On February 25, 2025, the US Department of State (DOS) expanded its Cuba-related visa restrictions, targeting individuals associated with Cuban labor export programs, particularly overseas medical missions. This policy applies to current and former Cuban government officials, foreign government officials involved in the program, and their near-kinds.
Secretary of State Marco Rubio said Cuba's labour export system, including medical missions, constitutes forced labor and enriching the regime while Cubans are robbing essential health care. The United States aims to hold it responsible and curb the exploitation of Cuban workers abroad.
Impact: This expanded visa restriction policy could affect multinational organizations, healthcare institutions and government agencies involved with Cuban experts. HR and the Global Mobility Team should reevaluate their employment and mobility strategies to evolve US regulations. Businesses with Cuban labor relations should implement due diligence to mitigate legal and reputational risks. Oversight of diplomatic development and involvement with legal advisors is key to navigating potential workforce disruptions and compliance challenges.
On February 20, 2025, Homeland Security Secretary Christi Noem announced a partial rollback of Haiti's Temporary Protection Status (TPS) expansion. The designation, originally set for 18 months, has been shortened to 12 months and expired on August 3, 2025. The initial registration period for new TPS applicants will also end on this day.
Employers and government agencies are required to update their Employment Approval Document (EADS) records as the records of Haitian TPS beneficiaries with A-12 or C-19 Employment Approval Document (EADS) will only be extended until August 3, 2025, rather than February 3, 2026.
Secretary Noem said Haiti's terms will be reassessed before further decisions are made.
Impact: A reduction in the time frame for Haiti's TPS designation creates uncertainty in the workforce for employers with Haiti employees. The HR and Global Mobility Teams should verify the validity of work approvals, update I-9 records, and assess potential workforce disruptions. Companies should clearly communicate changes to affected employees and explore alternative immigration options when necessary. Maintaining DHS updates and preparations for contingency plans is important to maintain compliance and workforce stability.
On February 18, 2025, the US Department of State (DOS) updated its non-immigrant visa interview exemption policy. Eligible applicants include certain diplomatic and official visa holders (A, C-3, G, NATO, and TeCro E-1 categories) and those renewing their visas in the same category within 12 months of expiration. Applicants must apply from nationality or country of residence, do not have a previous visa refusal (unless exempt) and meet eligibility criteria. The Consulate retains its discretion to request an interview. Applicants must check the embassy website for specific procedures.
Impact: The updated interview exemption policy streamlines visa processing for eligible applicants and reduces latency and administrative burden. The HR and Global Mobility Teams should advise employees on eligibility, ensure timely updates within a 12-month window, and monitor embassy-specific guidelines. Although policies provide efficiency, case-by-case interview requirements remain, they emphasize the need for proactive planning and compliance monitoring.
As of March 3, 2025, the USCIS website lists the January 20, 2025 edition as official versions of Form I-485, I-918, I-192, I-134, and G-325A. These editions have not been available up to now.
Important Issues:
The bounty period will not be announced: It remains unclear whether USCIS will reject applications submitted on March 3 using previous versions. Changes to Terminology: The updated form replaces “non-citizen” with “alien” and marks a policy shift. Further expected revisions: Additional form updates may affect how gender-related data is collected.
Impact: This unexpected change poses a risk of compliance and could lead to delays in processing, rejections, or legal challenges in ongoing immigration cases. Employers, legal teams and global mobility specialists should immediately check all affected filings and prepare for potential disruptions.
Visa Bulletin in March 2025 announced a recovery in the EB-4 and Special Religious Workers (SR) categories, warning immediately that it is “unavailable” in April. If this occurs, your EB-4/SR visa number 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 14th, 2025. No SR visas can be issued and final actions regarding status case adjustments will not be taken after March 13, 2025. The Breaking News also outlines rank cutoffs for the diversity visa category for March and April.
Impact: EB-4 retreat and potential inability to use visa numbers could delay workforce planning for employers that rely on special immigration categories, particularly religious organizations. The expiration date for the SR category adds even more urgency to allow affected employees to take action immediately. The HR and Global Mobility teams need to evaluate visa alternatives, communicate with affected employees, and work closely with legal advisors to navigate these changes to mitigate disruptions.
On February 5, 2025, the Department of Homeland Security (DHS) issued guidance to employers regarding the form I-9 verification of Venezuela Temporary Protection Status (TPS) beneficiaries. Based on the TPS designation of March 10, 2021 and September 9, 2024, the Employment License Document (EADS) with Category Code A12 or C19 and expiration date and September 9, 2025 will expire on March 10, 2025. Employers must revise these employees by March 11, 2025.
For 2023 Venezuela TPS-designated beneficiaries, EADs, which require an expiration date of April 2, 2025, must have confidence by April 3, 2025. DHS has also confirmed that the 2023 TPS designation will end on April 7, 2025, but the 2021 designation will remain valid until September 10, 2025.
Impact: HR and Global Mobility Teams must ensure continuous work permit compliance in preparation for the I-9 respect of TPS beneficiaries in Venezuela. Employers must identify affected employees before the expiration date, inform them of deadlines, and break records to avoid employment disruptions. Given the termination of the TPS designation in 2023, businesses need to explore alternative migration options to help affected employees maintain workforce stability.
The US Office of Citizenship (USCIS) has announced that the initial registration period for the fiscal year (FY) 2026 H-1B Cap Season will take place from noon on March 7, 2025 until noon on March 24, 2025.
Important updates include:
The beneficiary-centered selection process (introduced in 2025) will continue. In other words, each unique beneficiary will be entered into the lottery only once, regardless of the number of registrations submitted on behalf of the number of registrations. Currently, H-1B petitioners need an organizational account. First-time subscribers can create an account at any time. The daily credit card transaction limit for H-1B fees has temporarily increased to $99,999.99 to accommodate bulk payments. The new Organizational Account feature streamlines H-1B processing, including improving pre-population and paralegal access for certain fields on Form I-129.
USCIS will notify selected subscribers by March 31, 2025.
Impact: With the H-1B cap season approaching, HR teams and global mobility experts need to act promptly to register eligible employees and secure work permits. The beneficiary-centered selection process reduces multiple filings per candidate, making employee strategic choices more important than ever. Organizations need to ensure compliance with new registration requirements, update their organizational accounts, and prepare for potential technical and financial transaction challenges. Enhanced organizational accounts can help streamline the process, but HR teams need to review them in advance to optimize efficiency. Early preparation is key to protecting your H-1B visa slot for prioritized talent.
On February 14, 2025, the Department of State (DOS) announced a 30-day public comment period (ends March 17, 2025) when a change to the US passport application (Form DS-11) was proposed. The update includes replacing “gender” with “sex” and requiring applicants to arrange biological sex in Executive Order 14168 as a student (M) or female (f). Additionally, DOS will no longer issue overseas birth passports or consular reports with the “X” marker, but existing “X” passports remain valid until they are valid.
The lawsuit filed February 7, 2025 in the U.S. District Court in Massachusetts challenges executive orders and passport policies, alleging it is unconstitutional and harmful to transgender, non-binary and intersex individuals. The plaintiffs are seeking a class-wide injunction to block the enforcement of the policy.
Impact: Removing the “X” gender marker on a US passport can present compliance and documentation challenges for global mobility teams, particularly employees who identify as non-binary or transgender. HR experts need to be prepared for potential travel disruptions, legal uncertainty, and impacts on employee well-being. Companies should monitor legal developments, support affected employees in navigating passport changes, and review policies to ensure employee mobility and inclusiveness in international missions.
On February 7, 2025, President Trump signed an Executive Order (EO) to halt foreign aid to South Africa and prioritize resettlement of African refugees in the United States. The EO has directed state and homeland security secretaries to focus on humanitarian relief and resettlement, particularly property confiscation, victims of government-supported racism. The US refugee admissions program is used for resettlement. Some African groups say they prefer to stay in South Africa and have refused to appeal to migrate.
Impact: This executive order could have a major impact on immigration and refugee policies related to South Africa. Global mobility teams may need to prepare for potential changes in refugee and resettlement processes, including entry priorities for certain ethnic groups such as Africans. HR experts supporting South African employees may need to navigate new resettlement opportunities and advise on the potential risks and impacts of EO, particularly in terms of employee relocation and humanitarian assistance to those affected by discrimination claims. It is important for mobility teams to stay up to date with policy changes and provide guidance to employees considering transition options under the new US Refugee Initiative.
