RE: DHS Docket No. USCIS-2025-0370, “Employment Authorization Reform for Asylum Applicants”

Maine’s economy is tied to the successful integration of immigrant communities, including asylum seekers. Delays in work authorization undermine workforce development efforts in critical sectors facing labor shortages, increase reliance on already strained municipal systems such as General Assistance, and create unnecessary barriers to self-sufficiency for individuals who are already legally permitted to remain in the U.S. while their cases proceed.​

The proposed rule change will cause many asylum seekers to lose or fail to obtain work permits, destabilizing families, communities, and regional economies. By extending the wait to 365 days and allowing 180-day processing delays, work authorization will be delayed due to agency backlogs, not individual eligibility. Mandatory biometrics for renewals adds further burden and risk of denial.​

The proposed rule would indefinitely bar people who seek asylum after the rule goes into effect from applying for authorization to work legally during their years-long legal process.

If implemented, the asylum work permit rule would halt the processing of initial applications for work permits until U.S. Citizenship and Immigration Services’ (USCIS)​ can process all affirmative asylum applications within an average of 6 months.

As stated in the notice, processing times in recent years have averaged between 22-35 months. DHS estimates that the pause on initial applications could last from 14 to 173 years or longer.

Additionally, this proposed asylum work permit rule would create new, onerous requirements to renew work authorization for those who already have it, and expand USCIS authority to deny applications for work permits based solely on agents’ discretion.

This new regulation would also increase the time those seeking asylum must wait before they are eligible to apply for work authorization from 5 months to 1 year.

Three reasons why this matters:

1. Major labor-market disruptions.
Roughly 2.3 million adults are already legally working while completing the asylum process, helping to fill essential roles in industries facing widespread labor shortages, including in food, construction, and transportation. Preventing large numbers of these individuals from renewing their work permits and barring new workers from joining them will worsen labor shortages and disrupt production and services for everyday Americans.

2. Rising inflation.
Labor and operating costs for businesses of all sizes will increase as employers lose experienced workers and struggle to fill vacancies. Costs will be passed on to everyday Americans who will have to pay even more for housing, healthcare, and basic goods and services, while some businesses will have to slow or stop production and expansion. Inflation will drive prices higher.

3. Significant economic loss.
People with temporary status, including those with an active asylum claim, pay an estimated $25.7 billion each year in federal, state, and local taxes. These tax dollars pay our teachers and first responders, infrastructure like roads and bridges, and key programs like Medicare and Social Security. Cutting off this revenue stream would undermine economic stability and weaken the government’s capacity to sustain essential public services and programs.