USCIS Issues New Guidance on $100K H-1B Fee

Following President Trump’s September 19, 2025 proclamation “Restriction on Entry of Certain Nonimmigrant Workers” requiring employers to pay a $100,000 fee for certain H 1B workers seeking to enter the United States, United States Citizenship and Immigration Services (“USCIS”) released additional guidance on October 20, 2025. This update, published on USCIS’s H-1B webpage , clarifies how and when the new fee applies but still leaves several key issues unresolved.

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OPINION The “Gold Card” Green Card: A Concerning Shift in US Immigration Priorities

On September 19, 2025, following his February 25, 2025 remarks previewing a residency pathway for high-net-worth individuals, President Donald Trump issued an Executive Order directing the Departments of Commerce, State, and Homeland Security to establish a new immigrant visa program within 90 days. The initiative, now known as the “Trump Gold Card” program, will allow foreign nationals to obtain lawful permanent resident status in the United States based on a significant financial contribution: at least US $1 million by an individual applicant, or US $2 million when paid by a corporation on behalf of an individual.

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DHS Ends Automatic Extensions of Work Permits for Renewal Applicants

On October 30, 2025, The Department of Homeland Security (“DHS”) along with United States Citizenship and Immigration Services (“USCIS”) published an interim final rule ending the automatic extension of Employment Authorization Documents (“EADs”) for certain categories of applicants who file renewal requests on or after October 30, 2025. Under the previous regulation, USCIS automatically extended work authorization and EAD validity for up to 540 days for individuals in specific eligibility categories while their renewal applications were pending in an attempt to ease the effects of USCIS delays in processing. The new interim final rule does not affect any EADs that were automatically extended before October 30, 2025.

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New US Citizenship Civics Test Effective October 20, 2025

Beginning October 20, 2025, United States Citizenship and Immigration Services (“USCIS”) will implement the 2025 Civics Test, announced on September 17, 2025. The agency has stated that the updated test aims to ensure applicants demonstrate a deeper understanding of US history, government, and civic responsibilities, with the goal of naturalizing individuals who are “fully assimilated and will contribute to America’s greatness.” Applicants who file Form N-400 on or after October 20, 2025, will be required to take the new test. Those who filed, or have pending applications, before that date will continue to take the 2008 Civics Test.

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