Starting with the Fiscal Year 2021 H-1B Lottery
AILA practitioners have been using the USCIS electronic registration system for employers seeking to file H-1B cap-subject petitions. The sixth season of the H-1B electronic registration process opened at noon (ET) on March 7, 2025, with the “beneficiary-centric” selection process and the myUSCIS enterprise account system. The following practice pointer addresses the most frequently asked questions regarding the electronic H-1B registration process based on information available to date.
FY2026 USCIS Organizational Account Enhancements
For FY2026, USCIS has made multiple enhancements for organizational and representative accounts for H-1B filing. While the details of these enhancements are still being learned, it is known that enhancements include the following:
The ability for paralegals to work with more than one legal representative: A paralegal will now be able to accept invitations from multiple legal representative accounts, allowing them to prepare H-1B registrations, Form I-129 H-1B petitions, and Form I-907 requests for premium processing for different attorneys, all within one paralegal account.
An easier way for legal representatives to add paralegals to company clients.
Pre-population of certain Form I-129 fields from selected H-1B registrations.
The ability to prepare a spreadsheet of H-1B beneficiary data and upload the information to pre-populate data in H-1B registrations.
These enhancements went live on March 7, 2025.
Electronic Registration Process
1. On what website or platform will USCIS host the electronic H-1B registration process?
USCIS uses the myUSCIS online portal to conduct the electronic H-1B registration process. The myUSCIS online portal was updated during the FY2025 filing season to allow for new account types, H-1B registration, and online filing of H-1B forms. This practice pointer was prepared prior to the USCIS launch of new enhancements for the enterprise accounts. For users who created a myUSCIS account before February 2024 and log into their account for the first time after the enhancements of the enterprise account system were added, the user will be required to choose the new account type (legal representative). Companies with existing myUSCIS accounts will have to choose (organizational account) and designate an administrator for that organizational account. For more information on how to create a myUSCIS account, please see How to Create a USCIS Online Account | USCIS.
2. Do lawyers need to create a myUSCIS account for each client, or can an attorney register one account to manage and file applications for all clients?
One attorney or accredited representative should have a single “Representative” account and should be able to manage multiple clients under that account.
3. How do attorneys or law firms submit electronic registrations on behalf of clients?
USCIS unveiled the organizational account structure in January 2024 with a streamlined digital handshake between the attorney and company accounts. Once the company representative has created a myUSCIS company group, it can invite attorneys to join its group to submit H-1B registrations on its behalf. To do so, a company representative will need to go to their “my representatives” tab and enter the attorney’s name and email address to invite an attorney to collaborate on immigration filings in the account.
Conversely, attorneys can set up a company group and invite company administrators to join the company group. To do so, the attorney will need to enter the following:
Company name,
Company doing business as (DBA), if applicable,
Company identification number (EIN, SSN, or ITIN),
Company address,
Company administrator’s full name, email address, and phone number.
It is very important that attorneys meet with company clients to determine whether the company or attorney will create the company group. Once created, company groups cannot be deleted.
Once either the company or attorney has created the company group linked to the other party, the attorney may invite a paralegal(s) and initiate a form/filing on behalf of companies. Paralegals may create, edit, and delete drafts of forms. They may not submit forms/filings or pay the associated fees on behalf of companies.
With the organizational account feature, attorneys have the option to pre-populate Form G-28 with the information stored in their online accounts. To use pre-populated information, the attorney will need to review the saved information and submit the Form G-28. Additionally, paralegals and attorneys will be able to create an H-1B registration form (H-1BR). Once the Forms G-28 and H-1BR forms are complete, attorneys may submit and notify the company administrators that the draft forms are awaiting their review and signature.
If the registration is accepted, the registrant’s authorized signatory will provide their electronic signature by typing their full legal name into a designated box, as well as checking a box stating that they understand English and the information in the form. After the registrant electronically confirms the registration and Form G-28 information, they will need to notify the attorney that the forms have been accepted and are ready to submit.
If the registration is rejected by the client (i.e., due to incorrect registration information), the attorney or paralegal must edit the information in the form, and the attorney must notify the client to review the Forms G-28 and H-1B registration again.
For more information regarding the Form G-28 process, please see the USCIS Frequently Asked Questions at Organizational Account FAQ and for more information on how to upgrade your existing account to a legal representative account and add or invite clients, see the Legal Representative Accounts Instructions.
4. Can an attorney submitting registrations through their online account be signed in from multiple computers/IP addresses at the same time?
An attorney may be signed into their myUSCIS account from more than one computer and IP address but can use only one email address per account, and no email address may be used more than once to set up different accounts.
5. Can multiple accounts be created under a single attorney’s name, in case of system malfunctions or an account getting locked out?
Yes, but each account will need its own unique email address.
6. Can a petitioner/employer/registrant use the same email for two different myUSCIS account types?
No, a petitioner/employer/registrant cannot use the same email address for two different myUSCIS account types (Organizational Admin account/Organizational User). A petitioner/employer/registrant must have separate email addresses for each account and account type. To participate in the H-1B electronic registration process, they must have at least one organizational account with a designated company user as the “administrator.”
7. If a company has multiple entities (e.g., subsidiary, affiliate, and parent), can each entity submit a registration if they have a Federal Employer Identification Number (FEIN)?
The H-1B registration regulation and the recently published final H-1B Modernization Rule declined to finalize a proposal that would significantly restrict the ability of related entities within a corporate family to submit separate registrations for the same beneficiary. As long as there is a legitimate business need for each petition/petitioner and there are two (or more) real and separate job opportunities, then each entity can submit a registration for the same beneficiary. Each petitioner must be able to establish the legitimate business need. If not, USCIS may deny or revoke approvals for all the cap-subject petitions filed by the “related entities” for the same beneficiary.
Previously, in response to a stakeholder question, USCIS indicated that an organization with multiple entities/employers may designate one user to act as the authorized signatory for multiple entities/employers, although a unique email address and a separate myUSCIS account is required for each entity/employer.
8. What information is required for the electronic registration process?
The electronic registration form requests basic information about the prospective petitioning company or organization and employee, including the following:
Registrant Information:
Legal name of the prospective petitioning company or organization.
The Doing Business As name(s) of the prospective petitioning company or organization, if applicable.
Employer identification number (EIN) of the prospective petitioning company or organization.
Primary U.S. office mailing address of the prospective petitioning company or organization.
Legal name (first, last, and middle names), title, and contact information (daytime phone number and email address) of the authorized signatory.
Beneficiary Information:
Beneficiary’s legal name.
Beneficiary’s gender.
Beneficiary’s date of birth.
Whether consideration under the INA 214(g)(5)(C) advanced degree exemption is requested because the beneficiary has earned, or will earn prior to the filing of the petition, a master’s or higher degree from a U.S. institution of higher education.
Beneficiary’s country of birth.
Beneficiary’s country of citizenship.
Beneficiary’s passport or travel document number.
Beneficiary’s passport expiration date (Passport MUST be valid at the time of H-1B registration) NO EXCEPTIONS.
The registration system will not let you re-use beneficiary information from previous years and/or registrations. It will also time out after 15 minutes, but it should save the information you have entered until that time.
The DHS regulations stipulate that the passport used at registration must be the same passport listed on the H-1B petition. In its discretion, USCIS may find that a change in identifying information would be permissible in limited circumstances, including a legal name change due to marriage, change in gender identity, or a change in passport number or expiration date due to renewal or replacement of a stolen passport in between the time of registration and filing the petition.
9. Will any information regarding the offered position need to be provided as part of the electronic H-1B registration process?
No information regarding the offered position is currently required as part of the electronic registration process, such as the job title or the minimum job requirements. Nevertheless, some members believe it is a best practice to evaluate the offered position and the credentials of the beneficiary in advance of submitting an electronic registration to assess whether the registration is bona fide and non-frivolous and to raise any questions about the approvability of the H-1B petition with the corporate client before registration.
10. What can legal representatives do to prepare in advance of the lottery?
There are many steps legal representatives can take to prepare themselves and their clients for these changes. AILA recommends the following:
Check the passports of lottery beneficiaries to ensure that their passports are valid and will continue to be valid during the H-1B registration period. Beneficiaries with expired passports may not be registered.
Ensure that lottery beneficiaries do not have passports from more than one country, or, if they have passports from more than one country, that they use only one country’s passports. USCIS will view entries using different passport numbers as “duplicates” and USCIS could deny or revoke all entries and subsequent selections and petitions.
New filing fees went into effect on April 1, 2024. If clients are going to send you company checks to cover H-1B filing fees, make sure they know what the new fees are that apply to them (and if they qualify under the rule as a nonprofit or small business fees). See question 42 below.
A new Form I-129 went into effect on January 17, 2025. Prior editions will not be accepted. It is important that members check the form edition prior to submission, as USCIS is in the process of updating a number of forms to comply with recent executive orders and may not always provide a grace period.
11. Will an attestation be required as part of the electronic registration process?
Yes, at the time of submitting the electronic registration, the authorized signatory will be required to certify, under penalty of perjury, that they have reviewed the registration and that all of the information contained in the registration is complete, true, and correct and that the authorized signatory, or the organization on whose behalf the registration is being submitted, intends to file an H-1B petition on behalf of the beneficiary named in the registration if the registration is selected. The authorized signatory is required to provide their electronic signature confirming they have read and agree to the statement by typing their full legal name into a box provided. In addition, the authorized signatory is required to confirm they can read and understand English and that they have read and understand every question and instruction on the registration.
For FY2024, the attestation added the following: “I further certify that this registration (or these registrations) reflects a legitimate job offer and that I, or the organization on whose behalf this registration … is being submitted, have not worked with, or agreed to work with, another registrant, petitioner, agent, or other individual or entity to submit a registration to unfairly increase chances of selection for the beneficiary or beneficiaries in this submission.” If USCIS discovers that the registrant did work with another filer to unfairly increase chances of selection, they will find the registration was not properly submitted and no petition may be filed. USCIS can also revoke a petition after the fact and refer the registrant for prosecution.
In addition, a petitioner may only submit one registration per beneficiary per fiscal year. Once the initial registration period has closed, if the prospective petitioner has more than one registration submitted for the same beneficiary, USCIS will invalidate all registrations submitted for that beneficiary by that prospective petitioner or their authorized representative. USCIS has provided a duplicate checker function for the electronic registration process that allows a user to check if the employer-registrant named in the draft registration previously submitted a registration for any of the beneficiaries included in that draft for the same fiscal year. While using this check does not guarantee that an employer will not submit a duplicate, it does compare the beneficiaries listed in the draft with any registrations previously submitted during the current registration period. The duplicate checker function will not check for duplicates within that draft or between drafts. It only checks submitted (and paid) registrations for duplicates. USCIS also advises that it will check for duplicates even if they are submitted by different users.
Ultimately, the burden remains on the employer and their authorized representative to ensure that no duplicate registrations are submitted. To that end, USCIS also provides a tool to download a .csv file and search for duplicate entries.
If a duplicate is discovered while the registration period is still open, the attorney can go into the account and delete the extra submission(s) until there is only one registration for the beneficiary (screenshot example below)
12. Will a Labor Condition Application (LCA) be required as part of the electronic registration process?
No, an LCA is not required to be completed prior to the electronic registration process. Some legal representatives, however, choose to prepare and submit LCAs for beneficiaries in advance of the electronic registration process or shortly after the acceptance of the registration, as a certified LCA must be included with the H-1B petition filing. Members should strategize with their clients on whether or not to file LCAs for H-1B cap-subject beneficiaries in advance of the selection process (in order to file the H-1B petition promptly upon selection) versus after the registration is selected (in order to maximize the time on the LCA), keeping in mind that obtaining a certified LCA in advance of the H-1B selection process is important to preserve cap-gap benefits where a beneficiary’s OPT expires shortly after the 90-day filing period opens.
In addition, even if no LCA is filed in advance of the selection process, members should consider conducting a wage analysis for the proffered position prior to submitting the electronic registration. Failure to consider whether the petitioner is paying the required wage could result in USCIS selecting a registration that ultimately cannot be filed. As discussed in Question 33 below, registrations that are selected but ultimately not filed may be flagged by USCIS for a potential fraud investigation.
13. What date will the registration process open?
USCIS will open the initial registration period on March 7, 2025, at noon (ET).
14. How long will the registration filing window remain open?
The FY2026 registration period will open on March 7, 2025, at noon (ET) and run through noon (ET) on March 24, 2025. USCIS indicated that all registrations submitted during the registration period will be included in the lottery regardless of whether a registration was submitted on March 7 or March 24, even if USCIS determines it has received more than enough registrations to meet the numerical limitations prior to this date. However, it is strongly recommended that practitioners not wait until the last minute to submit a registration. Please note that USCIS has confirmed that a possible government shutdown will not affect the registration period or pay.gov.
15. Is there an option to draft the registration earlier than the start of the registration period to allow for attorney or client review?
Representatives and registrants must wait until March 7 to draft and submit any H-1B cap registrations.
16. May I edit a registration after it has been submitted?
No. During the registration period, USCIS will permit users to review and edit the registrations of beneficiaries as many times as needed before the registration is submitted. Once a registration has been submitted, it cannot be edited. However, the system permits a registration of an individual beneficiary to be deleted, if needed, without impacting the registrations of other beneficiaries in the registration batch. Registrants can delete the registration of an individual beneficiary before the system closes on March 24 by clicking a “delete” button next to each beneficiary’s name (see screenshot below).
17. Once you submit a registration, can you later add more beneficiaries if still within the registration period?
During the registration period, USCIS permits registrants to continue to submit registrations for additional beneficiaries.
18. Is there a limit on the total number of beneficiaries that a prospective petitioner may register?
USCIS places no limit on the total number of beneficiaries that a prospective petitioner may register for the H-1B visa lottery; however, each registration batch can only include up to 250 beneficiaries at a time. Additional beneficiaries can be added to subsequent registration batches for the same petitioner.
19. If an employer submits multiple beneficiaries, let’s say ten names, per registration, and later identifies that the employer needs to withdraw one of those ten names, does the system force the employer to withdraw all ten names that had been submitted in that registration, thereby requiring the employer to resubmit the nine names that it did not desire to withdraw from the registration system?
Upon submission of the registration and payment of the registration fee, a prospective petitioner will be able to see a list of all beneficiaries they have registered. Each beneficiary will be assigned a 19-digit confirmation number. Prospective petitioners have the option to delete a specific beneficiary from the registration, if needed, by clicking “delete” without impacting the other beneficiaries that the prospective petitioner has registered. After a registration is submitted, USCIS will not refund the fee paid for a deleted beneficiary.