Financial Firms Face Outsized Impact From Trump’s H-1B Overhaul

(UNITED STATES) Financial firms across the United States 🇺🇸 are bracing for sharp changes after President Trump’s September 19, 2025 H-1B overhaul introduced a new $100,000 fee on all new H-1B petitions filed after 12:01 a.m. EDT on September 21, 2025. The fee applies to new cases only — including petitions connected to the 2026 H-1B lottery — and does not apply to renewals or petitions filed before the effective date. The policy is set to run for 12 months unless extended and is meant to steer visas toward higher-paid, higher-skilled roles while addressing concerns about wage pressure on U.S. workers.

According to analysis by VisaVerge.com, the rule lands hardest on Wall Street and major card networks, where H-1B workers power tech platforms, quant models, risk engines, and automated trading systems that keep markets and payments running.

Immediate financial impact

The immediate impact centers on cost. For banks, card issuers, asset managers, hedge funds, and consulting giants, a $100,000 fee per new H-1B petition radically changes hiring math — especially for entry-level and junior analyst roles.

• Tech giants with wider margins may absorb the hit more easily.
• Large banks, operating under tight capital rules, face constrained operating leeway, making each foreign hire a heavier decision.
• In 2025 alone, the top 10 U.S. financial firms received about 12,000 H-1B visas, with JPMorgan Chase accounting for 2,440.

JPMorgan CEO Jamie Dimon said the move “caught everyone off guard,” reflecting how few companies budgeted for such a large, sudden charge. The fee is expected to push firms to slash new H-1B entries for junior jobs and reserve filings for only the hardest-to-find specialists.

Policy changes overview

Under the current policy:

• The $100,000 fee is a one-time charge applied to each new H-1B petition submitted to USCIS after 12:01 a.m. EDT on September 21, 2025.
• Petitions filed earlier are not affected. H-1B extensions, amendments without a change of employer, and transfers filed before the cutoff remain outside the fee’s scope.
• The rule covers:
  • New cap-subject filings tied to the next lottery cycle.
  • New cap-exempt filings (e.g., some nonprofits, universities), unless a later agency notice excludes them.
• Federal agencies (Department of State, USCIS, and CBP) issued clarifying guidance confirming current H-1B holders and those with petitions already on file may continue their status and travel based on past approvals without paying the new charge.

Supporters say the change raises the bar for H-1B use, ensuring employers sponsor only when skill sets are rare and pay levels are high. Critics call it a blunt instrument that penalizes sectors relying on advanced skills — cloud security, quantitative finance, and machine learning — where domestic talent is thin. Although the policy window is 12 months, many employers worry about extensions and resulting year-over-year uncertainty.

Filing process and official resources

This fee is separate from standard USCIS charges and fraud prevention fees that already apply to H-1B filings. Companies must still submit a full petition package led by Form I-129 (Petition for a Nonimmigrant Worker), which carries its own fees and documentary requirements.

Key official resources:
– USCIS H-1B information page: USCIS: H-1B Specialty Occupations
– Petition form: USCIS: Form I-129, Petition for a Nonimmigrant Worker

Employers preparing new filings should consult Form I-129 instructions and confirm updated fee schedules and policy notes posted by USCIS.

Timing pressures for financial firms

The timing is especially hard for financial firms. Many hire in cycles tied to graduation dates and market needs, with H-1B lottery planning typically starting months in advance. With the new fee kicking in right before the 2026 cap season, employers face three main choices:

1. Downsize H-1B participation.
2. Pass on junior overseas talent.
3. Pay the fee for a small number of high-impact roles.

Company counsel report revising campus offers, canceling H-1B plans for junior analysts and developers, and concentrating filings on hard-to-replace experts in areas like risk quant, ultra-low-latency trading, cryptography, real-time fraud models, and core cloud infrastructure.

Financial firms face outsized effects

America’s largest financial firms are among the biggest users of the H-1B program. Firms like JPMorgan, Goldman Sachs, Citigroup, Bank of America, Morgan Stanley, and American Express — plus major asset managers and card networks — rely on H-1B hires for:

• Building and securing trading systems
• Maintaining global payment rails
• Modeling risk across portfolios

2025 average H-1B salaries in key firms:
– JPMorgan: ~$160,567
– Goldman Sachs: ~$126,495
– Deloitte: ~$139,704

These figures reflect the premium for technical skills but also highlight cost structures that now must absorb the $100,000 fee per new petition.

Three pressure points

• Cost thresholds: For junior programmers, risk ops analysts, or support engineers, the $100,000 fee may exceed a first-year hire’s business value.
• Talent pipeline disruption: Quant finance and banking tech draw heavily from international graduates moving from F-1 OPT to H-1B. The fee acts as a barrier at the moment employers decide whether to sponsor these graduates.
• Shifts in location strategy: Firms may move functions to Canada 🇨🇦 or other countries with friendlier visa policies, especially for cloud engineering, model validation, and data engineering.

Some employers predict a surge in offshoring for routine and junior roles, while rare specialties may still be sponsored. Risk models may be developed in Toronto or Montreal and deployed to U.S. trading desks; payments code may be maintained in Vancouver while U.S. teams handle compliance and client-facing work. Industry consultants note large card issuers and asset managers already run sizable tech teams in Canada, India, and Europe — the fee will likely accelerate that trend.

Alternative visa and staffing strategies

Legal and HR teams are evaluating alternatives:

• Faster green card sponsorship for top recruits (early PERM planning)
• Cap-exempt H-1B sponsorship through qualifying nonprofit or academic partners for research roles
• L-1 intracompany transfers for senior staff with prior affiliate experience
• O-1 petitions in rare cases for extraordinary ability

Each alternative has strict rules and timing constraints, and none fully replace H-1B scale and predictability.

People effects and internal triage

Junior employees and fresh graduates face the greatest disruption. VisaVerge.com reports HR teams at several large banks are segmenting offers into three buckets:

1. Roles the firm will fund even with the fee (specialists)
2. Roles deferred or moved abroad
3. Roles shifted to U.S. citizens or permanent residents

Current H-1B holders are reassured that renewals are not subject to the fee, and agency guidance confirms they may continue and travel under prior approvals. However, lateral moves that require a new employer petition will trigger the fee, discouraging mobility and potentially slowing wage growth for H-1B workers.

“I may stay put longer, even if a rival firm calls,” said one senior quant, noting the fee’s deterrent effect on lateral moves.

Concentration of exposure: the top financial firms received about 12,000 H-1B approvals in 2025, with JPMorgan’s 2,440 leading the pack. These hires focus on risk engines, pricing models, AML/fraud detection, and platform reliability. A reduction in new filings could slow feature releases, extend project timelines, or increase reliance on contractors abroad.

Legal and market outlook

The policy’s 12-month window is short in statute but long for business planning. Firms building staffing plans for 2026 and 2027 must assume the $100,000 fee remains at least through next fall. If extended, the effect compounds.

• Legal challenges are under discussion, especially in California, where companies argue the rule disrupts innovation and harms sectors reliant on global talent.
• Most general counsel advise planning under the current rule and revising only if court action changes it.

Current employer responses fall into three tracks:

1. Budget triage and role prioritization
   • Business units must justify each new H-1B filing, demonstrating why local hiring cannot meet the need.
2. Alternative pathways
   • Early PERM, L-1 transfers, cap-exempt partnerships, and O-1 routes are being assessed.
3. Timing and compliance strictness
   • Firms accelerated filings where possible before the cutover and are stress-testing processes to avoid missed deadlines and costly refilings.

Worker-side implications and advice

International students graduating in late 2025 and 2026 are recalibrating career plans:

• Many plan to maximize F-1 OPT and STEM OPT time, then consider Canada or Europe if U.S. sponsorship dries up.
• Others discuss early green card sponsorship or L-1 transfers through affiliate placements.
• University career centers are advising international students in finance and fintech to consider cross-border teams and alternate locations.

Practical action items:

• Employers: identify roles that truly require new H-1B sponsorship and fund only those; use internal mobility, U.S. graduate hiring, and overseas affiliates for other needs.
• International students: confirm program end dates, maximize OPT/STEM OPT, and discuss early green card or affiliate-year options with employers.
• Current H-1B holders: plan extensions early, verify whether a next move requires a new petition, and keep travel records aligned with current approvals.
• Legal teams: monitor court developments and updates from USCIS, the Department of State, and CBP.

Metrics to watch and long-term risks

As the first quarter after the policy takes effect begins, watch:

• Number of H-1B registrations submitted for the 2026 lottery
• Share of registrations tied to financial firms
• Rate at which large banks announce new or expanded tech hubs abroad
• University placement rates for international students in U.S. finance

If the $100,000 fee remains beyond 12 months, offshoring trends could harden and the U.S. share of certain high-skill finance functions could shrink.

Sectoral consequences and compensation strategies

The financial calculus changes most at the low end of the pay scale. Example: a first-year data analyst earning $110,000 becomes far more costly to sponsor when adding a $100,000 surcharge. For high-demand specialties, firms may still absorb the fee because leaving roles unfilled carries greater cost.

Ripple effects reach consulting and professional services (Deloitte, Accenture, etc.), which staff large tech and analytics teams inside banks:

• If a bank refuses to fund the fee for a consultant, projects may move to offshore delivery centers or timelines may lengthen.
• With Deloitte’s average H-1B pay near $139,704, careful client-by-client decisions are likely.

Critics warn the policy may reduce the U.S. share of cutting-edge finance work. Advanced analytics for stress testing, climate risk, real-time payments, and AI-driven fraud screening often begin in U.S. hubs. If fewer specialists can enter on H-1B, research hubs may be placed in Toronto, London, or Singapore and then import the finished tools to U.S. operations. Supporters say the fee will push firms to invest in U.S. workers and raise pay where needed — both outcomes may occur: increased local training and more offshoring of remote-capable work.

Inside companies, talent executives are rewriting playbooks:

• Some banks will cut campus offers to international students.
• Others will fund a small number of new H-1B filings only for roles labeled “critical.”
• Some plan split roles: keep client-facing and regulatory work stateside while placing engineering-heavy subteams abroad.
• Firms are auditing current H-1B populations to plan renewals (not subject to the fee) early.

The change also affects diversity and inclusion. U.S. graduate programs in statistics, applied math, computer science, and financial engineering enroll many international students who later join finance. If H-1B pathways narrow, the sector may see fewer multilingual, globally trained professionals in early-career cohorts. Many students are now looking harder at Canada 🇨🇦 pathways, where employer-backed permits and point-based immigration can offer quicker routes to permanent status.

Final trade-offs for firms and workers

One open question is how firms adjust salary strategies. Because the policy aims to direct visas to higher-paid roles, managers may:

• Push pay bands higher for targeted jobs and accept the fee, or
• Raise salaries for U.S. hires and expand training budgets, betting junior U.S. candidates can grow into roles over 12–24 months.

Recruiters warn that rapid shifts could cause wage compression and retention problems.

Smaller firms and community banks will feel greater strain: a single $100,000 surcharge can consume a large share of a small IT budget, potentially delaying upgrades or prompting use of nearshore contractors.

At the policy level, the administration argues higher fees will reduce misuse and lift pay for U.S. workers. Business groups counter that audits and targeted enforcement would be better than an across-the-board surcharge. Legal observers expect challenges focused on statutory authority, rulemaking process, and economic harm to regions and sectors — particularly in places like California.

For now, financial firms face a stark choice: pay the $100,000 per new H-1B to keep scarce skills in U.S.-based teams, or move more work to friendlier markets. Either way, the next hiring cycle will look different:

• Campus recruiting for international students will likely slow.
• Lateral moves for H-1B workers may stall.
• HR leaders will spend more time modeling the return on each new petition.

The H-1B overhaul was designed to push companies to think harder about when they use the visa. In finance, that shift will be felt most in the engine rooms of modern markets — where code, models, and risk systems meet the real-time demands of clients and regulators.