Comment to Proposed EAD Rules
The Advocates for Human Rights (“the Advocates”), submits this
comment related to DHS Docket No. USCIS–2025–0370 and urges the Department of Homeland
Security (the “Department”) to withdraw the Notice of Proposed Rulemaking (“NPRM”) in its
entirety. See Employment Authorization Reform for Asylum Applicants, 91 Fed. Reg. 8616 (Feb.
23, 2026) (DHS Docket No. USCIS-2025-0370). The NPRM would make sweeping changes to
employment authorization for pending asylum applicants, including a potentially indefinite pause
on new Employment Authorization Document (“EAD”) applications, a tripled waiting period,
new discretionary and arbitrary eligibility barriers, and extended processing timeframes.
