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HR Guide: Immigration Government Shutdown 2025 - Actions to Avoid Oct 1 Disruptions

Updated: Oct 1

The government may shut down on October 1, 2025. Use this immigration government shutdown HR guide 2025 as a do-now guide for HR leaders managing foreign national employees and global mobility.


Minimal, textured illustration on off-white: calendar, government building, computer with lock, and a folder with a pause symbol, linked by curved arrows in muted purple tones.

Why this matters

A lapse in federal funding does not hit every immigration system the same way. Some continue, some slow, and some stop. The companies that plan today and tomorrow will avoid stranded employees, missed I-9 steps, and project delays. Use this immigration government shutdown HR guide 2025 to align HR, Legal, and managers on fast decisions.



What you get from this HR Guide on Immigration Government Shutdown 2025

  • A two-day action plan you can execute right now

  • A quick view of which agency processes are likely to continue vs pause

  • Copy-paste emails and Slack messages for employees, managers, recruiters, and leadership

  • Simple trackers to manage backlogs while systems are offline



First, a quick view of impact areas in immigration

Area

What usually continues

What may pause

HR risk if you wait

USCIS

Most case filings and premium processing continue because fees fund operations

Programs tied to appropriations may pause

Lost time on critical extensions or EAD renewals

DOL OFLC / FLAG

FLAG portal, LCAs, PERMs, and prevailing wages pause

No new LCAs, no PERM filings, queue grows

E-Verify

E-Verify is suspended

New hires still need I-9s, but you cannot create cases until systems return

Department of State

Most visa and passport services continue, fee-funded

Individual posts may scale back if fee reserves dip

Travel uncertainty, longer wait times

CBP

Ports of entry remain open

Some delays possible

Reentry timing and I-94 review still required

Use this grid as a conversation starter with Legal and leadership. Confirm agency notices as they publish, then update your plan.


Where the pause hits in common scenarios


  • H-1B transfer or change of employer - The pause is at the Department of Labor. You cannot get an LCA certified while FLAG is offline. USCIS filing requires a certified LCA. Prepare LCA postings and signatures now so you can file the moment FLAG returns.

  • H-1B cap case waiting on approval - USCIS keeps adjudicating, including premium processing. Travel and stamping may still be affected by local consulate capacity.

  • PERM labor certification - New prevailing wage requests and PERM filings pause at DOL. Use the downtime to finalize ads, audits, and documentation so you can file immediately when systems are back.

  • TN and E-3 - Consular visa services generally continue because they are fee-funded. Some posts may scale back to emergencies if fee reserves run low. For Canadians applying TN at the border, CBP continues essential functions, but expect possible delays.

  • L-1 - USCIS filings continue. If the employee needs a visa stamping abroad, build extra time and check the post/consulate capacity.

  • I-9 and E-Verify - Keep completing Form I-9 on time. E-Verify is unavailable. Keep an outage log and create cases when systems return. If you use the DHS alternative remote procedure, continue the photo plus live video steps.

  • Travel while a status extension is pending - A timely filed H-1B or L-1 or TN extension allows up to 240 days of continued work inside the U.S. If the employee leaves, they may need visa stamping to re-enter. Use your stoplight travel policy to decide.




Sep 29 - Do these today (immigration government shutdown HR guide 2025)


By 12 noon

(1) Freeze moves that need an LCA until you file. File any urgent LCAs now. Capture screenshots and submission receipts.

(2) Submit time-sensitive PERM items: prevailing wage requests and PERM applications that are ready. Save proof of submission.

(3) Prioritize USCIS filings: ship premium processing for near-term expirations, bridge extensions, and EAD renewals to lock receipt dates.


By 3 pm

(4) E-Verify contingency on paper: publish a 1-pager for recruiters and HRBPs:

  • Keep completing Form I-9 on time.

  • If E-Verify is down, log the outage, onboard the employee, and create the E-Verify case when the system returns.

  • Keep copies of completed I-9s and your outage log.

(5) Travel stoplight refresh: apply your Green-Yellow-Red rules. Have a. call with the Yellow category travelers to confirm stamping plans and buffers.


By end-of-day

6) Message leadership and managers using the templates below.7) Spin up trackers listed below so you are ready if systems pause at 12:01 am on Oct 1.



Sep 30 – Final prep

  1. File anything left at DOL by close of business.

  2. Double-check recruiter workflows: I-9 completion will continue. E-Verify cases will be queued for later. Train on the alternate remote procedure if your company uses it.

  3. Travelers and consular cases: add a 3 to 5 day buffer to return dates. Push essential appointments earlier where possible.

  4. Payroll and I-9 alignment: confirm your I-9 reverification queue, especially for workers who will re-enter the U.S. soon and receive new I-94s.

  5. Escalation tree: publish phone numbers for HR first responders, Legal, and your immigration vendor.



Copy-paste messages


1) Company-wide Slack for employees who travel

Heads up on possible federal shutdown Oct 1. If you have international travel or visa stamping this month, contact HR before you book or depart. We will apply a stoplight travel policy to keep returns predictable. If you are already abroad, keep HR updated after any visa appointment and after reentry so we can review your new I-94.

2) Managers

Please route all travel and location changes for foreign national employees through HR before committing. Moves that require a new LCA may be delayed if the DOL portal pauses. We will triage by business criticality.

3) Recruiters and onboarding

Continue completing Form I-9 on time. If E-Verify is unavailable, log the outage and proceed with onboarding. We will create the E-Verify case when systems return. Use the attached 1-pager for steps and the outage log template.

4) Leadership

If a shutdown begins Oct 1, USCIS is expected to continue most case work, but DOL labor certifications and E-Verify will likely pause. We have front-loaded filings and activated a travel stoplight policy. Expect slower government response times and potential visa appointment constraints at some consulates. We will report status daily at 10 am while the lapse continues.


Two simple trackers you can build in minutes


A) DOL backlog tracker

Columns: Employee, Role, Office, Needs (LCA, PWD, PERM), Status, Filed date, Proof saved, Business impact if delayed 1 to 3 months, Owner.

B) E-Verify catch-up tracker

Columns: Employee, Hire date, I-9 complete date, E-Verify case created date, Outage dates, Notes, Owner.

Save both trackers in a shared folder that HR, Legal, and TA can access.


What to do if a shutdown starts Oct 1

  • HR daily huddle: 15 minutes to review filings, I-9s, travel, and escalations.

  • USCIS: keep filing. Use premium where it protects work authorization or travel. Save receipts.

  • DOL: hold new LCAs, PWDs, and PERMs, and keep your backlog ranked by impact. Prepare postings and signatures so you can file the moment FLAG returns.

  • E-Verify: keep onboarding with timely I-9s. Maintain your outage log. Create cases when the system is back.

  • Consulates: expect uneven capacity. Keep proof of urgency handy for expedition requests.

  • Courts: assume non-detained hearings will be reset. Keep employees and counsel in sync on new dates.



Quick FAQs for HR


Do we have to stop hiring if E-Verify is down

No. Complete Form I-9 on time. Create the E-Verify case once the system returns.


Can we move a remote employee to a new state or office

If the role requires an LCA and new worksite details, consider pausing non-essential moves until DOL is back online.


Should we cancel all travel

No. Use the stoplight rules. Green may proceed. Yellow needs approvals and a stamping plan. Red should wait.


What should a returning traveler send HR

A copy of the new I-94 within 3 business days so HR can confirm dates and plan I-9 reverification if needed.



One-pager: E-Verify outage steps for recruiters

  1. Complete Form I-9 on time. Do not delay the hire because E-Verify is unavailable.

  2. Record the outage dates and a short note of what you tried.

  3. When E-Verify is back, create the case for each hire made during the outage and keep your log for the audit file.



Final takeaway

A shutdown does not have to derail hiring or travel. Front-load DOL filings today, keep USCIS cases moving, run your travel stoplight policy, and be ready to catch up on E-Verify. The companies that prepare in the next 24 to 48 hours will feel far less friction on Oct 1.



This guide is for employers and is not legal advice. Always confirm current agency guidance as it is published.

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