The Immigrant Legal Resource Center (ILRC) submitted a comment urging DHS to withdraw its proposed rule that would dramatically restrict access to employment authorization for many immigrants.
On April 8, 2026, the ILRC submitted a comment in response to a proposed federal immigration rule that would sharply limit appeals to the Board of Immigration Appeals, arguing that it would weaken due process protections for people facing removal.
The comment explains that denying applications after they have already been accepted can result in the loss of filing fees, lengthy delays, and even permanent loss of immigration benefits when eligibility depends on the original filing date.
On June 29, 2026, the Immigrant Legal Resource Center (ILRC) submitted comments urging USCIS to withdraw its proposed revisions to Form N-648, the Medical Certification for Disability Exceptions used by naturalization applicants seeking a waiver of the English and civics requirements based on disability. ILRC commented that the proposed revisions unlawfully impose new eligibility standards that are not authorized by the Immigration and Nationality Act, federal regulations, or USCIS's own Policy Manual.
The Immigrant Legal Resource Center (ILRC) submitted comments opposing the Department of Homeland Security's proposed rule to increase the filing fee for Form I-246, the Application for a Stay of Deportation or Removal, from $155 to $755. The comment provides that the proposed 387% fee increase is arbitrary and capricious under the Administrative Procedure Act because DHS fails to provide a reasoned justification for the increase or adequately consider its devastating impact on immigrants seeking protection from deportation.
On June 24, 2026, the ILRC submitted a comment opposing proposed changes to the USCIS change of address Form AR-11.
On June 22, 2026, the Immigrant Legal Resource Center (ILRC) submitted a comment opposing ICE’s proposed rule to increase the fee imposed on individuals ordered removed in absentia from $5,130 to $18,000.
On May 4, 2026, The Immigrant Legal Resource Center (ILRC) submitted a formal comment opposing proposed changes to the EOIR-33 change-of-address form, arguing that the revisions are procedurally improper and substantively harmful.
On April 23, 2026, the Immigrant Legal Resource Center (ILRC) submitted a comment opposing a proposed rule that would significantly limit work authorization for asylum seekers. The ILRC comments that the rule would drastically restrict access to work permits and make it nearly impossible for many asylum seekers to survive while their cases are pending. It highlights that the proposal would lengthen wait times, add new eligibility barriers, and allow broad discretionary denials, effectively undermining the asylum system and deterring legitimate applicants. The ILRC contends the rule would cause severe economic, social, and health harms, including lost wages, increased exploitation, family instability, and reduced access to legal representation and basic services, while also disproportionately harming immigrants of color. Additionally, the ILRC criticizes related form changes as unlawful and overly burdensome, concluding that the proposal lacks evidence to support its stated goals and urging DHS and USCIS to withdraw it entirely.
The U.S. Department of Justice transferred out all permanent staff from the Recognition and Accreditation program in March 2026, rendering the future of the program uncertain. ILRC wrote to DOJ demanding reinstatement of staff and a return to reasonable processing times for applications.