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What U.S. employers need to know about USCIS’s proposed AR-11 overhaul

August 2026 employment law letter
Authors: 

Benjamin A. Nucci, Snell & Wilmer

U.S. Citizenship and Immigration Services (USCIS) has proposed significant changes to Form AR-11, the address change form that most foreign nationals in the United States must file within 10 days of moving. Although the address reporting obligation is long-standing, the proposed revisions would expand the form well beyond a routine address update, collecting employment, schooling, and public benefits information that could increase the visibility of employer identity across government records.

The proposal hasn’t been finalized, and the USCIS is accepting public comments through July 6, 2026. This alert summarizes the key changes, explains why they matter for employers, and identifies practical steps HR, global mobility, and legal teams should consider now.

How Form AR-11 works today

Under current law, most foreign nationals present in the United States must notify the USCIS of any address change within 10 days. The existing AR-11 form is straightforward: It collects the individual’s name, date of birth, immigration status, and previous and new addresses. Failure to comply can result in fines up to $5,000; imprisonment; or removal proceedings.

Because the form captures limited information, it has historically attracted little employer attention. The proposed revisions would change that dynamic.

What the proposed form would require

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