By John Fay
On December 12, 2025, the Department of Homeland Security (DHS) announced the termination of all Family Reunification Parole (FRP) programs, impacting individuals from Colombia, Cuba, Ecuador, El Salvador, Guatemala, Haiti, and Honduras. Following closely on the heels of recent restrictions to Employment Authorization Document (EAD) validity periods and automatic extensions, this move could affect thousands of current workers in the U.S. with FRP-based employment authorization. Here’s what HR and compliance teams should consider with respect to their I-9 management programs.
Executive Summary
The Action: As of December 12, 2025, DHS is terminating the FRP programs that allowed certain individuals from the seven countries listed above to enter the U.S. and work while waiting for family-based immigrant visas. A Federal Register provides more details.
The Timeline: For individuals already in the U.S. under these programs, their parole status will generally terminate on Jan. 14, 2026 (30 days after the Federal Register publication date), unless they have a pending adjustment of status application (Form I-485) that was postmarked or electronically filed on or before Dec. 15, 2025.
The Employer Impact: DHS intends to revoke the EADs associated with this parole. This creates a compliance challenge where employees may possess EADs that appear valid on their face for several more years but are effectively invalid.
What Was Family Reunification Parole?
The Family Reunification Parole (FRP) processes were designed to allow certain beneficiaries of approved family-based immigrant visa petitions to come to the United States on a case-by-case basis. Instead of waiting outside the U.S. for their visa priority dates to become current, these individuals were "paroled" into the U.S., where they could apply for work authorization under the (c)(11) category while waiting to apply for lawful permanent resident status.
The termination applies to both the "modernized" FRP processes established in 2023 and the "legacy" programs for Cuba (2007) and Haiti (2014).
The Scope of the Change
According to the Federal Register Notice, approximately 15,000 individuals have been paroled into the U.S. under the modernized and updated programs since mid-2023. Additionally, there are thousands of pending applications that will now be non-confirmed or denied. While 15,000 may seem like a small number nationally, employers with significant populations of workers from the seven countries impacted may see a disproportionate effect.
The Compliance Conundrum: "Facially Valid" EADs
The most difficult aspect of this termination for employers could be the discrepancy between the expiration date on the physical EAD and the individual’s actual status.
Under the modernized FRP programs, parole was typically granted for an initial period of three years. This means many of these employees currently hold EADs with expiration dates ranging from 2026 to late 2027.
However, the Federal Register Notice explicitly states that DHS intends to revoke these EADs “consistent with the revocation on notice procedures” in the regulations. This leaves employers in a precarious position: holding a Form I-9 with a document that looks valid for another year or two, while the underlying work authorization has been revoked.
If this scenario sounds familiar, that’s because employers faced a very similar challenge earlier this year when DHS terminated the CHNV parole programs for Cubans, Haitians, Nicaraguans, and Venezuelans. Just like with CHNV, DHS has determined these categorical parole programs no longer align with US enforcement priorities and is effectively cutting them short for many individuals.
Following the termination of the CHNV parole programs earlier this year, DHS directed employers to use the E-Verify Status Change Report to identify revoked EADs of previously verified employees. While the latest announcement regarding FRP does not explicitly mention this report, the circumstances (categorical parole termination and mid-validity EAD revocation) are nearly identical. For the latest information on EAD revocations which have been loaded into the E-Verify system, employers can visit the USCIS EAD Revocation Guidance For E-Verify Employers web page.
Given the possibility of FRP-based EAD revocations, employers might want to consider some of the following potential I-9 strategies:
1. Identify Potential Exposure (seek guidance from your legal counsel and other experts): employers using electronic I-9 applications may be able to generate reports to help identify employees who presented an EAD (Form I-766) with the category code (c)(11) from these seven countries. While this data may provide a helpful baseline for understanding potential exposure, it is important to note that the (c)(11) category may include individuals whose work authorization is unrelated to the terminated FRP program.
2. Watch for E-Verify Status Change Revocations: participating E-Verify employers should already be in the habit of regularly checking this report per the E-Verify policy instructions announced earlier this summer. Employers accessing the E-Verify site directly can login and generate the report; employers using an E-Verify agent (such as an electronic I-9 vendor) can receive this information directly from their vendor.
3. Don't Assume An Employee Lacks Work Authorization: it is important to remember that losing parole status does not necessarily mean the employee has lost all work authorization. The Federal Register Notice provides an exception for FRP parolees who have a pending Form I-485 (Adjustment of Status) that is postmarked or electronically filed on or before Dec. 15, 2025. These individuals may still be authorized to work or may have received a new EAD under a different category (such as (c)(9)). As a reverification best practice, employers should provide the employee an opportunity to present new or alternative evidence of employment eligibility before taking adverse action after seeking guidance from your legal counsel and other experts.
4. Prepare Your Teams: inform your local HR teams and I-9 completers that a government revocation notice (whether via E-Verify or a letter presented by the employee) may override the expiration date printed on the EAD card. They should be familiar with the reverification process and the special pending I-485 allowance for terminated FRPs mentioned above. When in doubt, employers should consider working with their counsel.
This termination is the latest in a series of rapid changes to immigration and Forms I-9 compliance in 2025, from the elimination of certain automatic extensions to the shortening of EAD validity periods. As DHS continues to adjust its enforcement priorities, the gap between "standard" I-9 processing and the reality of complex status changes continues to widen.
If you need assistance managing your I-9s, tracking complex expiration dates, or monitoring E-Verify changes, Equifax Workforce Solutions can help you better automate and streamline your I-9 management program.
Contact us today to learn more about our I-9 Management and E-Verify solutions.
Disclaimer: This blog is intended for informational purposes only and does not constitute legal advice. Employers should consult with their own legal counsel regarding specific immigration and compliance matters.