Policy Advocacy

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.

For more than two years, advocates have decried Texas SB 4 (2023), a law that creates new state offenses of illegal entry, reentry, and failure to comply with a state removal order. As of May 29, 2026, the law is fully in effect, bringing all Texans and those suspected of being undocumented under the permanent threat of immediate detention and deportation by the state, should they be suspected of violating the law. Texas SB 4 represents an unheard-of state usurpation of federal law, violating constitutional principles and norms that govern how states interact with the federal government. This policy brief breaks down the law and shares how communities can best prepare for a world with Texas SB 4 on the books.

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.