On June 20, 2025, U.S. Citizenship and Immigration Services (USCIS) issued updated guidance to E-Verify employers regarding the revocation of Employment Authorization Documents (EADs) for individuals who entered under the CHNV (Cuba, Haiti, Nicaragua, and Venezuela) Humanitarian Parole program. This guidance comes as the Department of Homeland Security (DHS) resumes parole terminations following significant legal developments.
Earlier this spring, a federal district court in Massachusetts issued a nationwide preliminary injunction, blocking DHS from moving forward with CHNV terminations and related EAD revocations. But the pause was short-lived. On May 30, 2025, the U.S. Supreme Court stayed that injunction, allowing DHS to continue terminating parole and revoking work authorization while the case remains pending in the First Circuit. Seyfarth outlined the saga in a prior blog: CHNV Parole Update: SCOTUS Grants Stay, Terminations May Proceed — But Implementation Unclear.
As a result, over 530,000 CHNV parolees, who were issued valid EADs and lawfully completed Forms I-9 at the time of hire, may now be deemed unauthorized to work. Many employers hired these individuals in good faith, often unaware of the program's underlying fragility and the potential operational implications. The responsibility to address this shift now falls squarely on employers, particularly those enrolled in E-Verify.
What USCIS Is Requiring from Employers
To assist employers with identifying revoked EADs, USCIS has created a self-service reporting functionality (Status Change Report), and has directed E-Verify employers to pull down reports and then reverify affected employees "within a reasonable amount of time." However, the guidance lacks specificity, and the tools provided are limited. To limit PII issues, the Report currently lists only E-Verify Case Numbers and A numbers, crucially omitting employee names. This forces employers to manually reconcile these numbers with internal HR records, a time-consuming and error-prone process.
This leaves employers to reconcile a technical report against their internal HR records, which for many will require substantial manual effort. Employers are also expected to regularly generate this report to identify cases linked to revoked EADs, seemingly related to case-by-case case revocations generated by Customs and Border Protection (CBP).
Late Friday, USCIS posted an update in the "What's New" for E-Verify Users Following Parole Termination and EAD Revocation noting that the current report includes all revocations from April 9 through June 13. While the original chart on the USCIS webpage incorrectly implied a different date range, they corrected to reflect the earlier date this morning, June 23.
Accessing and Using the Status Change Report
Direct E-Verify Users: Log into the E-Verify portal, navigate to the Reports tab, and select the Status Change Report. Export the file (CSV or Excel) and cross-reference the case numbers with your employee records.
Employer Agents or Vendors: If your organization uses a third-party E-Verify agent, you must request the report from them. Ask whether they can assist in mapping the case numbers to employee identities and whether they offer enhanced reporting features, such as overlays with names, locations, or employment status.
Employers should immediately confirm:
- Whether the vendor can access and deliver the report;
- The expected turnaround time;
- Whether the vendor can assist with data matching;
- Whether any automation or alerts are available in their system.
Regardless of the setup, the legal obligation to complete reverification and maintain compliance remains with the employer.
Compliance Risks and Unanswered Questions
The USCIS guidance leaves several critical issues unresolved. Notably, the term "reasonable amount of time" remains undefined, creating uncertainty for employers, especially those managing large or multi-site workforces. We expect that most employers will download the reports early this week and begin issuing notifications, likely allowing only a short turnaround time for reverification. Employers should carefully consider the appropriate timeframe for action, balancing both risk tolerance and operational impact with competent legal counsel.
Employers not enrolled in E-Verify face even greater uncertainty, as they have no formal way to identify affected employees. Some are choosing not to act unless an employee self-identifies. Others, if they retain copies of List A documents, are reviewing EADs for C11 category codes and meeting with employees to confirm whether the EAD is tied to CHNV. That said, this approach is viewed by many as extreme, especially since some employers do not retain document copies (albeit a best practice) and have no reliable way to identify impacted individuals.
The underlying concern is how Immigration and Customs Enforcement (ICE) will respond. Will enforcement target only employees with revoked work authorization, or could employers also face scrutiny for continuing to employ individuals whose parole or EADs were quietly revoked? This ambiguity leaves non–E-Verify employers in a precarious position, with no clear guidance on how to proceed.
Operational and Labor Market Impact
This compliance burden comes amid ongoing labor shortages in key sectors such as hospitality, construction, agriculture, logistics, and health care—industries where CHNV parolees are heavily represented. The sudden loss of a previously authorized workforce, combined with increased I-9 audits and enforcement, poses a serious threat to business continuity.
What E-Verify Employers Should Do Now
In the absence of clear timelines or automated alerts, employers must act proactively:
- "Direct" E-Verify users: Generate the Status Change Report and begin mapping case numbers to employees.
- Employer Agent/Web Services E-Verify users: Contact your agent immediately to request the report and coordinate a data-matching strategy.
Begin planning reverification efforts and document every step taken. This documentation may be critical in the event of an ICE audit.
Final Thoughts
Although the CHNV litigation is still ongoing, the Supreme Court's stay allows DHS to proceed with terminating parole and revoking EADs. Now, employers must respond. Given the continued lack of clarity around key aspects of the process, employers should coordinate closely with internal stakeholders and legal counsel to set expectations, define timelines, and assign responsibilities, both for E-Verify and non–E-Verify settings.
Aside from minor updates, no additional substantive guidance from USCIS is expected. Taking timely, well-documented steps to identify and reverify affected employees is essential to mitigating compliance risks and maintaining operational continuity.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
