Effective December 5, 2025, U.S. Citizenship and Immigration Services (USCIS) has updated its Policy Manual to significantly shorten the maximum validity periods for Employment Authorization Documents (EADs).
This change marks a shift from the previous 5-year validity period down to 18 months for several major categories. This update follows the enactment of the “One Big Beautiful Bill Act” (H.R. 1) and aims to increase the frequency of security vetting and background checks for foreign nationals working in the U.S.
This change does not affect EADs issued prior to December 5, 2025; those cards remain valid until the expiration date printed on the front.
Affected Categories: 18-Month Maximum Validity
The following groups will now receive EADs valid for a maximum of 18 months (reduced from 5 years) for all initial and renewal applications pending or filed on or after December 5, 2025:
1-Year Maximum Validity Categories
Under the statutory requirements, the following categories are limited to one year or the duration of their authorized status, whichever is shorter (effective July 22, 2025):
Critical Impact on Employers and Applicants
This policy change, combined with the termination of the 540-day automatic EAD extension rule on October 30, 2025, creates significant administrative challenges:
- More Frequent Renewals: Impacted individuals must now file for work authorization (I-765) roughly three times more often than under the previous 5-year rule.
- Processing Backlogs: The increased volume of applications is expected to cause longer USCIS processing times and potential gaps in work authorization. The sheer volume of new renewal filings (Form I-765) will overwhelm USCIS, potentially pushing processing times beyond the 18-month validity of the card itself.
- Increased Costs: Applicants will face more frequent filing fees, with no fee waivers for many categories.
- Workforce Continuity: Employers must now monitor EAD expiration dates more closely to avoid unauthorized employment penalties. Because automatic extensions are no longer available for most categories, an employee must have their new EAD in hand before the old one expires. With validity cut to 18 months, the window for USCIS to adjudicate renewals has shrunk significantly.
Why Partner with Malescu Law?
With EAD validity periods reduced to 18 months and the 540-day automatic extension rule terminated, you and your organization is at risk of “work authorization gaps.” A single expired EAD can lead to forced employee terminations, and Form I-9 compliance penalties.
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We serve companies and individuals across all 50 states, the District of Columbia and Puerto Rico.
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