USCIS Narrows Use Of Adjustment Of Status For Employment-Based Green Cards

May 28, 2026

 

What's New

On May 21, 2026, USCIS issued Policy Memorandum PM-602-0199, clarifying that adjustment of status (AOS)—the process many foreign nationals use to obtain lawful permanent residence (a “green card”) from within the United States—is a matter of discretion, not an entitlement, even where statutory eligibility is met. The memo does not change eligibility requirements but directs officers to treat AOS as an “extraordinary” form of relief rather than a routine alternative to consular immigrant visa processing abroad.

What It Means

For employers, the policy signals heightened scrutiny at the final stage of the green card process and will likely require more applicants to complete the green card process outside of the United States at U.S. consulates.

Historically, most employer-sponsored workers completed permanent residence through AOS while continuing to work in the United States. The memo reorients that pathway as a disfavored exception, suggesting that even eligible employees may be expected to pursue consular processing abroad.

As a result, obtaining permanent residence through AOS will be less predictable. Cases involving status violations, perceived immigrant intent issues, or other complicating factors face increased denial risk.

The policy memo’s emphasis on departing the U.S. when a temporary stay is complete is particularly relevant for non-dual-intent visa holders (e.g., F-1, TN, J-1, O-1), though even H-1B and L-1 workers may face additional scrutiny.

What You Should Do

Employers should review green card pipelines, identify employees relying on AOS, and assess risk factors. Plan for potential delays, denials, and workforce disruption tied to green card timing.





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