Policy Advocacy

On August, 24, 2026, the ILRC submitted a comment opposing a proposed rule entitled Naturalization Application Fee Adjustments. The rule seeks to raise the application fee for Form N-400 by 75-80% as well as eliminates the fee waiver and fee reduction for naturalization applications. ILRC opposes this rule given that it will create a substantial barrier for low-income naturalization applicants who could be permanently priced out of citizenship.

On September 28, 2026, the ILRC submitted a comment in opposition of an interim final rule (IFR) entitled Affirmative Asylum Referrals without Interview. This rule will deprive many asylum seekers of their ability to fully present their cases at the asylum office and instead, push them into the immigration court backlog where they face and adversarial system and ever-growing due process violations. ILRC also opposes the issuance of this rule without the notice and comment period required by the Administrative Procedures Act.

On September 22, 2026, the ILRC submitted a comment opposing a proposed USCIS rule to increase the filing for for H-1B Visa petitions. The proposed rule set a filing fee of over $100,000 and also proposed to use the USCIS filing fees for other agencies.

The Immigrant Legal Resource Center (ILRC) submitted a comment to USCIS opposing proposed changes to Form I-130, which would more than double the form’s length and require additional information from petitioners and beneficiaries, including expanded criminal history, employment, education, and family-history questions.

The Immigrant Legal Resource Center (ILRC) submitted a comment strongly opposing the Department of Homeland Security’s Final Rule on “[Immigrant] Registration Form and Evidence of Registration.” The rule expands and formalizes a registration process that could expose millions of immigrants—and potentially U.S. citizens—to increased fear, confusion, racial profiling, and immigration enforcement.

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.

This new policy platform examines how the 1996 laws expanded detention, deportation, and family separation – and outlines a vision for a more just and humane future.

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.