Publication
Beyond Address Changes: What USCIS’s Proposed AR-11 Overhaul Means for Employers
U.S. Citizenship and Immigration Services (USCIS) recently proposed major changes to Form AR-11 — the form that foreign national employees must file whenever they move to a new address. The government is accepting public feedback on this proposal until July 6, 2026. The requirement to report an address change within ten (10) days is not new, but the proposal would significantly increase the amount of information collected and could have implications for employers.
This alert provides a general overview of the proposal, key changes, and issues HR and mobility teams may want to monitor.
How It Works Today
Most foreign nationals in the United States must file the Form AR-11 to report any address change to USCIS within ten (10) days of moving. Missing this deadline can result in fines up to $5,000, jail time, and/or significant impacts to their immigration status, including being placed in deportation proceedings. Until now, the form was simple — it just required the foreign national to list their name, date of birth, immigration status, and old and new addresses.
What the New Form Would Require
The draft of the revised form adds several new sections that ask for additional personal, employment-related, and immigration-related information. The form also asks whether the foreign national has received certain public benefits and advises that USCIS may compare the information against records maintained by other federal agencies. See Regulations.gov for proposed revised form.
Why This May Matter for Employers
These changes may have practical consequences for companies that employ foreign national workers.
- Employer information would be captured in government records. Each time a foreign national employee moves and files the revised form, the employee would be required to list the company’s name and address. For companies with mobile workforces, this could create a recurring record of employer information that may be shared with law enforcement or other agencies.
- Inconsistent information could receive closer review. Employer names on the Form AR-11 may be compared against visa petitions, labor applications, I-9 records, and benefits databases. If an employee lists a different employer than what appears on a petition, that inconsistency could receive additional attention.
- Benefits data may be relevant to future immigration filings. AR-11 responses about government benefits may be considered in public charge-related reviews, which can affect certain future immigration applications.
- Accuracy remains important. Fines up to $5,000, jail time, or deportation can result from noncompliance or inaccuracies. The form is signed under penalty of perjury, and the filer must authorize USCIS to access records for enforcement purposes. Errors may have immigration consequences for the employee and operational consequences for the employer.
Key Considerations
HR and mobility teams should consider noting the following:
- Public comments. The comment period remains open through July 6, 2026, for stakeholders that wish to provide feedback on the proposal. See Regulations.gov
- Employee communications. HR and mobility teams may consider informing foreign national employees now, that the form could change and that employer information reported on the form should be consistent with immigration filings.
- Relocation processes. Employers that transfer employees internally within the United States should consider reviewing their processes now to determine whether they address AR-11 reporting and related worksite-change considerations for sponsored employees.
- Record consistency. Employers may wish to conduct an audit to review whether employer information in petitions, I-9 files, and labor condition applications is consistent with the information employees would report on the Form AR-11.
- Regulatory monitoring. Regulations.gov (Docket No. USCIS-2008-0018) will reflect updates on the proposal and any final version of the form.
- Internal resources. Employers with intranet pages, employee resource materials, and hosted links to Form AR-11 may need updating if a revised form is finalized.
The proposed revisions would change Form AR-11 from a basic address-change form into a broader collection tool for employment and benefits information. USCIS states that this data may be used for deportability determinations, benefits-restriction enforcement, and information sharing across agencies. For employers, the proposal is best understood as a development to monitor in connection with workforce mobility, immigration recordkeeping, and internal employee-facing resources.
About Snell & Wilmer
Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 17 locations throughout the United States and in Mexico, including Phoenix and Tucson, Arizona; Los Angeles, Orange County, Palo Alto and San Diego, California; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno-Tahoe, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
