ILRC Comment Opposing USCIS's Rule Eliminating Auto-Extension of Employment Authorization

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ILRC submitted this comment on November 25, 2025 opposing the Interim Final Rule (IFR) eliminating automatic extensions of Employment Authorization Documents (“EADs”). The IFR was improvidently issued without prior notice and comment, is unsupported by data or reasoned analysis, and falsely claims that it is part of a foreign affairs exception intended for regulations which impact international policies.

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ILRC-Comment-IFR.pdf
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