I-765 Renewal: Essential Documents Checklist with 2025 Update

U.S. immigration officials will end the long-running extra buffer for work permit renewals next year, telling employers and workers they should plan for approval gaps rather than count on an automatic extension. The policy shift, taking effect on October 30, 2025, removes the automatic 540-day extension that has let many applicants keep working while they wait for a new Employment Authorization Document, or EAD.

The change affects thousands of foreign nationals who file an I-765 renewal to extend permission to work, including students on Optional Practical Training, spouses of certain nonimmigrants, humanitarian applicants, and others who rely on timely EAD processing to stay on payroll. Under the new rule, workers must stop work on the day their current EAD expires unless they receive the new card in time or have another valid basis for work authorization.

What the rule change means: timing and responsibility

The decision puts the focus back on processing times for the Form I-765, the application used to request and renew an EAD. Applicants now face a tighter timeline, and employers must monitor expiration dates more closely.

• Removing the automatic extension shifts risk from USCIS to families and employers, who must now build in more lead time.
• Many companies had adjusted to the longer automatic cushion; without it, payroll interruptions are more likely if applicants file late or if processing slows.
• Workers must stop working the day their EAD expires unless they already have another lawful basis for employment.

Key date: October 30, 2025 — the automatic 540-day extension ends. Treat EAD end dates as firm stops unless the replacement card is in hand.

Fees and filing channels

USCIS has not changed EAD filing fees as part of this update, but costs remain notable for families planning budgets:

• Form I-765 filing fee: $520 for paper and $470 for online submission
• Possible additional biometric fees when USCIS requires biometrics

USCIS encourages online filing for eligible categories to simplify submission and reduce mailing delays. Applicants can find official filing options and current guidance on the USCIS website at uscis.gov. The agency’s tool explains which categories are allowed to file online.

Filing timing: why earlier matters now

For workers weighing when to file an I-765 renewal, timing now has higher stakes. The standard advice to file as soon as eligibility opens shifts from caution to necessity.

• Filing early does not guarantee quick approval, but it gives more time before a potential work stop.
• If an EAD lapses with no automatic extension, employers must remove the person from active work until the new card arrives.
• Consequences include disrupted projects, lost income for families, and operational issues for employers.

Required documents and common reasons for delays

Accuracy and completeness remain critical. USCIS commonly rejects or delays applications for missing or incorrect items.

Essential items USCIS expects with an I-765 renewal:

• A properly completed Form I-765 that matches USCIS formatting rules
• Two identical passport-style photos taken within the last six months
• Proof of identity (e.g., biographical page of a current passport)
  • If a passport is close to expiration, include a copy of the renewal receipt or proof of renewal
• Copy of the most recent U.S. entry record (Form I-94) from the CBP portal
• Front and back copies of previous EAD cards to establish eligibility
• Students on OPT/CPT: latest I-20 forms bearing the school’s work authorization notation

Common avoidable mistakes:

• Incomplete forms or missing signatures
• Incorrect fee payments
• Photos that do not meet standards

USCIS often returns filings that lack key items. Each rejection or Request for Evidence (RFE) can add days or weeks to the timeline.

Practical filing tips to reduce delays

Small steps can reduce avoidable delays and help with tracking:

• Include a short cover letter listing enclosed documents (optional, but helpful)
• Pay the correct fee; paper filers paying by check or money order should make it payable to “U.S. Department of Homeland Security” — avoid abbreviations
• Attach Form G-1145 to receive a text and email when USCIS accepts the filing
• Those with an attorney must include Form G-28 signed by the applicant and representative
• Use mail tracking and keep copies of everything sent

These steps don’t replace the need for accurate information on the application itself, but they help with tracking and may reduce uncertainty.

Employer and household impacts

The most immediate concern is what happens on the expiration date once the cushion is gone.

• Unless the worker has another lawful basis to work, they must stop working when the EAD expires until the new card arrives.
• For households dependent on a single income, even short pauses can cause missed rent, delayed bills, or use of savings.
• Employers face staffing gaps, the need to reschedule client work, shift overtime to other staff, or contract temporary help.
• HR teams must update reminder systems and communicate proactively with foreign national employees.

A staffing manager at a mid-sized clinic summarized the operational shift: “We’ll map EAD end dates like we track medical credentials. If people have to stop working, patients still need care, and that’s on us to plan for.”

Processing volume and surge risks

Processing volumes often spike when rules change, as people rush to file before a deadline.

• With October 30, 2025 approaching, USCIS may see a wave of I-765 renewal filings in late summer and early fall.
• If receipts surge, processing backlogs could lengthen — increasing the risk that an EAD will expire before a replacement arrives.
• USCIS may continue to request supporting evidence in cases with missing identity or eligibility documents, so filing a complete package initially is safest.

Biometrics: potential added delay and cost

Biometrics remain a potential step for many renewals:

• Not every applicant will need biometrics, but when required, USCIS charges additional biometric fees.
• Missed fingerprint appointments or rescheduling can cause delays that now have bigger consequences without the automatic extension.
• Applicants should watch mail for appointment notices, check online case accounts regularly, and keep travel plans flexible until processing finishes.

Practical behaviors that gain importance

Some routine practices become more important as the buffer disappears:

• Use a cover letter to flag special issues (passport renewals, name changes, travel affecting I-94) when relevant
• Track mailed filings and keep copies of all submissions
• Respond quickly to USCIS notices and RFEs to avoid losing time
• Coordinate with university international student offices or HR to plan start dates and avoid travel that could delay receipt of mail

Even a single unpaid day can ripple across a household budget; a week or more of lost income can force difficult choices.

Official resources and final guidance

USCIS remains the definitive source of instructions and filing methods. Relevant resources:

• USCIS main site: uscis.gov
• Form I-765 and filing guidance: Form I-765
• Optional electronic acceptance notice: Form G-1145
• Attorney on record form: Form G-28
• Retrieve Form I-94 from CBP portal for arrival/departure records

Recommended action items

1. File renewals early — treat earlier filing as necessary, not optional.
2. Keep passports, I-94s, I-20s (for students) and prior EAD copies up to date and included in filings.
3. Attach tracking aids (G-1145, mail tracking) and include a cover letter when helpful.
4. HR teams: update reminder systems, map EAD end dates, and prepare contingency staffing plans.
5. Monitor USCIS guidance at uscis.gov for any procedural updates before October 30, 2025.

Takeaway: The automatic 540-day extension is ending — plan earlier filing, stricter document checks, and stronger employer-employee coordination to avoid forced work stoppages when EADs expire.