USCIS Policy Memo - USCIS pauses benefit applications for individuals from 39 countries listed in Presidential Proclamation (PP) 10998 and re-reviews approvals since Jan. 20, 2021
1 January 2026
On January 1, 2026, USCIS issued a policy memo which builds upon the agency’s previous policy memo, dated December 2, 2025, by expanding the pause on all benefit requests pending with USCIS, submitted by or for individuals who list one of the restricted countries in the December 16, 2025, Presidential Proclamation (PP) 10998, as either their country of birth, their country of citizenship, who have acquired Citizenship by Investment (CBI) from one of the listed countries, or or who carry a travel document issued or endorsed by the Palestinian Authority, with very limited exceptions. The pause will remain in effect until further notice.
The January 1, 2026 policy memo also requires USCIS to conduct a comprehensive re-review of approved benefit requests for individuals from all the countries restricted by PP 10998 that were approved on or after January 20, 2021. As part of this re-review, affected individuals may receive requests for additional interviews, documentation, or further background checks.
Impact of Adjudication Pause and Re-Review Policy on International Students and Scholars
This policy will likely cause delays in the processing of USCIS benefits applications for individuals who were born in or are citizens of one of the countries restricted by PP10998, even if the individual holds dual citizenship with a country that is not restricted by PP10998. Some examples of potentially impacted applications include applications for Optional Practical Training (OPT) (Form I-765), applications to change status (Form I-539) and applications to register permanent residency or adjust status (Form I-485), among others.
Requests which are handled directly by university DSOs, such as requests for Curricular Practical Training (CPT) or Form I-20- F-1 extensions, are not impacted by this policy.
If you were born in, or are a citizen of, one of the countries restricted by PP 10998, and have a pending application with USCIS, please consult with your school’s DSO or A/RO in the International Students Office on your campus regarding the impact of possible delays. Depending on your specific situation, you may wish to consult with an immigration attorney to evaluate your situation and discuss your potential options. You can contact our Help Desk if you have questions.
Legal Challenge
A lawsuit challenging this policy is expected. IMMpact Litigation has stated that it is preparing a legal case concerning the policy and its impact on individuals from the 39 countries listed in PP 10998. More details about the lawsuit are available here.
Resources
For more details about the entry restrictions imposed by PP 10998, please see our Insights Report.
