North America
Key trends shaping North America's labor and immigration landscape
Rising cost and fiscal gating of immigration benefits
Immigration authorities in the United States are increasingly using high government fees as a policy lever to regulate access to immigration benefits. The introduction of a USD 1,000 immigration parole fee under the HR-1 Reconciliation Bill and the previous implementation of a USD 100,000 fee for certain new H-1B petitions represent a marked escalation in cost-based screening. These measures go beyond routine fee adjustments and signal a deliberate effort to limit discretionary relief and certain employment-based pathways through financial thresholds. For employers, immigration budgeting and cost forecasting are becoming materially more complex, particularly for high-volume or early-career talent programs.
Intensified national security screening and country-based risk differentiation
The last quarter saw a pronounced expansion of security-driven immigration controls in the United States, with adjudications increasingly shaped by nationality, country of birth, and perceived geopolitical risk. USCIS has begun applying country-specific scrutiny in discretionary benefit adjudications, suspended processing for applicants connected to 19 designated high-risk countries, and expanded entry restrictions under the June 2025 presidential proclamation. In parallel, the Department of State has broadened social media vetting requirements, while DHS (U.S. Department of Homeland Security) continues to expand biometric collection. Together, these measures reflect a systematic shift toward layered security screening across the full immigration lifecycle, from visa issuance to in-country benefits.
Retrenchment of flexibility and processing accommodations
US authorities are rolling back pandemic-era and efficiency-focused accommodations in favor of tighter procedural control. The termination of automatic Employment Authorization Document extensions removes a critical buffer that employers have relied on to maintain workforce continuity. At the same time, consular appointment disruptions linked to enhanced vetting and expanded data collection initiatives, such as proposed ESTA changes, underscore a more rigid and interruption-prone operating environment. Employers must increasingly plan for gaps in work authorization, travel delays, and extended adjudication timelines as baseline risks rather than exceptions.
Selective prioritization of labor market needs in permanent immigration pathways
While the United States environment trends toward restriction, Canada continues to refine its economic immigration programs to better align with labor market priorities. Ontario’s expansion of discretionary return criteria under the OINP reflects a growing emphasis on program manageability and targeted selection rather than broad intake. This illustrates a broader North American contrast, with Canada focusing on demand-driven optimization while the United States emphasizes enforcement, cost barriers, and security controls.
Canada
Greater discretion and labor market alignment under provincial nomination programs
Ontario amended regulations governing the Ontario Immigrant Nominee Program effective October 31, 2025, expanding the list of factors that may justify returning applications prior to nomination issuance. These changes are designed to allow the program to concentrate resources on applications that align with current labor market priorities and program capacity.
While not a tightening of eligibility criteria per se, the expanded discretion increases uncertainty for applicants and employers relying on the OINP as a predictable permanent residence pathway. Employers should expect more selective processing outcomes and ensure that applications are closely aligned with provincial demand signals and program objectives at the time of filing.
United States
Cost escalation and structural barriers to access
During the last quarter of 2025, the United States significantly increased the financial thresholds associated with immigration benefits. Effective October 16, 2025, USCIS, CBP, and ICE began collecting a USD 1,000 immigration parole fee under the HR-1 Reconciliation Bill, applying to individuals granted parole at ports of entry or while in the United States. In parallel, USCIS issued enforcement guidance for the Presidential Proclamation on Restriction on Entry of Certain Nonimmigrant Workers, operationalizing the USD 100,000 fee for certain new H-1B petitions filed on or after September 21, 2025. Together, these measures signal a shift toward cost-based gating of both discretionary relief and employment-based visa pathways.
Tightening of adjudicatory flexibility and workforce continuity challenges
The operating environment for employers became more rigid as DHS rolled back key procedural accommodations. Effective October 30, 2025, the automatic 540-day extension of Employment Authorization Documents was terminated, increasing the risk of work authorization gaps for renewal applicants. At the same time, USCIS confirmed that country-specific conditions, including those outlined in Presidential Proclamation 10949, are now being considered in discretionary benefit adjudications. These changes heighten uncertainty and place greater emphasis on early filing strategies and contingency planning.
Expansion of security-driven screening and entry restrictions
National security considerations continued to drive US immigration policy in late 2025. USCIS suspended adjudication of all pending immigration benefit requests for individuals born in or citizens of 19 designated high-risk countries, with no defined timeline for resumption. Concurrently, the Department of State expanded social media vetting requirements to H-1B and H-4 visa applicants, triggering consular appointment disruptions, while CBP proposed broader data collection requirements under the ESTA program. Looking ahead, the expansion of full entry restrictions to additional nationalities effective January 1, 2026 reinforces the durability of nationality-based screening as a central feature of the US immigration framework.