The Department of Labor (DOL) reported that as of March 18, a total of 5,910 cases were issued Final Decisions. Certified positions for this period were allocated for 110,641 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 767 17,028*
December 2024 1,566* 26,419*
January 2025 20* 140
February 2025 –** –**

*Indicates a change in the numbers previously reported by DOL for the month of the indicated filing window.

**As of COB March 18, there were no Final Decisions issued or Positions Certified, although there was a slight increase in both cases submitted and positions requested (five cases were submitted and the number of workers for positions requested was 81).

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.

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

As of March 18, a total of 4,181 cases were issued Final Decisions. Certified positions for this period were allocated for 59,747 workers.

DOL completed processing of the following groups who filed between Jan. 1-3:

  • Group A (1,943*** cases were issued a Final Decision with Positions Certified for 27,101*** workers)
  • Group B (1,032*** cases were issued a Final Decision with Positions Certified for 14,387*** workers)
  • Group C (835 cases were issued a Final Decision with Positions Certified for 12,847 workers)
  • Group D (371 cases were issued a Final Decision with Positions Certified for 5,412 workers).

DOL is still processing Groups E, F and G who filed between Jan. 1-3.

***Indicates a change in the numbers previously reported by DOL for this group.

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.

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U.S. Citizenship and Immigration Services listed updates that show only the Jan. 20 edition of certain forms will be accepted starting March 24 and designated dates thereafter.

Key Points:

Prior editions for all forms listed can be used until the respective date indicated above.

Additional Information: A complete list of form 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.

The Department of Labor’s Employment and Training Administration, Office of Foreign Labor Certification (OFLC), gave notice that record deletion from the Foreign Labor Application Gateway (FLAG) system starts at midnight on March 20.

Key Points:

  • The deletion of records within FLAG that are older than five years from the final determination date follows the approved National Archives and Records Administration (NARA) Record Control Schedule.
  • OFLC programs impacted by this implementation include:
    • Prevailing Wage Determinations (PWD)
    • Permanent Labor Certification Applications (PERM)
    • Temporary Labor Certification Applications (H-2A, H-2B and CW-1 visas)
    • Temporary Labor Condition Applications (H-1B, H-1B1 and E-3 visas)
  • To avoid losing important work authorization records, employers and stakeholders should download any cases older than five years from the FLAG system by March 19.

Additional Information: The legacy Permanent Online System that provided public access to permanent labor certification applications and final determinations was fully decommissioned on Dec. 1, 2024. The FLAG System was implemented in 2023 to replace the legacy Permanent Online System, improve customer service and modernize the administration of foreign labor certification programs.

The NARA Records Schedule provides mandatory disposition instructions for managing agency records. Records classified as “permanent” due to historical value are transferred to the National Archives of the United States at the end of their retention period. Under the NARA Records Schedule/Record Control Schedule, all other records are classified as “temporary” and destroyed.

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 April Visa Bulletin shows a major retrogression of more than two years in the EB-5 unreserved visa category preference for both China and India.

Key Points:

  • China retrogressed from July 15, 2016, to Jan. 22, 2014.
  • India retrogressed from Jan. 1, 2022, to Nov. 1, 2019.
  • The State Department noted that retrogression of the Final Action Dates was necessary to hold number use within the maximum allowed under the fiscal year 2025 annual limits after experiencing increased demand and number use in the EB-5 unreserved visa categories by applicants from China, India and across other countries. The EB-5 unreserved visa category applies to investments made in non-targeted employment areas or infrastructure, or made prior to the enactment of the EB-5 Reform and Integrity Act of 2022.
  • If the EB-5 unreserved visa category becomes oversubscribed, the State Department may establish a Final Action Date for applicants chargeable to all other countries.

Additional Information: In the other employment-based visa preference categories, India showed some advancement in the EB-1, EB-2 and EB-3 visa categories. China advanced in the EB-2 and EB-3 visa categories.

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 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.