USCIS Policy Implementation Notice: January 2025 Updates and Compliance Requirements
Mahaprasad Nanda
January 04, 2025
Form I-129 Revision: Procedural Impact and Compliance Mandates
USCIS has implemented a revised Form I-129 (Edition Date: 01/17/25) pursuant to the H-1B modernization final rule and H-2 final rule. Practitioners should note:
Immediate implementation without transitional grace period
Mandatory rejection of submissions utilizing the prior 04/01/24 edition
Required compliance for all petitions filed on or after January 17, 2025
Integration with modernized H-1B registration process
Dissolution of H-4/L-2 Bundling Settlement Agreement
The expiration of the federal court settlement agreement governing H-4 and L-2 adjudication bundling warrants immediate procedural adjustments. Counsel should anticipate:
Decoupled adjudication timelines between principal and dependent applications
Strategic considerations for premium processing elections
Potential necessity for interim solutions for employment authorization continuity
Modified client advisory protocols regarding processing timeframes
Ukraine TPS Extension: Procedural Requirements and Eligibility Maintenance
DHS has authorized an 18-month TPS extension for Ukraine nationals. Critical compliance points include:
Re-registration window: January 17, 2025 - March 18, 2025
Extension period: April 19, 2025 - October 19, 2026
Continued eligibility verification requirements for approximately 103,700 beneficiaries
Documentation maintenance obligations
Visa Bulletin Priority Date Analysis: Employment-Based Categories
Current priority date movements necessitate strategic filing considerations:
EB-2 India: Forward movement to October 1, 2012 (2-month advancement)
EB-2 China: Progression to April 22, 2020 (1-month movement)
EB-2 All Other Countries: Advanced to April 1, 2023
Practice Advisory
Counsel should implement the following measures:
Review all pending I-129 submissions for immediate form compliance
Develop modified processing time advisories for H-4/L-2 dependent cases
Institute enhanced tracking protocols for decoupled adjudications
Evaluate strategic premium processing elections in light of bundling termination
Review impact on outstanding RFEs and pending submissions
These procedural modifications necessitate immediate review of internal processes and client communication protocols. Practitioners should assess the impact on pending cases and adjust filing strategies accordingly.
The convergence of these policy changes requires heightened attention to submission timing, documentation requirements, and client expectations management. Firms should review their standard operating procedures to ensure compliance with these modified requirements.