• DOS Announces Expansion of Visa Restriction Policy for Individuals Exploiting Cuban Labor
• DHS Partially Vacates Haitian TPS Notice, Reduces Extension and Redesignation Period
• DOS Rescinds Previous Expansion of Interview Waiver Policy
• USCIS I-485 Form Update
• March Visa Bulletin Announces Retrogression of EB-4 Category, Religious Workers Expiration
• DOS Releases Employer Guidance on I-9 Reverification Process for Venezuelan TPS Beneficiaries
• FY 2026 H-1B Cap Initial Registration Period Opens March 7
• DOS Requests Public Comments on Passport Application Changes; Lawsuit Filed
• President Trump Calls for Resettlement of White South Africans in the United States

DOS Announces Expansion of Visa Restriction Policy for Individuals Exploiting Cuban Labor

On February 25, 2025, the U.S. Department of State (DOS) expanded its Cuba-related visa restrictions to target individuals linked to Cuba’s labor export program, particularly its overseas medical missions. The policy applies to current and former Cuban government officials, foreign government officials involved in the program, and their immediate family members.

Secretary of State Marco Rubio stated that Cuba’s labor export system, including medical missions, constitutes forced labor, enriching the regime while depriving Cubans of essential medical care. The U.S. aims to hold those responsible accountable and curb the exploitation of Cuban workers abroad.

Impact: This expanded visa restriction policy could affect multinational organizations, healthcare institutions, and government agencies engaging with Cuban professionals. HR and global mobility teams should reassess hiring and mobility strategies to ensure compliance with evolving U.S. regulations. Businesses with Cuban labor connections should conduct due diligence to mitigate legal and reputational risks. Monitoring diplomatic developments and engaging with legal counsel will be key to navigating potential workforce disruptions and compliance challenges.

DHS Partially Vacates Haitian TPS Notice, Reduces Extension and Redesignation Period

On February 20, 2025, Homeland Security Secretary Kristi Noem announced a partial rollback of Haiti’s Temporary Protected Status (TPS) extension. The designation, originally set for 18 months, has been shortened to 12 months, now expiring on August 3, 2025. The initial registration period for new TPS applicants will also end on this date.

Employers and government agencies must update records for Haitian TPS beneficiaries with Employment Authorization Documents (EADs) coded A-12 or C-19, as their validity now extends only through August 3, 2025, instead of February 3, 2026. Additionally, individuals with pending TPS applications may withdraw their requests and seek a fee refund.

Secretary Noem stated that conditions in Haiti will be reassessed before any further determinations are made.

Impact: The reduction of Haiti’s TPS designation period creates workforce uncertainty for employers with Haitian employees. HR and global mobility teams must verify work authorization validity, update I-9 records, and assess potential workforce disruptions. Companies should communicate changes clearly to affected employees and explore alternative immigration options where necessary. Staying informed on DHS updates and preparing contingency plans will be critical to maintaining compliance and workforce stability.

DOS Rescinds Previous Expansion of Interview Waiver Policy

On February 18, 2025, the U.S. Department of State (DOS) updated its nonimmigrant visa interview waiver policy. Eligible applicants now include certain diplomatic and official visa holders (A, C-3, G, NATO, and TECRO E-1 categories), as well as those renewing a visa in the same category within 12 months of expiration. Applicants must apply from their country of nationality or residence, have no prior visa refusals (unless waived), and meet eligibility criteria. Consular officers retain discretion to require interviews. Applicants should check embassy websites for specific procedures.

Impact: The updated interview waiver policy streamlines visa processing for eligible applicants, reducing wait times and administrative burdens. HR and global mobility teams should advise employees on eligibility, ensure timely renewals within the 12-month window, and monitor embassy-specific guidelines. While the policy offers efficiency, case-by-case interview requirements remain, underscoring the need for proactive planning and compliance oversight.

USCIS I-485 Form Update

As of March 3, 2025, the USCIS website lists the January 20, 2025 editions as the official versions of Forms I-485, I-918, I-192, I-134, and G-325A—despite these editions not being previously available until now.

Key Issues:

• No Grace Period Announced: It remains unclear whether USCIS will reject applications submitted on March 3 using prior versions.
• Terminology Change: The updated forms replace “non-citizen” with “alien,” marking a policy shift.
• Further Revisions Expected: Additional form updates may impact how gender-related data is collected.

Impact: This unexpected change poses compliance risks and could lead to processing delays, rejections, or legal challenges for immigration cases currently in progress. Employers, legal teams, and global mobility specialists should immediately review all affected filings and prepare for potential disruptions.

March Visa Bulletin Announces Retrogression of EB-4 Category, Religious Workers Expiration

The Department of State’s March 2025 Visa Bulletin announces a retrogression in the EB-4 and Special Religious Worker (SR) categories, with a warning that they may become “Unavailable” as soon as April. If this happens, EB-4/SR visa numbers will not be available again until October 1, 2025, when the new fiscal year begins.

Additionally, the SR category is set to expire on March 14, 2025. No SR visas can be issued, and no final actions on adjustment of status cases can be taken after March 13, 2025. Individuals granted SR visas must enter the U.S. by midnight on March 13, or their visas will no longer be valid. The bulletin also outlines diversity visa category rank cut-offs for March and April.

Impact: The EB-4 retrogression and potential unavailability of visa numbers could delay workforce plans for employers relying on special immigrant categories, particularly religious organizations. The expiration of the SR category further adds urgency for affected employees to take immediate action. HR and global mobility teams should assess visa alternatives, communicate with impacted employees, and work closely with legal counsel to navigate these changes and mitigate disruptions.

DOS Releases Employer Guidance on I-9 Reverification Process for Venezuelan TPS Beneficiaries

On February 5, 2025, the Department of Homeland Security (DHS) issued guidance for employers on Form I-9 verification for Venezuelan Temporary Protected Status (TPS) beneficiaries. Employment authorization documents (EADs) with Category Code A12 or C19 and expiration dates of March 10, 2024, or September 9, 2022, under the 2021 TPS designation will now expire on March 10, 2025. Employers must reverify these employees before March 11, 2025.

For beneficiaries of the 2023 Venezuela TPS designation, EADs with an expiration date of April 2, 2025, require reverification before April 3, 2025. DHS also confirmed that the 2023 TPS designation for Venezuela will end on April 7, 2025, but the 2021 designation remains valid until September 10, 2025.

Impact: HR and global mobility teams must prepare for I-9 reverifications of Venezuelan TPS beneficiaries to ensure continued work authorization compliance. Employers should identify affected employees, communicate deadlines, and update records before the expiration dates to avoid employment disruptions. Given the termination of the 2023 TPS designation, companies should also explore alternative immigration options for impacted employees to maintain workforce stability.

FY 2026 H-1B Cap Initial Registration Period Opens March 7

U.S. Citizenship and Immigration Services (USCIS) announced that the initial registration period for the fiscal year (FY) 2026 H-1B cap season will run from noon ET on March 7, 2025, to noon ET on March 24, 2025. Employers must register each beneficiary electronically via a USCIS online account and pay the $215 registration fee.

Key updates include:

• The beneficiary-centric selection process (introduced in FY 2025) will continue, meaning each unique beneficiary will be entered into the lottery only once, regardless of the number of registrations submitted on their behalf.
• Organizational accounts are now required for H-1B petitioners. First-time registrants can create an account at any time.
• The daily credit card transaction limit for H-1B fees has been temporarily increased to $99,999.99 to accommodate high-volume payments.
• New organizational account features will streamline H-1B processing, including pre-population of certain fields on Form I-129 and improved paralegal access.

USCIS expects to notify selected registrants by March 31, 2025.

Impact: With the H-1B cap season approaching, HR teams and global mobility professionals must act quickly to register eligible employees and secure work authorization. The beneficiary-centric selection process reduces multiple filings per candidate, making strategic selection of employees more critical than ever. Organizations should ensure compliance with new registration requirements, update organizational accounts, and prepare for potential technical and financial transaction challenges. The enhancements to organizational accounts may help streamline processes, but HR teams should review them in advance to optimize efficiency. Early preparation is key to securing H-1B visa slots for high-priority talent.

DOS Requests Public Comments on Passport Application Changes; Lawsuit Filed

On February 14, 2025, the Department of State (DOS) announced a 30-day public comment period (ending March 17, 2025) for proposed changes to the U.S. passport application (Form DS-11). Updates include replacing “gender” with “sex” and requiring applicants to list their biological sex at birth as male (M) or female (F), in line with Executive Order 14168. Additionally, DOS will no longer issue passports or Consular Reports of Birth Abroad (CRBAs) with an “X” marker, though existing passports with “X” will remain valid until expiration.

A lawsuit filed on February 7, 2025, in U.S. District Court in Massachusetts challenges the executive order and passport policy, arguing they are unconstitutional and harmful to transgender, nonbinary, and intersex individuals. The plaintiffs seek a class-wide injunction to block enforcement of the policy.

Impact: The removal of the “X” gender marker on U.S. passports may create compliance and documentation challenges for global mobility teams, particularly for employees who identify as nonbinary or transgender. HR professionals should prepare for potential travel disruptions, legal uncertainties, and the impact on employees’ well-being. Companies should monitor legal developments, support affected employees in navigating passport changes, and review policies to ensure inclusivity in workforce mobility and international assignments.

President Trump Calls for Resettlement of White South Africans in the United States

On February 7, 2025, President Trump signed an executive order (EO) to halt foreign aid to South Africa and prioritize the resettlement of Afrikaner refugees in the United States. The EO directs the Secretaries of State and Homeland Security to focus on providing humanitarian relief and resettling Afrikaners, who are victims of alleged government-sponsored racial discrimination, particularly property confiscation. The U.S. Refugee Admissions Program will be used for their resettlement. Some Afrikaner groups have stated their preference to remain in South Africa, rejecting the call to emigrate.

Impact: This executive order could significantly affect immigration and refugee policies related to South Africa. Global mobility teams may need to prepare for potential changes in refugee and resettlement processes, including admission priorities for certain ethnic groups like Afrikaners. HR professionals supporting employees from South Africa may need to navigate new resettlement opportunities or advise on potential risks and impacts of the EO, especially in terms of employee relocation and humanitarian support for those affected by discrimination claims. It’s crucial for mobility teams to stay updated on policy changes and offer guidance to employees considering migration options under new U.S. refugee initiatives.