What employers and foreign nationals need to know about USCIS’s enhanced FBI security vetting initiative and its impact on pending applications
On April 27, 2026, U.S. Citizenship and Immigration Services (USCIS) deployed an upgraded fingerprint-based FBI security check system. As a direct consequence, the agency has begun pausing the adjudication of certain pending immigration benefit applications in order to re-vet those cases under the new system.
The scope of this initiative is broad. Any pending application for which fingerprint-based background checks were submitted to the FBI before April 27, 2026 may be subject to re-vetting. Adjustment of status, naturalization, and asylum applications are among the most commonly affected case types.
While USCIS has characterized the expected delays as brief, the agency has not provided a specific timeline for completion. For employers managing active immigration programs and foreign nationals awaiting critical immigration benefits, the uncertainty warrants prompt attention.
What USCIS Is Doing
The new vetting system represents an agency-wide upgrade to the FBI security check infrastructure that underlies a significant portion of USCIS’s adjudicative workload. For cases already in the pipeline, the transition requires USCIS officers to re-submit previously collected fingerprint data to the new system before the application can proceed to final adjudication.
Importantly, no action is required from applicants. USCIS officers are responsible for re-submitting the fingerprints already on file. Applicants will not be asked to schedule new biometrics appointments or provide additional documentation as part of this process.
USCIS officials have stated publicly that “any delay in decision issuance should be brief and resolved shortly.” However, the agency has not defined what “shortly” means in operational terms, and it remains unclear how many pending cases are affected or how long the re-vetting queue will take to clear.
Which Applications Are Affected
The re-vetting requirement applies to any case type that involves fingerprint-based background checks, where those checks were submitted to the FBI prior to April 27, 2026. Case types most commonly affected include:
- Adjustment of status applications (Form I-485)
- Applications for naturalization (Form N-400)
- Asylum applications
- Any other pending benefit applications that required biometric collection and for which background checks were submitted before the transition date
Employers and practitioners should also note that this re-vetting initiative is separate from the USCIS adjudication hold that has been in place since January 2026 for individuals born in or nationals of countries subject to the current travel ban. The two policies operate independently. Affected individuals may be subject to both, which could compound delays significantly.
Why This Matters for Employers
For most affected applicants, the practical significance of this initiative lies not in the re-vetting itself, but in the downstream consequences of delayed adjudication.
Foreign nationals awaiting final approval on adjustment of status applications may be approaching the expiration of their employment authorization documents (EADs), advance parole (AP) travel documents, or underlying nonimmigrant status. Adjudication delays that push final decisions beyond those expiration dates can create gaps in work authorization or complicate international travel plans.
Employers managing large-scale immigration programs should conduct a targeted review of their population with pending I-485 and other affected applications, with particular attention to individuals whose related documents are expiring in the next 60 to 90 days.
As Vic Goel, Managing Partner of Goel & Anderson, notes:
“The re-vetting process itself is administrative, and no action is required from applicants. The real risk lies in the timing. Employers need to identify now which employees have documents expiring in the near term, and assess whether any protective filings or contingency steps are appropriate while we wait for USCIS to work through the backlog.”
Key Practical Considerations
Employment authorization. For foreign nationals whose work authorization is tied to a pending adjustment of status application, confirm whether an EAD renewal application has been filed and whether the auto-extension provisions under applicable regulations apply. In many cases, a timely-filed EAD renewal will extend work authorization automatically for a defined period, but the specific rules depend on the category and circumstances.
Travel. Foreign nationals with a pending I-485 who do not yet have a valid advance parole document should refrain from international travel. Departure from the United States without advance parole is generally treated as an abandonment of a pending adjustment of status application, regardless of the reason for the delay in adjudication.
Underlying status. For applicants who entered the United States in a nonimmigrant status that is expiring or has expired, and who are awaiting adjustment, confirm whether the pending I-485 provides a sufficient basis for continued presence, and evaluate whether any additional protective steps are warranted.
Compounding factors. As noted above, individuals from travel ban-designated countries face a separate adjudication hold that has been in effect since January 2026. For those individuals, the combination of both holds may result in substantially longer delays.
Recommended Steps for Employers and Foreign Nationals
Employers should consider taking the following steps now:
- Identify affected employees
Conduct a review of all pending I-485 and other affected applications, and flag individuals with EADs, AP documents, or nonimmigrant status expiring within the next 60 to 90 days. - Assess EAD auto-extension eligibility
For employees with pending EAD renewal applications, confirm whether auto-extension applies and document the basis for continued employment authorization. - Advise on travel restrictions
Ensure that employees with pending adjustment of status applications understand the travel implications and do not depart the United States without a valid advance parole document. - Monitor USCIS communications
Track USCIS processing time updates and any agency announcements regarding the duration and resolution of the re-vetting initiative. - Coordinate with counsel
For individuals with complex status situations or documents expiring in the near term, engage immigration counsel proactively to assess whether any additional filings or protective steps are appropriate.
A Note on the Broader Context
This development is one of several recent USCIS enforcement and operational shifts that are adding complexity to the adjudicative environment. In addition to the fingerprint re-vetting initiative and the travel ban adjudication hold, USCIS has been expanding its use of data-driven compliance tools and site visits across a range of benefit categories.
The common thread across these developments is an agency that is increasingly focused on verification and scrutiny at every stage of the immigration benefit process. For employers managing large-scale immigration programs, the cumulative effect of these changes requires a more proactive and integrated approach to program management.
Goel & Anderson will continue to monitor USCIS guidance and agency communications regarding this initiative and will provide updates as additional information becomes available.
This alert is provided for informational purposes only and does not constitute legal advice. Each matter is fact-specific, and the impact of this development will vary depending on individual circumstances. If you have questions about how the USCIS re-vetting initiative may affect your workforce or your own pending application, please contact your Goel & Anderson attorney.
