USCIS Expands AR-11 (Change of Address Form): Elevates Employer Exposure

On May 7, 2026, U.S. Citizenship and Immigration Services (USCIS) published a 60-day notice proposing to amend Form AR-11, Alien Change of Address. The proposal would significantly expand the scope of information that foreign nationals must provide when reporting a change of address. The new form includes a requirement to list the “Alien’s” employer. The public comment period is open until July 6, 2026.  The impact on employers is nuanced but significant and follows a growing trend of the government to be tracking and integrating data across systems.

Background

The Immigration and Nationality Act (INA) requires most foreign nationals in the United States to report a change of address to USCIS within 10 days of moving. This obligation is commonly satisfied by filing Form AR-11, either online through a USCIS account or by mail. Historically, the form has served primarily to keep USCIS records current and support compliance with alien registration requirements. Failure to comply carries immigration consequences and monetary penalties.

What Is Changing

USCIS is not proposing to create a new change-of-address reporting requirement; rather, the proposed changes would materially expand the information collected through the existing mandatory requirements. Under the proposal, foreign nationals would be required to disclose:

• Employment or schooling information, including the identity of their current employer; and
• Receipt of means-tested public benefits, consistent with existing statutory and regulatory considerations related to public charge inadmissibility.

These expanded data points may also enhance the government’s ability to identify potential inconsistencies, misrepresentations, or fraud indicators across filings and benefit programs, particularly as systems become more integrated.

USCIS states that the proposed changes aim to support public charge enforcement and compliance with existing benefit restrictions. It is unclear how USCIS would use the employer information, but it could potentially be shared with enforcement components (such as DOJ or ICE) to support employer compliance investigations, including identifying potential targets for Form I-9 audits. Employers should review the Table of Changes and the Draft Form AR-11.  

DHS currently has the ability to report on individuals who have lost work authorization to employers that utilize E-Verify. Specifically, CHNV (Cuba, Haiti, Nicaragua, and Venezuela) revocations are now routinely updated through the CHNV Revocation Report (officially known as the Status Change Report). This E-Verify tool flags employees whose Employment Authorization Documents (EADs) have been terminated following the end of the CHNV humanitarian parole program.

Why This Matters for Employers

• New visibility into employer data. Because foreign national employees would be required to disclose, among other things, employment information as part of a routine address update, USCIS would gain access to more detailed data about which employers are sponsoring or employing noncitizens. Employers should be aware that this information may be used for enforcement or eligibility assessments.  

• Expanded downstream notifications and compliance implications. As DHS continues to integrate data across systems, the inclusion of employer information on Form AR-11 raises the possibility that notifications tied to status changes, like those currently available through E-Verify for CHNV populations, could be expanded beyond the E-Verify platform. In other words, employers that do not participate in E-Verify today could nonetheless become indirectly visible to the government through AR-11 reporting and, over time, may receive or be subject to similar status-linked notifications or downstream enforcement activity. This represents a meaningful shift: historically, proactive alerts regarding work authorization termination have largely been limited to E-Verify users, but broader data collection and interagency sharing could level that distinction. Employers should therefore anticipate a future in which government insight into workforce composition is not limited by program participation and plan compliance strategies accordingly.

• Employee assistance and accuracy. Employers may wish to proactively assist their foreign national employees in completing Form AR-11 accurately and on time, particularly given that errors, omissions, or inconsistencies in filings may carry greater risk if the information is used in an enforcement context. This is particularly important where the employer has sponsored the foreign national’s employment. Errors and omissions on the form can carry immigration consequences, such as delay or denial of future benefit applications, resulting in a work authorization gap or worse, visa revocation.
• Timely address updates. Regardless of whether the proposal is finalized, employers should reiterate to their foreign national employee populations the importance of timely compliance with the existing 10-day address reporting obligation.
• Update hosted links and resources. Employers that host a link to Form AR-11 or related instructions on their website, internal intranet, or employee resource pages should monitor USCIS for publication of the revised form. Once finalized, the new version will likely replace the current form, and outdated links or materials could lead employees to file on a superseded version, potentially creating compliance issues.

• Heightened scrutiny of cross-filing consistency. Employers should also be mindful that expanded data collection increases the likelihood that inconsistencies between AR-11 filings and other immigration records (e.g., petitions, labor condition applications, or benefit requests) may be identified and scrutinized.

Recommended Next Steps

1. Monitor the rulemaking. We will continue to track developments and will provide updates if the proposed changes are finalized.
2. Consider submitting a public comment. The comment period is open until July 6, 2026. Employers and industry stakeholders who wish to weigh in on the proposed changes have an opportunity to do so. Our team is available to assist in preparing and submitting comments on the proposed rulemaking and can also share information with larger associations that may consider commenting.
3. Review internal mobility and relocation processes to ensure AR-11 compliance is incorporated when sponsored employees move. Concomitantly, employers should be reminding sponsored foreign national employees (such as those on an H-1B visa) to report changes work location (and related address) to the employer immediately because such changes may necessitate a visa amendment.
4. Remind foreign national employees of their obligation to file Form AR-11 within 10 days of any address change.
5. Audit internal resources (where applicable) to identify any hosted links to the current Form AR-11 that will need to be updated when the revised version is published.
6. Assess implications of expanded data collection and sharing. Employers should evaluate how increased data aggregation and interagency information sharing may affect their immigration compliance posture and risk profile. As USCIS collects more detailed information, potentially linking employee identity, work authorization, benefits usage, and employer affiliation, there is a heightened likelihood that discrepancies or compliance gaps could be surfaced across systems and agencies. Employers may wish to conduct proactive internal reviews of I-9 processes, public access files, and sponsorship records to ensure consistency and defensibility, and to align internal stakeholders (HR, legal, compliance) around an increasingly data-driven enforcement environment.

While the proposed changes to Form AR-11 reflect a broader shift toward increased data collection and interagency visibility, the goal is not to be alarmist. Rather, this development is best viewed as part of an evolving compliance landscape in which government systems are becoming more integrated and capable of cross-referencing information in new ways. For employers, the practical takeaway is the importance of preparation, consistency, and proactive risk management.

As these changes continue to unfold, we are focused on helping employers understand not just what is required today, but what may be coming next, providing forward-looking guidance that allows employers to “peek around corners” and adapt with confidence. Our team will continue to monitor developments closely and partner with clients to navigate these changes in a way that is measured, compliant, and aligned with business priorities.

For more information, contact the authors or your Seyfarth relationship partner directly. Seyfarth’s Immigration Compliance & Investigations specialty group is recognized as a national leader in the field. Trusted by Fortune 100 companies and small businesses nationwide, the team provides strategic, practical guidance across the full spectrum of immigration compliance. The group advises on Form I-9 and E-Verify compliance; ICE inspections and worksite enforcement actions; internal immigration assessments and I-9 audits; DOL immigration-related wage-and-hour investigations; H-1B compliance; and DOJ’s IER and OCAHO anti-discrimination matters, including foreign sponsorship and export control/ITAR issues. The team complements its expertise in the Immigration Compliance & Investigations sector with its first-in-class litigation capabilities. For additional timely updates on all things immigration, subscribe to Seyfarth’s dedicated immigration blog at throughtheimmigrationlens.com.