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• DOL Advances Final Rule to Increase Prevailing Wage Requirements
• Philippines Introduces New Rules to Streamline Alien Employment Permit Processing
• France Introduces Immigration Reforms to Expand Worker Mobility and Flexibility

DOL Advances Final Rule to Increase Prevailing Wage Requirements

The Department of Labor has submitted a final regulation to the Office of Management and Budget for review that could significantly increase prevailing wage requirements for employers sponsoring foreign workers. The changes would affect the H-1B, H-1B1, and E-3 visa programs, as well as PERM labor certification applications used in many employment-based green card cases. 

DOL initially proposed the changes in March 2026, seeking to raise minimum wage levels under its four-tiered Occupational Employment and Wage Statistics (OEWS) system. The proposed increases would affect all four wage levels, potentially raising sponsorship costs across a wide range of occupations. 

Under the March proposal, the wage percentiles would change as follows: 

These adjustments would substantially increase the minimum wages employers must offer in many sponsored positions, particularly at entry and intermediate skill levels. 

Importantly, the final rule is not yet in effect. Its exact provisions remain confidential until OMB completes its review and DOL publishes the regulation in the Federal Register. The final requirements may differ from those outlined in the March proposal. 

Once published, the regulation is expected to include an implementation date, potentially bringing the new wage requirements into effect before the FY 2028 H-1B cap filing season.

Impact: Higher prevailing wage requirements could significantly increase immigration sponsorship costs and affect hiring budgets, recruitment strategies, and PERM planning. Employers should review anticipated H-1B and PERM filings and prepare for possible wage adjustments while awaiting publication of the final rule.

Philippines Introduces New Rules to Streamline Alien Employment Permit Processing

The Philippine Department of Labor and Employment (DOLE) has introduced reforms to simplify the Alien Employment Permit (AEP) application process for foreign nationals working in the Philippines. Effective November 11, 2026, the changes aim to reduce administrative requirements and accelerate work permit processing. 

Under the new framework, the standard government processing period will decrease from 15 to 10 business days, although DOLE may extend processing by up to 10 additional business days. 

Other significant changes include: 

• Simplified labor market testing: Employers will no longer need to publish job advertisements in newspapers. Instead, notices may be published through DOLE’s official online portal or designated public repository. 
• Reduced documentation requirements: Certain permits and approvals from other government agencies will no longer be required when submitting an AEP application, although underlying licensing obligations remain. 
• Revised payment procedures: Government fees will be collected after technical evaluation and approval rather than during initial submission. 
• New applicant requirements: Foreign nationals must attend an orientation covering Philippine history and cultural diversity, while employers must ensure qualifying foreign employees receive applicable healthcare benefits. 

The reforms also discontinue accreditation requirements for authorized representatives, allowing employers to process applications through designated HR personnel, representatives, or legal counsel. 

Although the changes are intended to improve efficiency, DOLE may issue additional guidance clarifying implementation procedures and requirements for applications already underway. 

Impact: The reforms could reduce administrative costs and simplify work permit applications for employers sponsoring foreign nationals in the Philippines. However, temporary processing delays may occur as DOLE transitions to the new procedures. Employers should allow additional time for upcoming applications and monitor further government guidance. 

France Introduces Immigration Reforms to Expand Worker Mobility and Flexibility

France has implemented several immigration reforms effective October 30, 2026, introducing greater flexibility for foreign workers, shorter residence permit processing periods, and changes to EU Blue Card and intracompany transferee (ICT) requirements. The reforms support France’s alignment with updated European Union immigration directives. 

One of the most significant changes provides additional protections for foreign nationals experiencing unemployment. Temporary Worker permit holders now have three months to secure new employment without losing their residence status, while EU Blue Card holders receive six months. Workers must still meet applicable requirements when transitioning to a new employer. 

Other key reforms include: 

• Faster processing: Standard residence permit processing periods decrease from four months to three months, with an additional 30 days permitted for complex cases. 
• EU Blue Card flexibility: Holders of EU Blue Cards issued by another EU country may qualify for mobility to France after 12 months, reduced from 18 months. 
• New ICT salary requirements: Intracompany transferees and trainees will become subject to higher minimum salary thresholds once authorities establish the applicable amounts. 
• UK worker exemption: Certain qualifying UK-based employees may become eligible for work permit exemptions for assignments totaling up to 12 months, subject to further government guidance. 

The reforms also introduce more flexible EU Blue Card validity periods for shorter employment contracts and revised renewal conditions for certain locally hired foreign workers. 

Importantly, some provisions, including the ICT salary thresholds and UK work permit exemption, are not yet operational pending additional government instructions. 

Impact: The reforms could improve workforce mobility, reduce processing delays, and provide greater stability for foreign employees transitioning between jobs. Employers should review affected immigration categories and assignment plans while monitoring further guidance on provisions that have not yet been fully implemented.