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Documentation

US Guidance Revises Change of Status (cos) and H-1B 60-Day Grace Period

The FY 2027 H-1B cap season introduces wage-weighted selection rules effective February 27, 2026. This update covers essential registration timelines, the beneficiary-centric lottery system, and critical strategies for maintaining legal status. It highlights the importance of the 60-day grace period for those facing job loss and provides a step-by-step guide for Change of Status filings to avoid unlawful presence in the United States.

Last updated: January 26, 2026 5:01 pm
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Key Takeaways
→New weighted H-1B selection rules are scheduled to take effect starting February 27, 2026.
→The FY 2027 lottery registration will likely open in early March 2026 for eligible candidates.
→Workers facing job loss must utilize the 60-day grace period for transfers or status changes.

February 27, 2026 is the date to watch for FY 2027 cap planning. That is when the new weighted H-1B selection rule is scheduled to take effect, reshaping how registrations compete in the March 2026 lottery window.

This update matters even if you are not “in the lottery” today. Many readers will be planning around Change of Status (COS) filings and the 60-Day Grace Period after job loss, especially if FY 2027 selection timing collides with an I‑94 end date.

US Guidance Revises Change of Status (cos) and H-1B 60-Day Grace Period
US Guidance Revises Change of Status (cos) and H-1B 60-Day Grace Period

📅 Key Date: Late March 2026 is the typical timeframe for FY 2027 selection notices after the March registration closes.

FY 2027 H-1B cap timeline (employment start: October 1, 2026)

USCIS has not published the final FY 2027 cap calendar yet. The dates below reflect the long-running cap pattern and typical timing from prior years.

FY 2027 Milestone Date (typical)
Registration Opens Early March 2026
Registration Closes Mid March 2026
Selection Notification Late March / Early April 2026
Filing Window Opens April 1, 2026
Filing Window Closes June 30, 2026
Employment Start October 1, 2026
60-Day Grace Period: Quick Eligibility & Action Check
→ GRACE PERIOD LIMIT
Grace period limit: up to 60 consecutive days OR until I-94 expiration date, whichever comes first
→ EMPLOYMENT RULES
During grace period: stay may be authorized; employment generally not authorized unless/until a new H-1B petition is properly filed and portability applies
→ COMMON ACTIONS
Common actions in grace period: file H-1B change of employer (I-129), file COS for eligible categories (often I-539), or depart the U.S. before the window ends
→ Recommended Action
Calculate your grace-period window using the earliest credible “end of employment” date and your I-94 expiration. Set calendar alerts for day 30, day 45, and the last safe filing day, and save proof of your last paid/worked day in case USCIS asks.

How FY 2027 differs from last year

Two changes drive most FY 2027 strategy decisions. Both affect employers and beneficiaries when planning registrations, filings, and COS timing.

First, the one-registration-per-beneficiary rule continues. Since the 2025 shift to beneficiary-centric selection, multiple employers can still register you, but USCIS will treat you as one beneficiary in the selection pool.

Second, selection may be weighted by wage level. DHS published a final rule in late 2025, with an effective date in late February 2026. The tool on this page lists the policy dates and the wage-based entry multipliers.

For employees, this shifts the conversation to SOC code selection, worksite geography, and wage level. For employers, it increases the compliance value of correct leveling and credible specialty occupation evidence.

⚠️ Employer Alert: Wage level and SOC code choices must match the job duties and supervision level. Overstating level creates pay risk. Understating level can increase H-1B scrutiny.

What happens next after selection vs non-selection

→ Important Notice
If the grace period (or your I-94) has already expired, avoid “wait and see.” Late COS filings can be denied and may create unlawful-presence problems that affect future visas. Get individualized legal advice quickly and consider departing to stop the clock when appropriate.

If selected

Selection is only permission to file a cap-subject petition. Employers still must file a complete case and meet all filing requirements within the filing window.

  1. LCA preparation and posting for the offered role and worksite(s).
  2. Form I‑129 filing within the April 1 to June 30 window.
  3. Decide COS versus consular processing.
  4. Respond to any RFE on specialty occupation, wages, or employer–employee relationship.

COS is often the cleaner path if the worker is already in the U.S. and maintaining status. COS changes the worker’s status inside the U.S. on October 1 but does not issue a visa stamp.

→ Analyst Note
Build a single “status packet” folder: passport ID page, all I-797 approvals, most recent I-94, termination notice, recent paystubs, and a dated timeline of events. Use tracked delivery and keep the full filing copy (including checks and exhibits) for any RFE.

If not selected

Non-selection usually means “not chosen in this round.” USCIS may run additional selections if filings do not meet the cap, but that is not guaranteed.

In the meantime, the worker must maintain independent, valid status. That is where COS planning and the grace period become central to preserving options.

Section 1: What is Change of Status (COS) and where it can go inside the U.S.

Change of Status (COS) is a USCIS adjudication that changes your nonimmigrant status inside the U.S. COS relies on your I‑94 admission record and your continued eligibility.

2025–2026 Policy Updates That Can Affect H-1B and COS Planning
→ Presidential Proclamation
Additional H-1B fee for certain new petitions filed abroad/with consular notification — $100,000
Date: September 19, 2025
→ Weighted Selection Rule
Replacing random lottery. Example weighting: Wage Level IV = 4 entries, Wage Level I = 1 entry
Final rule: December 29, 2025 • Effective: February 27, 2026
→ F-1 Cap-Gap Extension
Extended through April 1
Effective: January 17, 2025

A visa stamp is different. A visa is an entry document used at a port of entry. COS does not give you a new visa stamp.

Common COS targets from H‑1B include B‑2, H‑4, F‑1, and sometimes a move to another work-authorized category through an employer filing, such as O‑1 or L‑1. Eligibility depends on the category rules and your facts.

Filing path matters:

  • Many “personal” COS requests use Form I‑539.
  • Most employment-based changes use Form I‑129 filed by the employer.
  • Dependents often file I‑539s in parallel, to keep everyone aligned.

Section 2: The 60-Day Grace Period: rules, timing, and actions allowed

After H‑1B employment ends, regulations allow a grace period of up to 60 consecutive days, or until the I‑94 expiration date, whichever is earlier. This is often described as a “bridge” period for next steps.

During this window, a person can be in a period of authorized stay even though they are not working. The tool on this page summarizes the exact regulatory phrasing and the action options it lists.

Work authorization is the key trap. Being in a grace period does not mean you can work. Work can usually resume only if a new employer files a nonfrivolous H‑1B petition and you qualify for portability under AC21.

Keep proof that supports dates and compliance:

  • Termination notice and the last day worked
  • Pay statements and severance terms
  • I‑797 approvals and I‑94 records
  • Prior LCA and job description packet, if available

💼 Employee Tip: Treat the grace period as a filing deadline, not a rest period. Count days and confirm your I‑94 end date from CBP.

Section 3: Procedure to Change Status (step-by-step)

Step 1: Pick the target status based on purpose. Visitor, dependent, study, or work all have different evidence needs.

Step 2: Confirm the correct form.

  • I‑539 is common for B‑2, H‑4, and F‑1.
  • I‑129 is required for employer-filed changes, including H‑1B portability, O‑1, and L‑1.

Step 3: Build the evidence packet.

  • Identity and travel history: passport, visa, entry stamps
  • Current lawful admission: I‑94
  • Current status basis: I‑797 approvals, pay history
  • Category-specific proof: finances for B‑2 or F‑1, relationship evidence for H‑4
  • A short explanation letter that matches facts to the requested category

Step 4: After filing. You should receive a receipt notice. Biometrics may apply in some I‑539 cases. RFEs are common when intent or maintenance of status is unclear.

A timely-filed COS can allow you to remain in the U.S. while the case is pending. Work permission depends on the category and whether the new status authorizes employment.

Section 4: Applying within vs after the 60-day grace period

Filing within the grace period, and before I‑94 expiration, is usually the lowest-risk compliance route. It preserves a stronger argument for authorized stay during processing.

Filing after the grace period is risky. USCIS can deny a COS as untimely. Late filings are discretionary and require strong documentation.

Unlawful presence rules can also affect future visa stamps and reentry planning. Even when USCIS approves an H‑1B petition, it may deny the COS portion and force consular processing.

Section 5: Important clarifications and limits

  • COS approval does not automatically grant work authorization unless the new status allows it.
  • B‑2 is not a job-search or work status. Working in B‑2 can create long-term immigration consequences.
  • An approved I‑140 does not give nonimmigrant status by itself.
  • Travel can be dangerous during pending COS. Departure can be treated as abandonment for some requests.
  • If you depart, you may need consular processing and a new visa stamp to return.

Section 6: Practical steps if job loss occurs

  1. Confirm your I‑94 expiration and save the CBP record.
  2. Document your last day of work and keep payroll records.
  3. Decide fast between transfer, COS, or departure.
  4. If a new employer exists, push for an I‑129 filing that supports portability.
  5. Avoid any work until you have a lawful basis to work.

Section 7: Timeline: before, during, and after the grace period

Before job loss: You are in status if you are working per the petition terms. COS planning is allowed when facts change.

During the grace period: You may have authorized stay. You generally do not have work authorization. A properly filed H‑1B transfer can restart work under portability.

After the grace period: You can fall out of status. Unlawful presence may begin accruing, depending on your I‑94 and USCIS findings. Depart or file a defensible option quickly.

Section 8: Significant new policies (2025–2026) and their impact

Several 2025–2026 developments change cost and risk math for FY 2027 cases. The tool on this page lists the exact dates, the fee amount, and the selection multipliers.

Practical planning impacts include adjustments to filing strategy and an increased focus on accurate wage-level classification and specialty occupation evidence.

– If consular processing triggers a major added fee for certain filings, in‑U.S. COS becomes more attractive when eligible.

– Weighted selection increases focus on prevailing wage levels. Level I roles can face higher scrutiny in specialty occupation reviews.

– F‑1 “cap-gap” timing changes can affect students moving from OPT to H‑1B start dates.

Alternatives if you are not selected in FY 2027

Options depend on your profile and employer type. Evaluate eligibility and timing carefully before pivoting to an alternative category.

  • Cap-exempt H‑1B with certain universities, nonprofits, and affiliated entities
  • O‑1 for extraordinary ability
  • L‑1 for qualifying intracompany transferees
  • TN for eligible Canadian or Mexican professionals
  • E‑2 / E‑1 for treaty-based employers and nationals, if eligible
  • F‑1 for a qualifying program, with careful intent and finance documentation
  • B‑2 as a short-term bridge, with strict no-work compliance

Section 9: Official sources and reference URLs

– USCIS H‑1B specialty occupation page: USCIS H‑1B specialty occupations

– USCIS cap season page: USCIS H‑1B cap season

– USCIS options after termination: USCIS information for nonimmigrant workers following termination of employment

– USCIS Form I‑129: USCIS Form I‑129

– USCIS Form I‑539: USCIS Form I‑539

– DOL prevailing wage data: FLC Data Center

Action plan for FY 2027 (employers and employees)

Employers: finalize job duties, SOC code, and wage level by February 2026, before March registration. Prepare LCAs for quick April filing.

Employees: confirm your I‑94 end date now. If job loss occurs, calendar the 60-Day Grace Period and prioritize an I‑129 transfer or a timely COS filing.

Dates to watch: late February 2026 (policy effective date), early-to-mid March 2026 (registration), and April 1, 2026 (filing window open). Review USCIS cap updates at uscis.gov/h-1b-cap-season.

📋 Official Resources:

– H-1B Program: https://www.uscis.gov/working-in-the-united-states/h-1b-specialty-occupations

– Cap Season: https://www.uscis.gov/working-in-the-united-states/temporary-workers/h-1b-specialty-occupations/h-1b-cap-season

– Prevailing Wages: https://flcdatacenter.com

Learn Today
Change of Status (COS)
A USCIS process allowing a nonimmigrant to change their legal category while remaining inside the United States.
Grace Period
A period of up to 60 days following employment termination where an H-1B worker can stay in the U.S. legally.
Beneficiary-Centric
A selection process where each individual is entered into the lottery once, regardless of how many employers register them.
Portability
The ability of an H-1B worker to start working for a new employer as soon as a new petition is filed.
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Sai Sankar
BySai Sankar
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Sai Sankar is a law postgraduate with over 30 years of extensive experience in various domains of taxation, including direct and indirect taxes. With a rich background spanning consultancy, litigation, and policy interpretation, he brings depth and clarity to complex legal matters. Now a contributing writer for Visa Verge, Sai Sankar leverages his legal acumen to simplify immigration and tax-related issues for a global audience.
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