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Appeals Court Speeds Challenge to $100,000 H‑1B Fee as Wage‑Weighted Selection Rule Takes Effect Next Month

Oral arguments in February will test the consular fee, with employers preparing for a redesigned H‑1B selection this spring.

Overview

  • U.S. Court of Appeals for the D.C. Circuit granted the Chamber of Commerce an expedited appeal, setting February arguments on President Trump’s $100,000 fee for certain H‑1B applicants.
  • A D.C. district judge recently upheld the fee under INA §212(f); the charge applies to beneficiaries seeking visas from abroad and not to in‑country changes of status, extensions, transfers, or cap‑exempt cases.
  • DHS has finalized a wage‑weighted H‑1B cap selection system effective February 27, 2026, replacing the random lottery for the upcoming FY 2027 registration season.
  • Registrations will be weighted by DOL wage levels—Level IV entered four times, Level III three, Level II twice, Level I once—and employers must lock in the SOC code, worksite, and wage level at registration.
  • DHS projects higher aggregate H‑1B wages (about $502 million in the first year) and modeling shows markedly lower selection odds for entry‑level roles, prompting employers to reassess hiring strategies before March.