U.S. Citizenship and Immigration Services announced a new “alien registration” process as part of implementation of an executive order issued by President Trump in January. The interim final rule (IFR) was published in the Federal Register on March 12 and is open to public comment for 30 days (through April 11).

Key Points:

  • Many noncitizens are already registered, including individuals who have been granted or applied for lawful permanent residence, received a Form I-94 when arriving in the U.S., were issued an Employment Authorization Document (EAD), or were issued a nonimmigrant or immigrant visa prior to their most recent arrival in the U.S.
  • The complete registration requirements, including who has already been registered, can be found here.
  • The policy requires that non-U.S. citizens aged 14 and older must register with USCIS, provide fingerprints and list their current address. Parents or guardians are also responsible for registering children in this category under 14.
  • The IFR states that all unregistered noncitizens in the United States, including previously registered children who turn 14, are legally required to comply with these registration requirements.
  • The revised form “Biographic Information (Registration)” is accessible through myUSCIS. Instructions on how to complete the form can be found here.
  • Failure to comply with these requirements may result in civil and criminal penalties, including fines and potential imprisonment.
  • Registration does not confer immigration status, work authorization or any other benefit under the Immigration and Nationality Act (INA) or U.S. law.
  • The IFR is scheduled to become effective April 11. Public comments can be submitted here through that date.

Additional Information: President Trump’s executive order directs the Department of Homeland Security to enforce compliance with alien registration requirements under Section 262 of the INA (8 U.S.C. 1302). Most noncitizens in the United States have already registered. However, a significant number in the United States have had no direct way in which to register and meet their obligation under INA 262.

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 announced that the Centers for Disease Control and Prevention provided updated guidance to panel physicians removing the requirement that immigrant visa applicants receive the COVID-19 vaccination, effective March 11.

Key Points:

  • Panel physicians will no longer determine that an immigrant visa applicant is ineligible for travel based on their failure to receive, or otherwise document, their vaccination against COVID-19.
  • U.S. embassies and consulates will no longer refuse an immigrant visa application for failure to present COVID-19 vaccination documentation.
  • Applicants with unexpired medical exams still valid for travel to the U.S. and who were previously found ineligible based solely on a failure to establish a valid record of COVID-19 vaccination may have a new medical exam issued by a panel physician without a fee.

Additional Information: Panel physicians are doctors appointed by the State Department to perform exams and certain verifications at U.S. embassies and consulates. Applicants impacted by the new guidance can reach out to the U.S. embassy or consulate at which they executed their application for an immigrant 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 U.S. State Department released the April Visa Bulletin. U.S. Citizenship and Immigration Services announced filings for employment-based visa preference categories must use the Final Action Dates chart, which shows advancement across all 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 advance from Feb. 1, 2022, to 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 from May 8, 2020, to Oct. 1, 2020.
  • India EB-2 visa Final Action Dates will advance from Dec. 1, 2012, to Jan. 1, 2013.
  • For all other countries under the EB-2 visa category, including Mexico and the Philippines, Final Action Dates will advance from May 15, 2023, to June 22, 2023.

EB-3 visa

  • China EB-3 visa Final Action Dates will advance from Aug. 1, 2020, to Nov. 1, 2020.
  • India EB-3 visa Final Action Dates will advance from Feb. 1, 2013, to April 1, 2013.
  • For all other countries under the EB-3 visa category, including Mexico and the Philippines, Final Action Dates will advance from Dec. 1, 2022, to Jan. 1, 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 June 22, 2023 Oct. 1, 2020 Jan. 1, 2013 June 22, 2023 June 22, 2023
EB-3 visa Jan. 1, 2023 Nov. 1, 2020 April 1, 2013 Jan. 1, 2023 Jan. 1, 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.

On Monday, the U.S. Senate confirmed Lori Chavez-DeRemer as the new U.S. Secretary of Labor.

Key Points:

  • The Senate confirmed Chavez-DeRemer with a majority vote of 67–32.
  • In 2022, Chavez-DeRemer was elected to the U.S. House of Representatives for Oregon’s 5th Congressional District and served on the Agriculture, Education and Workforce, and Transportation and Infrastructure Committees.
  • Bills she sponsored or co-sponsored while serving in Congress include, but are not limited to, the Civil Rights Protection Act of 2024, Rights for the TSA Workforce Act of 2024, Nurse Faculty Shortage Reduction Act of 2024 and the College Cost Reduction Act.

Additional Information: The U.S. Secretary of Labor is a Presidential Cabinet role that oversees the U.S. Department of Labor (DOL) and its 25 agencies in advancing its mission “to foster, promote and develop the welfare of the wage earners, job seekers and retirees of the United States; improve working conditions; advance opportunities for profitable employment; and assure work-related benefits and rights.”

DOL budgets, policies and performance reports can be found 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.

The Labor Department has posted updated processing times for permanent labor certification (PERM) applications and prevailing wage determination (PWD) requests.

PERM Processing Times: As of March 1, the department was still adjudicating PERM applications filed in November 2023 and earlier and reviewing appeals for reconsideration filed in January 2025 and earlier.

Average Number of Days to Process PERM Applications

Determinations Month Calendar Days
Analyst Review February 2025 497
Audit Review N/A N/A

PWD Processing Times: As of March 1, the National Prevailing Wage Center has processed most of the PWD requests filed in August and September 2024 and earlier for H-1B visa Occupational Employment and Wage Statistics (OEWS) and non-OEWS cases, and for PERM OEWS cases and non-OEWS cases.

Redeterminations were being considered on appeals filed in November 2024 and earlier for both H-1B visa cases and PERM cases.

Center Director Reviews were being conducted for both H-1B visa cases and PERM cases filed in August 2024 and earlier.

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 notices in the Federal Register that public comments are open or have been extended for certain new proposals and revisions to information collection processes pertaining to immigration forms and medical records.

Key Points:

Additional Information: To submit a comment on any of the above proposals, click on the green “Submit a Public Comment” tab located in the top right section of each of the respective Federal Register notice pages linked above.

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, President Trump’s executive order (EO) designating English the official U.S. language was officially published in the Federal Register, stating agencies can still provide existing multilingual services.

Key Points:

  • EO 14224, signed on March 1, establishes English as the official language of the United States.
  • The EO encourages new citizens to learn English to participate fully in society.
  • Although it revokes any policy guidance issued under EO 13166 from 2000 — “Improving Access to Services for Persons With Limited English Proficiency” — it does not require government agencies to discontinue multilingual services.
  • U.S. Citizenship and Immigration Services currently offers an online Multilingual Resource Center that provides information on a variety of immigrant- and nonimmigrant-related topics, including work authorization such as employee verification, specific form instructions, green cards, options for nonimmigrant STEM professionals to work in the U.S. and more.

Additional Information: Regarding agency discretion on services provided, Section 3(b) of the EO states “nothing in this order, however, requires or directs any change in the services provided by any agency. Agency heads should make decisions as they deem necessary to fulfill their respective agencies’ mission and efficiently provide Government services to the American people. Agency heads are not required to amend, remove, or otherwise stop production of documents, products, or other services prepared or offered in languages other than English.”

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 Labor (DOL) reported that as of Feb. 27, 2025, a total of 5,899 cases were issued Final Decision for fiscal year (FY) 2025 (first half of the visa cap) with a Requested Date of Need from Oct. 1, 2024, through March 31, 2025. Certified positions for this period were allocated for 110,297 workers.

The chart below indicates the number of Final Decisions issued and Positions Certified for filing windows from July 2024 to February 2025:

Filing window Total cases issued

Final Decision

Total worker Positions Certified
July 2024 2,492 44,907
August 2024 485 7,884
September 2024 221* 3,849
October 2024 359 10,414
November 2024 766* 16,988
December 2024 1,559* 26,165*
January 2025 18* 140*
February 2025 –** –**

*Indicates a change in November– January case and worker numbers from those reported as of Feb. 13.

**As of COB Feb. 27, there were no Final Decisions issued or Positions Certified, although six cases were submitted and there were positions requested for 83 workers.

As of Jan. 7, 2025, U.S. Citizenship and Immigration Services received enough petitions to reach the additional 20,716 H-2B visas made available for returning workers for the first half of FY 2025 with start dates on or before March 31, 2025.

For FY 2025 second half of the visa cap, DOL processing of Group A increased to 1,855 total cases issued a Final Decision and Positions Certified for 26,279 workers. Group B increased to 773 total cases issued a Final Decision and Positions Certified for 11,046 workers.

DOL is still processing Groups C–G for applications received for Requested Date of Need from April 1, 2025.

Background on Assignment Groups: The initial H-2B Assignment Group (i.e., Group A) will always include the number of H-2B applications containing a sufficient amount of worker positions to reach the applicable numerical visa cap, even if the numerical limits of the Immigration and Nationality Act are subsequently changed. Additional Assignment Groups are assigned in ascending sequential order for all remaining H-2B applications that were filed during the initial three-day filing window that requested the earliest start date of work permitted. Each H-2B Assignment Group after Group A (e.g., Group B, Group C, etc.) will total no more than 20,000 worker positions, or roughly 1,000 applications per group. More background on H-2B Temporary Labor Certification Program and the origin of Assignment Groups can be found 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.

In February, U.S. Citizenship and Immigration Services announced that the initial registration period for the fiscal year (FY) 2026 H-1B cap will open at noon Eastern on March 7 and run through noon Eastern on March 24, 2025.

Key Points:

  • Prospective petitioners and representatives must register each beneficiary electronically for the selection process and pay the associated $215 H-1B registration fee for each beneficiary using a USCIS online account.
  • As previously reported, H-1B petitioning employers who had an H-1B registrant account for the FY 2021 – FY 2024 H-1B registration seasons, but did not use the account for FY 2025, will have their existing account converted to an organizational account after their next login.
  • An H-1B cap-subject petition, including a petition for a beneficiary who is eligible for the advanced degree exemption, may only be filed by a petitioner whose registration for the beneficiary named in the H-1B petition was selected in the H-1B registration process.
  • If USCIS receives registrations for enough unique beneficiaries by March 24, they will randomly select unique beneficiaries and send selection notifications to users’ USCIS online accounts (and employers’ organizational accounts). Notifications to prospective petitioners and representatives whose accounts have at least one registration selected are anticipated to be sent by March 31.
  • If USCIS does not receive registrations for enough unique beneficiaries, all registrations for unique beneficiaries that were properly submitted in the initial registration period will be selected. Further details regarding the registration period can be found here.

Additional Information: Tutorials and FAQ on creating organizational accounts can be found 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.

The State Department announced that it has issued all EB-4 immigrant visas for fiscal year (FY) 2025.

Key Points:

  • All visas available in the Employment-Based Fourth Preference (EB-4) category for FY 2025 have been issued.
  • The Immigration and Nationality Act limits the number of EB-4 visas issued annually to 7.1% of the worldwide employment limit.
  • Embassies and consulates cannot issue further EB-4 visas until the start of FY 2026 on Oct. 1, 2025, when the annual limits reset.

Additional Information: EB-4 visas allow a wide variety of special immigrants, including religious workers, special immigrant juveniles, certain U.S. government employees, certain international organization retirees and certain international broadcasting employees, among others, to legally reside and work 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.