USCIS AR-11 Change Alert: EB3 Labor Sponsorship 2026 Employers Now at Risk

On May 7, 2026, USCIS published a 60-day notice proposing to amend Form AR-11, Alien Change of Address. The proposal would require foreign nationals to disclose employment information—including the identity of their current employer—and receipt of means-tested public benefits when filing a routine address update. The public comment period is open until July 6, 2026. For EB-3 applicants and other sponsored workers, the implications are significant. Because Form AR-11 is already a mandatory filing obligation under the Immigration and Nationality Act (INA), this expansion doesn't create a new requirement but dramatically increases the scope of data collected. Errors, omissions, or inconsistencies in the expanded form could result in delays, denials of future benefit applications, work authorization gaps, or even visa revocation. The employer exposure is particularly notable. USCIS would gain visibility into which employers are sponsoring or employing noncitizens through a form that was historically administrative in nature. That data could potentially be shared with DOJ or ICE for I-9 audit targeting or employer compliance investigations, even for employers not currently participating in E-Verify. This proposal fits a broader pattern of DHS data integration. Similar to how E-Verify users currently receive CHNV Revocation Reports when employees lose work authorization, expanded AR-11 data collection could eventually extend enforcement-linked notifications beyond E-Verify participants—meaning non-E-Verify employers could become indirectly visible to enforcement agencies. Employers sponsoring EB-3 workers should review the draft Form AR-11 and Table of Changes now. Proactively assisting foreign national employees in completing AR-11 accurately and on time is strongly advised. The comment period closes July 6, 2026—stakeholders may want to submit feedback before the form is finalized.