U.S. Citizenship and Immigration Services (USCIS) released the Frequently Asked Questions (FAQs) for H-1B Organizational Accounts for the upcoming FY25 process. Below are highlights from USCIS.

General Information

  1. What are the benefits of online H-1B organizational accounts?
    1. Multiple individuals from any entity, whether a company or other group, and their legal representatives can work together on H-1B registrations, Form I-129, Petition for Nonimmigrant Worker, and related Form I-907, Request for Premium Processing Service. These forms will be available to file online.
    2. Case management features for account holders, including an improved design and more efficient process are included.
  2. What is the availability of the organizational accounts?
    1. On February 28, 2024, the online filing of Form I-129 and related Form I-907 for non-cap H-1B petitions will be available.
    2. On April 1, 2024, FY25 H-1B petitions and related Form I-907 will be available for those selected for registration.
  3. How can I prepare for the organizational accounts?
    1. The first step is to determine who the Administrator will be for the company or organization. This role oversees the group for the company and legal representatives. The person selected for this role should have the authority to complete the registrations and petitions for the company, including signing, paying for, and submitting all related documents.
    2. If you chose more than one administrator, determine who has the authority to set the Company Group.
    3. If working with a legal representative, decide who will create the Company Group. Define who will be included in the Company Group in advance.
    4. Determine who will respond to USCIS Request for Evidence (RFE) and Notice of Intent to Deny (NOID) in advance. Only one opportunity is given to respond to these notices. Ensure the group coordinates the response process.
    5. If a company wishes to have more than one Organizational Account, each will need its own Administrator.
  4. How do I create an organizational account if I already have an existing applicant account? Do I need to use a new email to create the organizational account?
    1. Existing H-1B registrant account holders do not need to create a new account. The organizational account features will be available in your existing account if you choose to activate it. Upon login, if you are named the Administrator for the Company Group, you will login and select ‘Create a Company Group’ from the options. This will upgrade your H-1B registrant account to access and use the organizational account features.
    2. If your existing account is an applicant account, this will not include the H-1B electronic registration process. A new online account with new login credentials will need to be created.
  5. What if the wrong account type is selected when creating an online USCIS account? Can I correct that later?
    1. Unfortunately, users will not have the ability to switch to a different account type after creation. Be sure to select Organizational or Legal Representative as appropriate when creating your online account. Only these two account types have access to the H-1B electronic registration process.
    2. You can create a new USCIS online account if you chose the wrong type in the first effort.
  6. How do I access technical support?
    1. An email, H1Btechsupport@uscis.dhs.gov is available for any technical issues faced.
    2. Certain information must be submitted, including the full URL of where the error was received, a screenshot of the page that includes the URL, date and time of issue, receipt number if applicable, and the related email address for the online account.
  7. What are the new roles and permissions for Organizational Accounts?
    1. Here is the table from USCIS.
  8. Can electronic registrations be submitted in the same way as in the past?
    1. Depending on how the Company Group is setup, you can submit registrations in the same manner.
    2. You must be an Administrator of the Company Group account.
    3. Log in to your existing H-1B registrant account.
    4. When you are on the onboarding page, select ‘Create a Company Group’.
    5. After created, you will be the only person in the Company Group.
    6. By being the only person in your Company Group, a similar process is used to submit H-1B registrations as in the past.
    7. You can always invite others to join your Company group, whether Company Members or your legal representative.
  9. Are there changes to the FY25 H-1B electronic registration form?
    1. The form is very similar. Only basic information about the prospective petitioner and beneficiary is required.
    2. However, all H-1B registrants will be REQUIRED to include valid passport information or a valid travel document for each beneficiary. The document must be the same one used to enter the United States. If they are outside the U.S., it must be the document they intend to use upon entering the U.S. if they are selected for the H-1B visa.
    3. The passport or travel document must be current and unexpired.
    4. Each beneficiary must be registered under one and only one passport or travel document.
  10. Can I submit online applications for H-4 dependents concurrently with the online Form I-129 for the principal H-1B prospective employee?
    1. Unfortunately, no, not at this time.
    2. If you wish to concurrently file Form I-539 for H-4 dependents with Form I-129 for the H-1B principal, that must be done via paper filing.
    3. To ensure the paper forms are correctly associated with the online Form I-129 for the principal H-1B beneficiary, submit the Form I-129 first. Then submit the paper Form I-539 and Form I-765, as appropriate, including a printed copy of the online Form I-129 receipt notice.
    4. These forms will not be considered concurrently filed and may be adjudicated separately.
  11. Can I submit premium processing for Form I-129 online?
    1. Yes, you can file both Form I-907 and Form I-129 online.
    2. You can also submit Form I-907 after Form I-129 is submitted.
  12. Can I still file via paper?
    1. Yes, you can continue to file a paper Form I-129 H-1B petition and the related Form I-907 if you like. However, the paper-filed Form I-129 and Form I-907 will not be linked online.
  13. How do processing times compare between paper-filed and online-filed?
    1. There is no difference in processing times.
    2. However, online filing offers time-saving features, including immediate submission versus waiting for the paper documents to be delivered, avoid the standard file creation steps used at lockbox facilities, and faster receipt notice.
    3. Online submissions can receive and respond to RFEs and NOIDs faster through the USCIS online account.
  14. If I file paper-based Form I-129 or associated Form I-907, can I link them to the USCIS account after submission?
    1. No. Paper-filed submissions cannot be linked to an online account. However, this is being planned for future updates.
    2. The filing location for paper Form I-129 H-1B petitions and Form I-907 requests are moving from USCIS service centers to USICS lockboxes.
    3. Do NOT use the same addresses used in the past.
    4. New addresses will be announced in March 2024.

Company FAQs

  1. If I’m asked to be the Administrator for my Company Account, what do I need to do?
    1. Sign into your existing H-1B registrant account.
    2. After login, you will see a new company onboarding page.
    3. Choose ‘Create a Company Group’.
    4. Follow the prompts about the company and yourself. You will need the Employer Identification Number (EIN), Social Security number (SSN), or Individual Taxpayer Identification Number (ITIN) to create the Company Group.
    5. Creating the Company Group takes approximately 3 minutes.
    6. Once completed, the Company Group cannot be removed or changed.
    7. At this point, you are the Administrator. You can invite coworkers or legal representatives to join your group.
  2. If I’m not asked to be an Administrator but have an existing account what do I do?
    1. You must wait for the invitation to join the Company Group, as submitted by the administrator.
    2. When you receive the invitation, click on the link provided. Upon login, the company onboarding page is shown. Select ‘Review your pending invitations’ box.
    3. Follow the prompts.
  3. How do I build the members of the Company Group?
    1. When the administrator invites others to the group, they will select either Administrator or Member.
    2. Each Company Group can have as many Administrators or Members as they like. Each individual can be members of only one Company Account. The unique identifier for each individual is the email address.
    3. Invitations must be accepted within 7 days, otherwise the invitation expires.
    4. Invitations cannot be declined or withdrawn.
    5. If the person invited does not have an existing account, they will need to create a new H-1B registrant account.
    6. If the person invited is already a member of a Company Group as identified by their email address, an error message will be shown to the administrator.
    7. USCIS encourages each Company Group to have 2 administrators.
  4. How do we invite legal representatives to the Company Group?
    1. After login, go to the ‘My Representatives’ tab at the top of the home page.
    2. Select ‘Add a representative’.
    3. Enter the individual’s name and email address.
    4. Send invitation.
  5. What can an Administrator do in the H-1B organizational accounts setting?
    1. Administrators can start, edit, delete, sign, pay for, and submit H-1B registrations, including form I-129, respond to RFEs and NOIDs, and manage the people in the Company Group, as well as adjust roles.
    2. Administrators cannot submit Form G-28, Notice of Entry of Appearance as Attorney or Accredited Representative, nor can they setup the Legal Team. These functions are given to the Representative.
    3. At least one of the Administrators in the Company Group must be the name and electronic signature that is included in H-1B registrations and Form I-129 petitions.
    4. Administrators coordinate with their legal representatives regarding responding to RFEs and NOIDs, if received.
    5. Administrators can submit H-1B registrations and petitions, either independently or with a representative.
  6. Can I add a Legal Representative after the case is submitted?
    1. A legal representative can submit a separate Form G-28 online for a Form I-129 submitted online by the company. This can be done with or without Form I-907.
    2. If the Form I-129 was submitted via paper, the Form G-28 would also need to be submitted via standalone paper submission.
  7. What should be done if an Administrator leaves the role?
    1. For this reason, USCIS strongly recommends having at least 2 Administrators.
    2. If the Company Group has only one Administrator who is leaving the role, prior to leaving, a new Administrator should be chosen and given the role.
  8. Can a large company create multiple Company Groups for each sub-entity?
    1. Yes, as long as a different EIN is assigned to that sub-entity.
  9. Do Company Groups need to be EIN-specific?
    1. No, they do not need to be EIN specific. People from different EIN-assigned entities can join the same Company Group. However, the Administrator that oversees that Company Group must have the authority to complete and submit registrations and forms for all included entities.
  10. Can the beneficiary be included in the Company Group?
    1. There is nothing limiting adding the beneficiary to the Company Group. However, there is no beneficiary role in the Company Group.
    2. Remember, all members of the Company Group can see and edit H-1B registrations and Form I-129 petitions.
    3. Consider privacy issues before making the choice to add beneficiaries.

Legal Representatives FAQs

  1. Can paralegals be on more than one legal team?
    1. For the initial organizational accounts roll out, each paralegal’s unique online account can only be associated with one Legal Team.
    2. This enhancement is being considered for future releases.
  2. Can law firms use their existing case management software using the myUSCIS online platform?
    1. Unfortunately, no. The application programming interface is not yet available.
  3. How should the Legal Team be setup if multiple attorneys submit cases for the same employer? Can we have more than one Legal Team?
    1. Company Groups can work with multiple legal representatives, whether part of the same law firm or not.
    2. Each Legal Team will see only the work performed by themselves. They will not see work submitted by other Legal Teams.
    3. Each individual attorney added as a Legal Representative is considered a Legal Team.
  4. Can the Legal Team prepare and submit H-1B petitions for their company client without an online account?
    1. No, the Legal Team is required to use the online account.
  5. How does a company change their Legal Team after forms are submitted by a different Representative?
    1. The administrator of the Company Group must withdraw the G-28 from all cases where the original Representative is associated.
    2. Then, if they wish, the Administrator can remove that Representative from their Company Group entirely.
    3. The Administrator can add a new Representative at any time.
    4. New Representatives must file a standalone form G-28 for each and every existing case where they are assigned.
  6. Will the Representative have visibility to H-1B registrations started by the company to avoid duplication?
    1. No, representatives do not have visibility to registrations or forms started by the Company Group.
    2. The company must use the duplicate checker and ensure they coordinate offline with their legal representatives to ensure no duplicate registrations are submitted.
  7. Will an invited Legal Team have access to electronic registration selection notices and be able to file Form I-129 H-1B petitions online for those registrations prepared by the company employer?
    1. Only the legal team member that prepared and submitted the H-1B registration for the individual beneficiary will see the selection notice, assuming they are still the attorney of record per the G-28.
    2. However, any legal team member can prepare the online Form I-129 for selected beneficiaries for the company client.
    3. If a new Legal Team member is added after H-1B registration selection notices are sent, the company client will need to work outside the organizational account platform to provide the relevant information for filing.
  8. Can the same Legal Representative create multiple Legal Teams?
    1. Unfortunately, no. A Representative cannot create multiple Legal Teams from one online account.
  9. Can Legal Representatives collaborate with multiple company groups?
    1. Yes. Each Company Group Administrator invites the Legal Representative to collaborate to their individual account.
    2. Attorneys can send registrations to each Administrator for review and submission.

As always, ILBSG is here to support our clients through the ever-evolving landscape of U.S. immigration law and the role of technology. Contact us to find out how we are streamlining the process within the guidelines of the new H-1B Organizational accounts. If you have questions about the FY25 H-1B process or any other immigration-related issue, contact us. Our team of attorneys work directly with clients through the process, ensuring they get the right advice.

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