Updates on The H-1B Executive Action: What We Do and Do Not Know at This Time + FAQs

What’s Happening

On Friday, September 19th, the Trump Administration signed a Proclamation, Restriction On Entry Of Certain Nonimmigrant Workers (“H-1B Proclamation”), instituting a new “Travel Ban” on H-1B visa holders where their petitioning employer has not paid a new $100,000 fee for certain H-1B petitions filed after September 21, 2025. The initial wording of the H-1B Proclamation was extremely vague and imprecise and suggested that the new fee would apply to all H-1B visa holders outside the U.S. on the effective date, which caused extreme chaos and panic, with many H-1B workers rushing to get back to the U.S. before the Saturday evening deadline.

Following this initial chaos, separate clarifying guidance was issued by the White House, Customs and Border Protection (“CBP”), U.S. Citizenship and Immigration Services (“USCIS”), and the Department of State (“DoS”). Despite these additional clarifications, there continues to be conflicting information due to confusing wording across these individual resources which makes it difficult to ascertain the full scope of the new rule. Below we include:

  1. An analysis of what information is confirmed at this time and what remains unclear

  2. Responses to Frequently Asked Questions

  3. Some practical guidance for H-1B employers and what to expect next

  4. An overview of the official government guidance provided regarding the H-1B Proclamation to-date

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