,137
2026 358,737 343,981 336,153 7,828 120,141

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 recently noted a change to the Foreign Affairs Manual (FAM) clarifying that certain match officials can travel to the U.S. on a B-1 business visa or Electronic System for Travel Authorization (ESTA).

Key Points:

  • The FAM was “revised to add participants in international sporting events for visa processing” on April 14, 2025, in advance of FIFA World Cup 2026, the 2028 Olympic and Paralympic Games and other sporting events.
  • The policy manual now clarifies that certain referees, judges and technical officials may be issued a B-1 visa if they have been hired to serve in their officiate capacity at a sporting event with an international dimension.
  • Eligible match officials may also use ESTA to facilitate their travel to the U.S.

Additional Information: The new policy language falls under 9 FAM 402.2-5 (C)(10) (U) Participants in International Sporting Events (CT:VISA-2145; 04-14-2025) and reads:

Referees, Judges and Technical Officials: A referee, judge, or technical official may be issued a B-1 visa if the applicant has been hired subject to a selection process to referee, judge, oversee, or officiate a sporting event with an international dimension (such as FIFA World Cup or the Olympics). Technical officials are responsible for applying the rules or regulations of individual sports to make judgments on performance, ranking, time or rule infringement, and ensure that all athletes can compete fairly (for example, timekeepers, weigh-in officials, starters, lane inspectors, and stroke and turn officials). Such aliens may not receive a salary or payment for services from a U.S. source, other than remuneration for incidental expenses.

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 Labor Department posted the latest processing times for permanent labor certification (PERM) applications a week after it posted April 30 updates. As of May 8, the department was adjudicating PERM applications filed in January 2024 and earlier and reviewing appeals for reconsideration filed in March 2025 and earlier.

These dates reflect the month and year in which cases were filed and are currently being adjudicated. The Reconsideration Request date for reviewing appeals reflects the month and year in which cases that are currently being reviewed were appealed. For various reasons, the Office of Foreign Labor Certification (OFLC) may be completing the processing of applications filed prior to the month posted.

Average Number of Days to Process PERM Applications

Determinations Month Calendar Days
Analyst Review April 2025 499
Audit Review N/A N/A

These dates reflect the amount of time to process applications. Actual processing times for each employer’s PERM application may vary from the average depending on material facts and individual circumstances of the case. OFLC is reporting the average processing time for all PERM applications for the most recent month.

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 released the June Visa Bulletin. U.S. Citizenship and Immigration Services announced filings for employment-based visa preference categories must use the Final Action Dates chart. India dates remain the same and China shows slight advancement in EB-2 and EB-3 visa categories.

Final Action Dates:

EB-1 visa

  • China EB-1 visa Final Action Dates will remain the same (Nov. 8, 2022).
  • India EB-1 visa Final Action Dates will remain the same (Feb. 15, 2022).
  • For all other countries under the EB-1 visa category, including Mexico and the Philippines, Final Action Dates will remain current.

EB-2 visa

  • China EB-2 visa Final Action Dates will advance two months to Dec. 1, 2020.
  • India EB-2 visa Final Action Dates will remain the same (Jan. 1, 2013).
  • For all other countries under the EB-2 visa category, including Mexico and the Philippines, Final Action Dates will advance nearly four months to Oct. 15, 2023.

EB-3 visa

  • China EB-3 visa Final Action Dates will advance 21 days to Nov. 22, 2020.
  • India EB-3 visa Final Action Dates will remain the same (April 15, 2013).
  • For all other countries under the EB-3 visa category, including Mexico and the Philippines, Final Action Dates will advance slightly over one month to Feb. 8, 2023.

Final Action Dates Chart for Employment-Based Visa Applications

Preference Category All chargeability areas except those listed China India Mexico Philippines
EB-1 visa Current Nov. 8, 2022 Feb. 15, 2022 Current Current
EB-2 visa Oct. 15, 2023 Dec. 1, 2020 Jan. 1, 2013 Oct. 15, 2023 Oct. 15, 2023
EB-3 visa Feb. 8, 2023 Nov. 22, 2020 April 15, 2013 Feb. 8, 2023 Feb. 8, 2023

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.