Key Points:
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- A $100,000 payment must accompany all new H-1B petitions filed on or after 12:01 a.m. EDT, September 21, 2025.
- The Proclamation does not affect previously approved H-1B visas or petitions filed before September 21, 2025. It also does not impose fees on extensions or renewals, nor does it restrict current H-1B holders from international travel.
- It remains unclear whether the new payment requirement applies to other petition types, such as change of employer, concurrent employment, or amendments. However, since the Proclamation is structured primarily as an entry restriction rather than a fee regulation, we believe it is more likely that these petition types, when filed for beneficiaries physically present in the U.S., will not be subject to the $100,000 fee.
Impact Reference Table:
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We will continue to monitor these developments closely and provide updates as further guidance becomes available.
Our office will also host a Q&A session at 1:30 p.m. PT on Wednesday, September 24, 2025. Please join if you have questions about the Proclamation by confirming your attendance through our Q&A Session Questionnaire.