Overview
- The interim final rule takes effect October 30, 2025, requiring approval of a new Employment Authorization Document before work can continue for renewals filed on or after that date.
- Receipt notices (Form I-797C) issued on or after October 30 no longer serve as evidence of work authorization, prompting workers and employers to await the new EAD card.
- Limited exceptions remain, including certain Temporary Protected Status extensions by law or Federal Register notice, and automatic extensions granted for renewals filed before October 30 stay valid.
- Many common categories lose auto-extensions, including pending asylum (C08), adjustment of status (C09), and H-4 spouses (C26), though employment incident to status is unaffected unless an optional EAD is used.
- Employers must reverify under Form I-9 rules and cannot rely on receipt notices, with attorneys warning of likely short-term work gaps and USCIS opening a 30-day public comment period.