If you manage a workforce that includes foreign national employees, you are likely aware that the employment authorization document (EAD) compliance landscape has changed fundamentally over the past year. This article focuses on what those changes mean for your I-9 obligations and day-to-day workforce management.
On October 30, 2025, Department of Homeland Security (DHS) published an interim final rule ending automatic EAD extensions for timely filed renewals.[1] Anyone who filed or files to renew on or after October 30, 2025, gets no automatic extension of work authorization.[3] Employees who filed to extend work authorization before October 30, 2025, remain eligible for 540 days of automatic extension as they awaits issuance of the new EAD.[4][5]
Separately, U.S. Citizenship & Immigration Services (USCIS) reduced maximum EAD validity from five years to 18 months for refugees (EAD category: A03), asylees (EAD category: A05), withholding of removal (EADS category: A10), pending asylum applicants (EAD category: C08), adjustment of status applicants (EAD category: C09), and cancellation of removal/NACARA applicants (EAD category: C10).[7][8]
The One Big Beautiful Bill Act (H.R. 1), signed July 4, 2025, caps Temporary Protected Status (TPS) EADs at shorter of one year or the TPS designation period.[14][12] USCIS interpretive guidance, issued March 13, 2026, applies this cap partially retroactively: even pre-July 22, 2025, TPS filers get no more than one...
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