ALERT: Upcoming Changes to USCIS I-765 & I-765WS Forms

This Practice Alert summarizes USCIS’s new extreme vetting policies, including broad adjudication holds, re-review of previously approved cases, and heightened discretionary scrutiny, and explains their serious implications for immigrant survivors seeking safety and stability. It also provides practical guidance for practitioners on preparing clients for the impact of these measures and on developing case strategies and potential legal challenges.

On July 4, 2025, President Trump signed HR-1, the “One Big Beautiful Bill Act” (OBBBA), which significantly impacts immigrant survivors of human trafficking. The law imposes new filing fees for immigration benefits, motions, and appeals before USCIS and EOIR, establishes additional financial penalties for certain immigration violations, and eliminates eligibility for a range of federal public benefits for many immigrants who were previously considered “qualified,” including trafficking survivors. This Practice Alert reviews these fee and penalty changes, explains the new restrictions on public benefits, and outlines the impact on trafficking survivors seeking T visas and other forms of humanitarian relief, offering guidance for practitioners on how to mitigate the law’s potential harms.

In May and June 2025, ASISTA joined partners at Boston College School of Law, Harbor COV, and Tahirih to submit an amicus briefs to the First and Fourth Circuit Courts of Appeals in cases challenging the executive order on birthright citizenship. ASISTA and partners highlighted the importance of maintaining a preliminary injunction against implementing the order. If the order were implemented, many immigrant mothers of U.S.-born children would only be able to prove their child’s citizenship by submitting documentation about the child’s father’s immigration status. For survivors of intimate partner violence, just knowing the need for this documentation could make it difficult or impossible to leave the abusive relationship. For survivors of sexual assault or trafficking, contacting the perpetrator for the paperwork could put them and their families in immediate physical danger. Using real-life examples, the brief illustrates the stakes if immigrant parents were forced to choose between maintaining their safety and establishing their children’s rights. It urges the court not let this become reality. Read the First Circuit Brief, Doe v. Trump , here ; read the Fourth Circuit Brief, Casa, Inc., et al. v. Trump , here .

On March 14, 2025, President Trump attempted to invoke the Alien Enemies Act of 1798 to justify carrying out deportations without the due process of immigration proceedings. Since then, multiple federal courts have ruled the invocation was unlawful, but the government continues to fight for its usage, including before the U.S. Supreme Court. On May 16, 2025, the Supreme Court maintained a temporary prohibition on the deportations planned in Texas and sent the issue back to the lower courts. ASISTA celebrates the positive rulings but notes with condemnation that the push against them is ongoing. Check ASISTA’s alert: The Fight to Protect Survivors from the Alien Enemies Act Continue.