Policy Advocacy

On November 2, 2026, the Immigrant Legal Resource Center submitted a comment in strong opposition to ICE's Information Collection Activity, "Suspicious/Criminal Activity Tip Reporting" (OMB No. 1653-0049), published in the Federal Register on October 5, 2026. ILRC argues the activity violates the Paperwork Reduction Act because ICE never published the proposed form during the required 60-day and 30-day comment periods, and did not respond to ILRC's October 14 request for a copy. Beyond the procedural objection, ILRC contends the form would funnel more people into the deportation pipeline, undermine due process, invite abuse by individuals motivated by bias or white supremacist ideology, and be weaponized in domestic violence cases against immigrant survivors. ILRC urges ICE to abandon the form.

On October 12, 2026, the Immigrant Legal Resource Center (ILRC) submitted a comment opposing a new Department of Homeland Security (DHS) interim final rule that would make electronic filing mandatory for immigration benefit applications, along with a proposed form requiring applicants to request a waiver from that requirement.

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.