U.S. Citizenship and Immigration Services made minor changes to Form I-9 to align with statutory language and updated the Department of Homeland Security Privacy Notice. E-Verify/E-Verify+ citizenship status selection updates took effect April 3. Multiple previous editions remain valid until their respective expiration dates.

I-9 Form updates

  • The revised Form I-9, Employment Eligibility Verification, with an edition date of 01/20/25 and an expiration date of 05/31/2027 is now available for download.
  • Multiple previous editions remain valid until their respective expiration dates. More information can be found on the USCIS “I-9 Central” website.
  • The fourth checkbox in Section 1 was renamed to “An alien authorized to work.”
  • Descriptions of two List B documents in the Lists of Acceptable Documents were revised.

E-Verify/E-Verify+ updates

  • The citizenship status selection during case creation was updated to “An alien authorized to work.”
  • Employers must select “An alien authorized to work” in E-Verify if the employee attests on Form I-9 as “A noncitizen authorized to work.”
  • E-Verify cases will display “An alien authorized to work,” while employees and employers may continue to see “A noncitizen authorized to work” on Form I-9, depending on the form edition being used.
  • E-Verify+ participants will see the updated 01/20/25 edition date and 05/31/2027 expiration date reflected in Form I-9NG.

Additional Information: More details on the updates 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.

U.S. Citizenship and Immigration Services posted notice of new procedures for individuals covered by Deferred Enforced Departure (DED) for Hong Kong to apply for employment authorization documents (EADs) valid through Feb. 5, 2027, and automatically extends EADs issued under the program through Feb. 5, 2027.

Key Points:

  • DED for covered Hong Kong residents automatically extends through Feb. 5, 2027.
  • The notice automatically extends through Feb. 5, 2027, the validity of DED-based EADs bearing a Category Code of A11 and a “Card Expires” date of Feb. 5, 2023, or Feb. 5, 2025.
  • Eligible Hong Kong residents can apply for an EAD by filing Form I-765, Application for Employment Authorization. EAD requests are adjudicated by the Department of Homeland Security on a case-by-case basis.
  • DHS may provide travel authorization at its discretion to those covered under DED. Those needing travel authorization must file Form I-131.

Additional Information: The Federal Register notice outlines the process for Hong Kong residents under DED to obtain EADs and automatically extends DED-based EADs as described above. Additional information can be found on the USCIS website. The DED follows a memorandum issued by the Biden administration on Jan. 15, 2025, determining it was in the foreign policy interest of the U.S. to expand and extend the deferral of removal of certain Hong Kong residents.

Before today, DHS had not issued a Federal Register notice implementing an extension of DED-based EADs. The agency had provided guidance on Feb. 18, 2025, that although DED was automatically extended, DED-based EADs for Hong Kong residents were not being extended.

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.

Pending further litigation, the 2023 Temporary Protected Status (TPS) designation for Venezuela will remain in effect in compliance with a U.S. District Court order, and the validity of employment authorization documents (EADs) with certain “Card Expires” dates have been extended through April 2, 2026.

Key Points:

  • On March 31, 2025, the United States District Court for the Northern District of California ordered the postponement of the vacatur and termination of the 2023 TPS designation for Venezuela, leaving this TPS designation in effect pending further litigation.
  • The Department of Homeland Security confirmed on April 2, 2025, that the agency will revert to the Federal Register notice that was published on Jan. 17, 2025, which provides further guidance. U.S. Citizenship and Immigration Services also posted an alert with Form I-9 instructions.
  • Under the terms of the Jan. 17 notice, which are now in effect, the validity of EADs with “Card Expires” dates of Sept. 10, 2025; April 2, 2025; March 10, 2024; or Sept. 9, 2022, issued under the Venezuela TPS designations are extended through April 2, 2026, pending further litigation. The USCIS guidance states employers must reverify those employees before they start work on April 3, 2026.

Additional Information: Government updates regarding the program will be posted on the TPS page for Venezuela. USCIS guidance for completing the Form I-9 can be found here. BAL continues to monitor this litigation and related cases.

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.

Last week, U.S. Citizenship and Immigration Services announced that the H-2B visa cap was reached for the remainder of fiscal year (FY) 2025. The Department of Homeland Security and the Department of Labor jointly published a temporary final rule on Dec. 2, 2024, increasing the numerical limit (or cap) on H-2B nonimmigrant visas by up to 64,716 additional visas for all of FY 2025. Of the 64,716 supplemental visas, 44,716 are available only for certain returning workers.

The breakdown of the H-2B supplemental visas for spring and summer is as follows:

For the early second half of FY 2025 (April 1 through May 14)

  • There were 19,000 visas limited to returning workers who were issued H-2B visas or held H-2B status in FY 2022, 2023 or 2024, regardless of country or nationality.
  • These early second half of FY 2025 petitions must have requested employment start dates from April 1, 2025, through May 14, 2025.
  • Employers were required to file these petitions no earlier than March 20, 2025 (15 days after the second half statutory cap was reached).

For the late second half of FY 2025 (May 15 through Sept. 30)

  • There were 5,000 visas limited to returning workers who were issued H-2B visas or held H-2B status in FY 2022, 2023 or 2024, regardless of country of nationality.
  • These late second half of FY 2025 petitions must request employment start dates from May 15, 2025, through Sept. 30, 2025.
  • Employers must file these petitions no earlier than April 21, 2025 (45 days after the second half statutory cap was reached).

For the entirety of FY 2025

  • There were 20,000 visas reserved for nationals of Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Haiti and Honduras (country-specific allocations by law), attested by each petitioner regardless of whether those nationals are returning workers.
  • Employers who requested an employment start date in the first half of FY 2025 (on or before March 31, 2025) must have filed their petitions immediately on or after Dec. 2, 2024.
  • Employers requesting an employment start date in the second half of FY 2025 (on or after April 1, 2025) must file their petitions no earlier than March 20, 2025 (15 days after the second half statutory cap is reached).

More information on the allocation of supplemental visas 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.

U.S. Citizenship and Immigration Services announced it is updating its policy manual to recognize only two biological sexes, male and female.

Key Points:

  • The policy update and guidance is consistent with the executive order issued Jan. 20, 2025.
  • Under this guidance, USCIS considers a person’s sex as that which is generally evidenced on the birth certificate issued at or nearest to the time of birth. Secondary evidence will be used if sex at birth is indicated other than male or female.
  • This policy update and guidance is effective immediately and applies to benefit requests pending or filed on or after April 2, 2025.

Additional Information: While benefits won’t be denied solely for incorrect sex indication, delays may occur if the sex indicated differs from the birth certificate. The formal policy alert can be read 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.

U.S. Citizenship and Immigration Services announced it has received enough registrations to meet the fiscal year (FY) 2026 H-1B cap, including the advanced degree exemption.

Key Points:

  • All prospective petitioners with selected beneficiaries have been notified that they are eligible to file H-1B cap-subject petitions for their beneficiaries starting April 1, 2025.
  • Only petitioners with registrations for selected beneficiaries may file H-1B cap-subject petitions for FY 2026.
  • Petitioners must include a copy of the selection notice and evidence of the beneficiary’s valid passport.
  • The filing period for H-1B cap-subject petitions will be at least 90 days.

Additional Information: USCIS randomly selected enough beneficiaries to reach the H-1B cap. An H-1B cap-subject petition must be properly filed at the correct filing location or online at my.uscis.gov and within the filing period indicated on the relevant selection notice. Petitioners filing for selected beneficiaries based on their valid registration must still submit evidence or otherwise establish eligibility for petition approval, as registration and selection only pertains to eligibility to file the H-1B cap-subject petition.

More details on the H-1B electronic registration process 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 Handbook for Employers M-274 (also known as the Form I-9 employer handbook) has been updated to reflect the final rule changing the automatic extension end date to April 1 of the applicable fiscal year for F-1 visa students requesting H-1B visa status.

Key Points:

  • Section 7.4.2 of the handbook was updated to reflect the final rule automatically extending the duration of status and any employment authorization for an F-1 student who is the beneficiary of an H-1B visa petition requesting a change of status.
  • Under the final rule, the automatic extension end date was changed from Oct. 1 to April 1 of the fiscal year in which the H-1B status is being requested (or until the validity start date of the approved petition, whichever is earlier).

Additional Information: The final rule modernizing the H-1B visa program was published by the Department of Homeland Security on Dec. 18, 2024. Additional Form I-9 guidance for F-1 students 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 Department of Homeland Security provided notice that the recent designation of Romania into the Visa Waiver Program (VWP) is under review and that implementation of the Electronic System for Travel Authorization (ESTA) for Romanian citizens will remain paused until the review is completed.

Key Points:

  • The ESTA pause for Romanian citizens will remain in effect until the VWP review is completed.
  • Romanians traveling for short-term business or tourism should apply for the appropriate nonimmigrant “B” visas at U.S. embassies or consulates.

Additional Information: The VWP, managed by DHS and the State Department, allows citizens of designated countries to visit the U.S. for business or tourism for up to 90 days without a visa. In exchange, these countries must permit U.S. citizens to travel to their countries under similar conditions. The program enhances security through rigorous vetting and cooperation in counterterrorism, law enforcement and immigration enforcement. The current review of Romania’s VWP designation aims to ensure compliance with these security requirements, temporarily halting ESTA for Romanian citizens until the review is complete.

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 it received enough petitions to meet the H-2B visa cap for the second half of fiscal year (FY) 2025 and that eligible petitions for supplemental visas must be received by Sept. 15, 2025.

Key Points:

  • The H-2B visa cap for the first half of FY 2025 was reached in January.
  • March 5, 2025, was the final receipt date for new cap-subject H-2B petitions for the second half of FY 2025. Any new cap-subject H-2B petitions received after March 5, 2025, will be rejected.
  • To qualify for the 64,716 supplemental visas, petitions must be received at the filing location designated at the time of filing, which is currently the Texas Service Center, by Sept. 15, 2025.

Additional Information: On Dec. 2, 2024, the Department of Homeland Security and the Department of Labor jointly published a temporary final rule increasing the numerical limit (or cap) on H-2B nonimmigrant visas by up to 64,716 additional visas for all of FY 2025. Supplemental visas are available only to U.S. businesses that are suffering irreparable harm or will suffer impending irreparable harm without the ability to employ all the H-2B workers requested in their petition. Of the 64,716 additional visas, 44,716 are available only for certain returning workers. The remaining 20,000 visas are set aside for nationals of Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Haiti and Honduras who are exempt from the returning worker requirement.

Refer to the Temporary Increase in H-2B Nonimmigrant Visas for FY 2025 page for more details, including who can petition for supplemental visas and other filing information.

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 announced the termination of the 2022 and 2023 categorical parole programs for Cuba, Haiti, Nicaragua and Venezuela (referred to as “CHNV parole programs”). DHS is expected to publish a Federal Register notice March 25 to terminate these programs effective April 24.

Key Points:

  • The Biden administration established the temporary parole program for Venezuelan nationals in 2022 in an effort to discourage irregular border crossings, and then expanded the program in 2023 to include Cuban, Haitian and Nicaraguan nationals. In October 2024, DHS announced it would not extend the CHNV parole programs.
  • President Trump directed the immigration agencies to terminate categorical parole programs in a Jan. 20 executive order.
  • DHS has now determined that these programs “do not serve a significant public benefit, are not necessary to reduce levels of illegal immigration, did not sufficiently mitigate the domestic effects of illegal immigration, are not serving their intended purposes and are inconsistent with the [current] administration’s foreign policy goals.”
  • DHS indicated it expects parolees without a lawful basis to remain in the United States following the termination of these programs to depart the country by the termination date of April 24.

Additional Information: The termination of the CHNV parole programs is anticipated to impact approximately 530,000 Cuban, Haitian, Nicaraguan and Venezuelan nationals. The Trump administration’s actions to suspend categorical parole programs are currently under litigation, and this termination will likely face similar legal challenges.

In terms of enforcement, the register states that “DHS generally intends to remove promptly aliens who entered the United States under the CHNV parole programs who do not depart the United States before their parole termination date and do not have any lawful basis to remain in the United States. DHS retains its discretion to commence enforcement action against any alien at any time, including during the 30-day waiting period created by this notice.”

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.