United States • • • 🌿 Progressive

Formulario I-485 impreso sobre una mesa, junto a un bolígrafo
El Formulario I-485 de USCIS, Application to Register Permanent Residence or Adjust Status, con número de control OMB 1615-0023. · El Tecolote

USCIS proposes extending the Form I-485 collection without change

USCIS proposes extending the Form I-485 collection and its supplements without change, with comments until December 22, 2026, and an estimated annual burden of…

--- The context --- U.S. Citizenship and Immigration Services (USCIS) published a 60-day notice in the Federal Register on October 23, 2026, concerning Form I-485, the Application to Register Permanent Residence or Adjust Status, the central filing for legal residence inside the United States. --- The facts --- The notice proposes extending, without change, a currently approved collection of information: Form I-485 itself, its Supplement A (adjustment under section 245(i) of the Immigration and Nationality Act), its Supplement J (confirmation of a bona fide job offer or job portability under section 204(j)) and the National Interest Waiver for physicians. The control number is OMB 1615-0023 and the docket is USCIS-2009-0020. The affected public is primarily individuals or households who use the form to request and determine eligibility for adjustment of status to permanent resident. Comments are accepted for 60 days until December 22, 2026, through the Federal eRulemaking Portal (regulations.gov), including OMB Control Number 1615-0023 and Docket ID USCIS-2009-0020. --- The positions --- The agency presents the extension as a continuity step under the Paperwork Reduction Act of 1995: the collection already exists, the current form is not modified, and the comment period serves to evaluate whether the collection is necessary, whether the estimated burden is accurate and how to minimize it. The figures the agency itself puts forward show the scale of that burden: 791,897 paper I-485 responses at 6.86 hours per response and the online responses at 6.09 hours, with a total estimated annual burden of 8,391,317 hours and an estimated annual cost of $363,993,315. --- What remains unknown --- The notice announces no change to the form or to the requirements: it is a proposal in a comment period. What remains unknown is what comments the agency will receive and whether the extension will be approved as proposed when the period closes on December 22, 2026. --- Unanswered questions --- Will the agency receive comments challenging the accuracy of its estimated burden of 8,391,317 hours a year? Will the extension be approved without change when the period closes? Will USCIS reduce any part of the burden, such as the 1.17 hours per biometrics processing for 1,061,205 people? --- EPM analysis --- The notice's breakdown also adds 33,636 Supplement A responses at 0.88 hours, 57,353 Supplement J responses at 0.60 hours and 5,343 PDFi I-485 responses at 6.86 hours, plus 11,212 online Supplement A responses at 0.81 hours. These are the agency's official estimates for a collection that touches more than a million people a year across forms and biometrics. 📌 EPM Take: In EPM's view, what matters in this notice is what does not change: Form I-485 and its supplements would stay the same, and anyone with a pending process faces no new requirements because of this publication. It is a proposal in a comment period, not a new rule in force. That said, an estimated burden of 8,391,317 hours and $363,993,315 a year deserves real public scrutiny: the period until December 22, 2026, is the formal channel to challenge those figures under docket USCIS-2009-0020. This is not legal advice.
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