U.S. Citizenship and Immigration Services (USCIS) has revised the maximum validity periods for employment authorization documents (EADs) in several categories. This change is effective immediately and applies to EADs issued on or after December 5, 2025. For the impacted categories listed below, USCIS will limit the validity period from 5 years to 18 months.

The Impacted Categories:

• Refugees (A03)
• Asylees (A05)
• Withholding of removal grantees (A10)
• Pending asylum applicants (C08)
• Pending adjustment of status applicants (C09)
• Pending cancellation of removal applicants (C09)

Details:

• Applies to both initial and renewal EAD applications pending or filed on/after December 5, 2025.
• Does not impact EADs issued before December 5, 2025.
• Eligibility criteria for work authorization remains unchanged.

Implications:

• Applicants in affected categories must apply for EAD renewals more often.
• Increased volume of renewal applications is expected to create larger backlogs and longer processing times.
• Employers should anticipate disruption in work authorization for employees working on these EADs, especially considering the recent Department of Homeland Security interim final rule eliminating the automatic 540-day work authorization extension for renewal applicants whose initial EAD expires while the renewal application is pending. For more information on this interim final rule, please review our alert at the following link - New Interim Final Rule Ends Automatic Extension for Employment Authorization Documents: Miller Canfield.

Employers should notify employees several months before EAD expiration to avoid renewal delays and prepare for possible processing delays.