Washington’s PERM Suspensions: A Delivery Problem For CIOs And A Pipeline Test For Their Suppliers

What Changed: The October 8 Suspensions As Announced

At a White House press conference on visa fraud on October 8, 2026, Vice President JD Vance said the government was suspending Microsoft from the program through which employers sponsor foreign workers for permanent residence. He cited alleged fraud. Secretary of Labor Keith Sonderling said the suspension would also cover Adobe and six IT services firms: Cognizant, Infosys, Tata Consultancy Services, Wipro, HCL Technologies (HCLTech), and Capgemini. “We will not accept any new or process any pending permanent labor certification applications involving these companies,” Sonderling said.

The program is permanent labor certification, known as PERM. It is the Department of Labor’s test that no qualified US worker was available for a job, and the first step in many employment-based green card cases. PERM is not the H-1B visa, the temporary work visa for jobs that need at least a bachelor’s degree. A suspension of PERM stops green card cases at that first step. It does not, by itself, change anyone’s permission to work.

PERM has public case files. On Greyhound Research’s count of the Department of Labor’s PERM files, the six IT services firms received 116 PERM certifications in the nine months to June 2026, fewer than Adobe’s 182. Counts cover each company’s own-name US entities, and Capgemini’s include iGATE. Tata Consultancy Services (TCS), second in the Senate’s fiscal 2025 H-1B figures, received two, after 506 in fiscal 2025. Microsoft received 1,600 of the eight’s 1,898, or 84 percent. If the pending cases the Department holds look like these, most of the people stopped are at Microsoft.

Greyhound Research’s assessment is that the action is a delivery problem for buyers and a pipeline test for suppliers. The ten figures attributed to officials at the press conference, from more than 100,000 certifications since 2009 to a USD 48,000 pay gap, address the case for the action rather than exposure. They span H-1B and PERM, and a supplier’s H-1B volume, like its brand, says little about its PERM exposure.

The suspension lands on people before it lands on products. Nothing in the officials’ statements, as reported, indicates a product risk for software subscriptions, while services that depend on named sponsored people carry a continuity question.

At issue is not whether any of the eight committed fraud. A suspension is not a finding. On Greyhound Research’s reading, enforcement that tests conduct against the programs’ own rules serves buyers’ interests, because it lets them see which suppliers’ recruitment and pay records hold up. A supplier whose records break those rules can face debarment, which carries continuity risk into its clients’ accounts. The question is which contracted services and which workers’ green card cases the stop reaches, and what buyers and suppliers can establish before the written terms appear.

Greyhound Research advises technology buyers and providers, and in September 2025 it argued that immigration risk had become a board-level resilience issue rather than a human resources function. It is not a law firm. Every statement of law or immigration procedure in this research report is therefore linked to the official text that states or anchors it, or says where that text could not be opened. Where one was found, it is also linked to an immigration practitioner who reads it the same way.

A point on which Greyhound Research found no practitioner analysis is labeled as Greyhound Research’s own reading. The annex lists every legal point with its official text and practitioner, so a reader can check each one against its source.

In the public record, what changed on October 8 is known from the officials’ words. Greyhound Research last searched the responsible authorities’ channels through 2:13 a.m. Eastern Time (ET) on October 20, 2026. In those public channels it could not locate a written notice of the suspensions, a statement of the legal authority relied on, a list of the legal entities covered, or a start date. Notices sent directly to the employers would not necessarily appear there. The news coverage reviewed by then reported none, and no lawsuit over the action was reported.

A 44-minute video of the press conference sits on the White House event page, dated October 8, 2026. On October 11, 12, 19, and 20, 2026, Greyhound Research could not locate a transcript there, or an item for the event in the White House’s listings of remarks, statements, and fact sheets. Nor could it locate an item on the action in the Department of Labor’s foreign labor certification announcements, whose latest item was dated September 17, or the notices on its online filing system.

The Federal Register, the government’s daily record of official notices and rules, carried no such item either. Its public inspection lists, where documents appear before formal publication, were by their own notice unavailable on October 11 and 12. Read on October 19 and 20, the lists for October 9, October 13 to 16, and October 19 carried no Department of Labor document on PERM. On October 19 and 20, the Department’s newsroom listing, as Greyhound Research could reach it, did not show current pages.

The regulation on PERM suspensions speaks of labor certification applications, not of a worker’s status. Reddy Neumann Brown, a law firm advising affected workers, and India’s Ministry of External Affairs, in a statement relayed in the press, both read it as not, by itself, ending existing permission to work. For a buyer and a supplier alike, the task is to find where each worker’s case has stopped, then to identify which contracted service depends on that worker.

The regulation that fits the announcement

Officials had not publicly named an authority as of October 20, 2026, but 20 CFR 656.31 matches what they announced. Its trigger is possible fraud or willful misrepresentation “in connection with the permanent labor certification program.” The rule covers matters the Department refers for investigation and matters it learns the Department of Justice, the Department of Homeland Security, or another government entity is investigating. In either case, the Department “may suspend processing of any permanent labor certification application” involving that employer “until completion of any investigation and/or judicial proceedings.”

Under the same rule, a suspension “may last initially for up to 180 days” and can then be extended. The Department must tell the employer in writing, unless the investigating agency asks it, in writing, to do otherwise. Greyhound Research had found no such notice published as of October 20, 2026, and the public record does not show whether one was sent to any employer.

Practitioners treat the rule as the likely authority, not a confirmed one. Colombo & Hurd observes that “Officials did not say which regulation the suspensions rely on.” Meltzer Hellrung calls 656.31(b) “One possible source of authority.” WR Immigration advises that “the specific authority and duration applicable to these companies should be confirmed in DOL’s written notices.”

Later practitioner analyses read the record the same way. On October 16, Greenberg Traurig wrote that “DOL has not publicly confirmed which provision is the legal basis for the announced suspensions.” A day earlier, Morgan Lewis wrote that “it remains unclear whether each suspension rests on an investigation that satisfies the requirements of 20 CFR § 656.31(b).” Mayer Brown wrote on October 15 that the regulation treats a suspension “as a temporary hold tied to an investigation.” Of certifications already approved, it added: “Nothing announced so far revokes them automatically.”

Table 1 sets what officials said beside what the regulation says and how practitioners read it, on six points from pending cases and authority to the workers’ current status. Where the columns do not yet line up on the public record, buyers, suppliers, and workers face the most uncertainty, and a published written notice would settle the most.

New filings raise the largest open question in the announcement. Sonderling announced two separate steps on October 8: no processing of pending cases, and no acceptance of new ones.

On Greyhound Research’s own reading, the regulation covers the first step. Its text does not expressly address the second step, refusing new filings, other than through debarment, a formal bar from the program that requires a written notice. The Department may rely on an authority it has not yet stated publicly. Until a notice states the authority for that step, it is the step most likely to draw questions from employers, their clients, and their counsel, and the one on which they most need written terms.

Officials have described the duration in open terms. Asked how long the suspension would last, Vance said it would “last as long as it needs to,” and that the administration has “a number of tools to suspend it indefinitely.” Colombo & Hurd reports that the Department has announced no end date or timeline for resuming processing. For planning, that rules out a fixed six-month horizon, because the rule also allows the initial period to be extended.

Precedents: Cloudera and Cognizant

The same power has been used this year. On May 12, 2026, the Department of Labor announced that its Office of Foreign Labor Certification “has suspended processing of all permanent labor certification applications filed by, or on behalf of, Cloudera for 180 days.” It cited the Department’s existing suspension authority, and the release does not name a specific regulation.

On September 8, the Department’s Inspector General, Anthony D’Esposito, announced that Cognizant’s PERM filings were suspended, in a statement reported the next day. His office’s release of September 18 said that “the Department has suspended visa applications from Cognizant and Cloudera” pending a criminal investigation, wording broader than PERM. Both records predate the October 8 list.

For Cognizant, the October 8 announcement covers a company whose PERM suspension the Inspector General had already announced. As of October 20, 2026, the public record Greyhound Research reviewed did not show whether the new announcement restates that suspension or broadens it, a point the Department’s records would settle. That difference matters because the initial period runs from the date a suspension began. Cloudera, whose suspension was announced in May, was not among the eight named on October 8. The October 8 list names the employers announced that day, not every employer suspended this year.

Suspension is also distinct from the regulation’s other measures. Denial is a separate step, and so is debarment, which can last up to three years and needs its own written notice. As of October 20, 2026, nothing Greyhound Research located in the public record had turned the announcement into a fraud finding, a denial of filed cases, or a revocation of approved certifications. Neither the PERM nor the H-1B debarment list named any of the eight when read on October 20, 2026. “A suspension is not a finding,” the law firm Samper Law writes.

Cloudera’s suspension followed a Justice Department complaint of April 28, 2026, alleging discrimination against US workers in PERM recruitment. On October 16, the Justice Department and the Department of Labor announced a settlement. Under the agreement, Cloudera will “self debar from PERM for 24 months by not filing any ETA Forms 9089 during that period,” counted from its most recent PERM withdrawal.

Cloudera will also pay USD 600,000 in civil penalties and fund USD 1.4 million in back pay. It denies the allegations. The agreement does not cite 20 CFR 656.31 or say whether the May suspension was lifted, and the Justice Department’s release calls the bar a two-year debarment. On October 20, 2026, the Department of Labor’s published list of PERM debarments did not name Cloudera, and the date of its latest withdrawal had not been published.

The parties’ positions

The administration has described the action as a response to fraud. Vance said that “the fraud is that they’re making representations when applying for this program that are fundamentally illegitimate.” Sonderling said Adobe’s and Microsoft’s suspensions were due to “multiple active federal investigations,” as one report relayed it.

As of October 20, 2026, Greyhound Research had found no agency publication setting out the conduct alleged against any of the eight, and the agencies may hold investigation records that are not public. The Inspector General’s September statements say that Cognizant’s filings were suspended pending a criminal investigation. As published, they describe that investigation only in general terms and set out no conduct alleged against Cognizant.

At the October 8 event, the Department’s Inspector General announced a multi-agency Visa Fraud Strike Team, and his office described it in a release the next day. The team “will focus on H-1B and J-1 visa programs,” a sign that scrutiny will reach H-1B filings as well as PERM, whatever the suspensions’ final scope.

As of October 20, 2026, Greyhound Research had found public statements from five of the eight. Microsoft said on October 8 that 80 percent of its approximately 6,000 H-1B applications in “the last fiscal year,” which it did not define, were for existing employees. It added that it pays H-1B employees the same as others doing comparable work. TCS said on October 9 that it “will comply with any directive from the Department of Labor.”

Infosys said on October 10 that “We do not anticipate yesterday’s announcement of such suspension to have a material impact on the organization.” HCLTech’s chief people officer said on October 12, the day it reported results, that it expected no material impact on its workforce plans, as a press report relayed it. Wipro said in an October 13 filing, as another report relayed it, that “We don’t anticipate any material business impact from this announcement.”

Microsoft’s president, Brad Smith, answered the Vice President in an interview published on October 15. He said someone had “failed to inform the vice president accurately about our numbers,” as a press report relayed it, and that the “vast majority” of Microsoft’s green card applications were for long-serving employees, as another put it. In the press accounts Greyhound Research read, Smith gave no PERM count.

Industry and a foreign government have answered too. The industry body NASSCOM said that Indian technology companies have significantly reduced their dependence on H-1B visas. India’s Ministry of External Affairs said, as one report relayed it, that “The steps announced by the US do not advance the shared ambitions of both countries.” It also said that terms the Vice President used to describe the workers were offensive.

Vance later qualified his language. At a televised town hall aired on October 17, he said, “To the extent that my rhetoric has been imperfect here, that’s on me,” and that his comments were “not a criticism of the H-1B holder.”

In Congress, Representative Pramila Jayapal wrote that “You don’t fix a broken immigration system by taking a hammer to legal immigration,” and Vance replied that her position served corporations seeking cheap labor. Representative Suzan DelBene called the action “an attack on current H-1B visa holders already in the United States,” as one report relayed it. A third Representative, Shri Thanedar, wrote that he strongly disagreed with the decision and that it “will deeply harm America,” as another relayed it.

These three are the only statements on the action by members of Congress that Greyhound Research found as of October 20, 2026. It found none from the Senate Judiciary Committee’s chairman or ranking member, whose September 2025 letters published fiscal 2025 H-1B approval counts, the Senate figures. That search could not open the committee’s own press page. The published letters do not name the dataset behind those counts, which may come from agency records that are not public.

None of these positions is, by itself, public evidence of conduct. The officials’ statements allege fraud and, for Adobe and Microsoft, cite active federal investigations, whose records are generally not public. A notice, charge, or court record would set out the facts. The companies’ statements are their own accounts, and Greyhound Research located no independent check of them in the public record as of October 20, 2026.

NASSCOM, India’s Ministry of External Affairs, and the three Representatives also stated views on policy that the public record cannot test. Greyhound Research sets out each party’s position, in its own words where the source allows, and gives each the same weight.

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Scope And Timing: The Entities Covered And When The Clock Starts

The missing written terms would also fix two practical boundaries: the legal entities each suspension covers, and the date from which its initial 180 days run. Greyhound Research had located neither in any published document as of October 20, 2026.

Officials named eight companies by their corporate names, and a labor certification is filed by a specific legal employer for a specific job. The rule on what a certification covers makes it valid only “for the particular job opportunity,” the named worker and the area where the job is located. Whether it reaches subsidiaries, acquired businesses, or affiliates filing under their own names is a matter for those terms.

Visa-Pros, a practice of Weinstock Immigration Lawyers that advises affected workers, makes the same point: “The names read out on Thursday are not legal entity names, and no source says which U.S. employing entities are covered.” Greyhound Research therefore maps exposure by sponsoring entity and immigration stage, not by brand. Table 2 shows what the public record supports at each stage.

The heavy line in Table 2 marks where the announced coverage ends. New and pending PERM cases at the named employers sit on one side of it. On the other sit previously certified cases, approved I-140 petitions (the immigrant petition the employer files after certification), existing H-1B status, affiliates, and work performed outside the United States. Treating any of them as canceled would overstate the action. Equally, treating the stages inside the United States as untouched would anticipate the written terms.

The 180-day clock and the calendar of public milestones

Timing turns on the written terms too. October 8 is the date of the announcement, and the date on which any employer’s suspension took effect had not been published as of October 20, 2026. That date matters because the regulation measures its initial period from the date “the suspension began.”

The suspension rule gives the Department’s National Certifying Officer a decision point within 180 days of that date. If no criminal charge has been filed by then, or if court proceedings are still running, the officer may resume processing “some or all of the applications” or extend the suspension.

Of the suspensions made public in 2026 that Greyhound Research located, Cloudera’s was the earliest announced, on May 12, as already in place. On the announced dates, its initial period would have been the first to end. Its case closed instead through the settlement announced on October 16 and set out in section 1, a negotiated two-year bar. Greyhound Research found no published extension or lifting of the suspension before then, and the agreement does not address either.

The case shows one way a suspended employer’s PERM matter can be resolved. It does not show how the Department treats the end of an initial period when no settlement is reached. Nor does it fix a public date, since the bar runs from Cloudera’s latest PERM withdrawal, which had not been published as of October 20, 2026.

Three proposed rules affect the same workers. On September 11, the Department of Homeland Security proposed removing the grace period, the up to 60 days a worker may stay after H-1B employment ends, with comments due November 10, 2026. The deadline was unchanged when Greyhound Research checked on October 19.

Under the current rule, such a worker has up to 60 consecutive days, or until the authorized stay ends if that comes first. The agency grants the period at its discretion, once per validity period, and the worker may not work during it unless separately authorized. It stays in force until a final rule replaces it, as the law firm Cozen O’Connor advised on September 16, 2026.

On October 14, the same department proposed removing the rule under which USCIS generally gives deference to a prior approval involving the same facts when it decides an extension, with comments due November 13, 2026. For workers whose green card cases have stopped, it would reach the extensions that keep them in status. Both are proposals, not rules in force.

The Department of Labor’s proposed wage rule would raise the minimum wage employers must offer for H-1B and PERM jobs. That floor is the prevailing wage, the wage the Department sets as typical for an occupation in an area, at one of four levels that section 7 explains. The floor at Level I would move from the 17th to the 34th percentile of local wages, and at Level IV from the 67th to the 88th.

Published on March 27, the wage proposal closed for comments on May 26. The latest Unified Agenda entry Greyhound Research could open, in the government’s published list of rules in progress, showed the rule at the proposed stage on October 20, 2026. No final rule had appeared on the Federal Register’s public inspection lists through October 19. Fragomen noted at the outset that it could not become final before clearing federal rulemaking.

The suppliers’ own disclosure calendar runs alongside. Tata Consultancy Services reported quarterly results on October 8, HCLTech on October 12, and Wipro on October 15, the date it had set on October 7. Infosys will present its results to its board on October 23, Cognizant will report on October 29, and Capgemini will report third-quarter revenue on October 30. Exhibit 1 places these dates beside the enforcement dates and the three proposed rules, showing that enforcement, rulemaking, and disclosure run on separate calendars, with the next scheduled milestones all within a month.

Scheduled disclosures, and the statements filed around them, are where a buyer is most likely to see a named supplier state its exposure. TCS did so with a PERM count on October 9. Its results release the day before, issued on the day of the announcement, did not mention PERM. Infosys did so with a statement on materiality on October 10. HCLTech and Wipro followed on October 12 and 13 with statements on materiality, without counts in the accounts Greyhound Research could read.

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H-1B And PERM: Two Programs That Answer Different Questions

Mapping exposure by entity and case means keeping two programs apart: the suspension stops PERM cases, not H-1B visas, yet many figures cited for it are H-1B numbers. The two programs run under different tests and on different clocks, and Table 3 sets them side by side.

Two rows of Table 3 matter most: the test and the unit. An H-1B count measures positions attested to or petitions approved, extensions included, and an approval is a decision on a filing, not a person hired or a visa issued. A PERM certification is the Department’s approval of its labor market test for one named worker in one job. Both count cases, not distinct people: one worker can appear more than once over the years. Keeping the units apart resolves most of the differences in circulation over who is exposed.

The H-1B statute defines the job as a specialty occupation, one requiring at least a bachelor’s degree in the specific specialty, or its equivalent. Its cap on new cap-subject H-1B workers is 65,000 a year, plus a 20,000 exemption for holders of US master’s or higher degrees, and admission may not exceed six years. Practitioners Watson Immigration Law and Lincoln-Goldfinch Law read the rules the same way.

Before petitioning for a worker, the employer needs the Department’s certification of a labor condition application, under the rule that requires it. The application is the form that carries four promises, listed in the law and the rule on the form’s contents: the wage, the working conditions, the absence of a strike, and notice to employees. Its wage promise is the higher of the prevailing wage for the occupation in that area and the employer’s actual wage for similar workers, as Klasko Immigration Law Partners explains.

The application is an attestation, not a test of the labor market. In the Department’s words, the program is “attestation based,” and it reviews applications “within seven (7) working days for completeness and obvious errors or inaccuracies.” Under the rule on its review of the form, it “is not the guarantor of the accuracy, truthfulness or adequacy of a certified labor condition application.”

Most H-1B employers need not look for US workers first. The Department’s Wage and Hour Division states an H-1B employer “is not required to recruit U.S. workers” unless it is H-1B dependent or a willful violator, one earlier found to have broken the rules willfully. A dependent employer is one whose US workforce is 15 percent or more H-1B workers, with head-count thresholds for employers of 50 or fewer full-time-equivalent employees, under the Department’s Fact Sheet 62C. It must make extra promises on recruiting and not displacing US workers.

Even those employers owe none on an application used only for “exempt” workers. These are workers paid at least USD 60,000 a year or holding a master’s or higher degree related to the job, under the rule on exempt workers, as Reddy Neumann Brown explains.

PERM carries the labor market test: under the statute that sets it, the Secretary of Labor must certify two things. First, that there are “not sufficient workers who are able, willing, qualified” and available for the job. Second, that employing the foreign worker will not adversely affect the wages and working conditions of similarly employed US workers. Headman Law Group describes the first test, on available US workers, the same way.

For professional jobs, the PERM recruitment rule requires recruitment of US workers in the six months before filing. The steps are a 30-day job order with the state workforce agency and two Sunday advertisements, in a window Reddy Neumann Brown puts at 30 to 180 days before filing. Three more steps are required, and one of them may fall within the last 30 days. Recruitment records are the evidence the test was run.

A certification secures a place in a queue, not a green card. The employer next files an I-140, the immigrant petition and second step. Its priority date, which fixes the worker’s place in the green card queue, is the date the Department accepted the labor certification application for processing, under the rule that sets the priority date. Headman Law Group calls that moment locking the date in.

The queue is set by law: at least 140,000 employment-based green cards, immigrant visas in the law’s terms, are available worldwide each year. EB-2 and EB-3, the two categories most PERM cases feed, are each limited to 28.6 percent of that total, plus numbers the higher categories leave unused, a share Shusterman Law also cites. Those born in one country may receive no more than 7 percent of family and employment preference visas combined.

For Indian nationals the queue is long. The State Department’s Visa Bulletin is its monthly list of the queue dates that may receive green cards. Its October 2026 edition, still the latest on October 20, 2026, gives the final action date, the queue date now being reached. For EB-2 it is November 1, 2013, for India, against January 1, 2025, for all other chargeability areas, the Bulletin’s term for countries not listed separately. EB-3’s is January 1, 2014, for India against May 15, 2024.

Chinese nationals, the second-largest group in the eight’s past certifications (section 5), wait in a queue of their own when born in mainland China, because the queue generally follows country of birth. The same Bulletin’s final action dates for applicants born in mainland China are October 1, 2021, for EB-2 and January 8, 2022, for EB-3. Their wait is shorter than India’s and longer than the rest of the world’s.

The first step also takes time. On October 20, 2026, the Department’s processing times page, updated to October 5, showed it reviewing PERM applications filed in December 2025, with an average analyst review of 336 days in August 2026.

An H-1B worker may be sponsored for permanent residence, and PERM also serves jobs that H-1B cannot. The Department’s statistics for fiscal 2025, the year to September 30, 2025, rank the occupations certified. Software developers accounted for 31,415 certifications, 22.7 percent of the total. Lower down are meat, poultry, and fish cutters at 6,167 and fast food and counter workers at 4,017, jobs that H-1B, with its degree rule, cannot serve.

The suspension touches H-1B workers through the extension beyond six years. A 2000 law, AC21, allows two routes past the limit, as the Department of Homeland Security set out in 2016 and a practice alert from the law firm Troutman Sanders also notes. First, a one-year extension where a labor certification or immigrant petition was filed at least 365 days before it would take effect. Second, a three-year extension where an approved immigrant petition is held back by visa limits. A stop on new PERM filings can delay the first.

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The Figures Beside The Public Record: What It Confirms And Where It Stops

Because H-1B and PERM count different things, each figure cited since October 8 has to be read by its unit before it can say anything about exposure or conduct. Those the public record can check count filings, approvals, and layoffs, and none of them measures displacement. Greyhound Research set each beside official statistics, company filings, and the public case files in which the Department of Labor and US Citizenship and Immigration Services (USCIS) publish every employer’s PERM decisions and H-1B approvals.

Some figures the public record can confirm, under the unit named or another. Others it does not carry, or they were stated without a published unit, dataset, or definition, so the public record cannot test them. The record means the official statistics, company filings, court records, and public case files Greyhound Research reviewed. Agencies also hold records that are not public, such as pending cases, and these could test more.

Each figure receives an assessment in one of four groups, each limited to the public record. Supported, plausible, or consistent means that record confirms or fits it. Related measure, partly consistent, or not reconciled means the number exists under another definition or unit. Not found in the public record means the record reviewed does not carry it. The fourth, not tested on the public record, means no dataset or definition has been published, or Greyhound Research has not tabulated the dataset. Neither of the last two grades is a finding that a figure is wrong.

As a first test, Table 4 sets each named employer’s initial H-1B approvals, petitions approved for new employment rather than extensions, beside its PERM certifications from fiscal 2016 to June 2026. Company by company, the two volumes diverge.

The Senate figures were published in late September 2025, before fiscal 2025 ended on September 30, so they may cover only part of that year. They give TCS 5,505 H-1B approvals in fiscal 2025. In the nine months to June 2026, the Department’s file records two PERM certifications for Tata Consultancy Services Limited, the entity that files under TCS’s own name. Infosys had none, though press reports of USCIS figures gave it 8,140 H-1B beneficiaries, the workers named in approved petitions, in April to September 2024.

On Greyhound Research’s arithmetic from USCIS’s files and the Department’s PERM files, the six services firms received 0.55 PERM certifications per initial H-1B approval in fiscal 2016 to 2022, about one for every two. Microsoft, Adobe, Amazon, Google, Meta, and Apple received 1.21, more than one for each. The ratio compares filings, not people: it shows how each company uses the two programs, not what share of its H-1B workers it sponsors for a green card.

In the nine months to June 2026, Greyhound Research counts 1,600 PERM certifications for Microsoft in the Department’s file, about 1.5 percent of the 104,028 certified for all employers. On the same arithmetic, that is about 1.3 percent of its 121,000 US staff in June 2026.

The officials’ totals since 2009

Officials were reported to have cited ten figures on October 8, six about the programs and the eight companies together, and four about Microsoft. Table 5 sets the first six beside the public record, which confirms one, fits one, does not show one, and leaves three untested.

Sonderling said the eight companies had received more than 230,000 H-1B approvals and more than 100,000 permanent labor certifications since 2009. On Greyhound Research’s tabulation of the Department’s PERM disclosure files, the eight companies’ principal entities received about 101,500 certifications from fiscal 2009 to June 2026. Principal entities are the US entities filing under each company’s own name, with iGATE’s counted in Capgemini.

Greyhound Research grades the PERM total supported and the H-1B total plausible. USCIS’s employer files record 215,072 initial H-1B approvals for the eight from fiscal 2009 to part of fiscal 2023. The later years could take the count past 230,000, so the figure is plausible as a count of initial approvals. If Sonderling’s figure includes continuing approvals, more than 230,000 holds on that measure too: initial and continuing approvals together reached 652,332 in fiscal 2009 to 2022 alone.

The total since 2009 also spans a change in the eight’s filing patterns. Three-quarters of the eight’s certifications since fiscal 2009 came by fiscal 2021. Table 4 shows their share of national certifications falling from 9.9 percent in fiscal 2016 to 1.8 percent in the nine months to June 2026.

Sonderling also cited two larger figures, as reported. “Since 2009, just these companies alone have requested almost 3 million foreign workers,” he said, and of the totals, “That’s hundreds of thousands of jobs that were taken from American workers,” one report quoted him. As reported, neither was accompanied by a published unit, dataset, or definition. The public record Greyhound Research reviewed does not show the second: none of it measures displacement by any of the eight, and the investigation and audit files that might address it are not public.

Greyhound Research has not tested the first, almost 3 million. Among the public datasets it reviewed, only labor condition applications, which count positions requested, not people, could reach a count that size. In the Department’s statistics, Microsoft had 20,686 positions certified in fiscal 2025 and Infosys 16,328, together 37,014 on Greyhound Research’s arithmetic. Greyhound Research tabulated them only for fiscal 2025 and the nine months to June 2026, so whether they total near 3 million over 17 years is untested. The Department of Labor publishes those records, so a full tabulation could test the figure.

Several of the eight rank near the top of H-1B use by approvals. Officials tied the action to alleged fraud and, for Adobe and Microsoft, to active federal investigations, and the list does not follow an H-1B ranking. On the Department’s counts of positions certified on labor condition applications, only two of the eight were in the top ten in fiscal 2025 and three in fiscal 2024. None was in the first half of fiscal 2026. Those rankings, like the 2024 counts the press relayed from USCIS figures, measure H-1B use, not PERM exposure.

The Microsoft figures

One of the four Microsoft figures is consistent with approval counts and one sits close to PERM certifications. The public records reviewed do not show the third and leave the fourth untested. Table 6 sets the four, none published with a dataset, beside the company’s filings, official counts, and the Department’s public file, with the disclosure that would change each assessment. Microsoft’s president said in an interview published on October 15, as a press report relayed it, that the Vice President had not been accurately informed about the company’s numbers, without specifying which.

Greyhound Research grades Vance’s statement, as reported, that Microsoft laid off 6,000 American workers last year as not found in the public company or official records it could read by October 20, 2026. The figure 6,000 does appear in the record, as one estimate of the May 2025 cut Microsoft put at fewer than 3 percent of global staff, and in one local report of those cuts. As of October 20, 2026, no public company filing, statement, or official record that Greyhound Research could read gives 6,000 US layoffs for the year.

Microsoft’s US headcount was 126,000 in June 2024, 125,000 a year later, and 121,000 in June 2026, totals net of hiring and attrition that give no layoff count. The government may hold records on the 6,000 figure that are not public, including the layoff documentation behind Microsoft’s PERM cases.

That local report, on Washington State notices that exceeded 3,200 from May to September 2025, said Microsoft had “submitted approximately 15,000 layoffs nationwide this year,” including 6,000 in May. This 15,000 is close to a press tally of Microsoft’s global cuts in 2025, over 15,000 by July 24, 2025, without a US split. The report’s 15,000 may be the global figure rather than a US count, and the public record does not settle which. Microsoft’s July 2026 announcement of about 4,800 roles gave no US split either.

Greyhound Research read the seven notices Microsoft filed with Washington State from May 2025 to September 2026, each stating the positions eliminated and their separation date. It also read the notices filed in California, to June 30, 2026, and in Maryland by Microsoft and, in their own names, by three of its subsidiaries, LinkedIn, Activision Blizzard, and ZeniMax Media. Table 7 lists them all: 3,876 positions for 2025 and 1,867 for 2026 in the states read, a floor rather than a national count.

The May 13, 2025, notice covers 1,985 Washington positions. With the four smaller 2025 notices that followed, the state’s 2025 total is 3,202, the figure the local report carried. The six California and Maryland notices of 2025 add 674 positions, for a total of 3,876 across the states read. Of these, 3,296 are in Microsoft’s own notices and 580 in its subsidiaries’.

Texas’s file, with notices to June 23, 2026, shows none from Microsoft or the three subsidiaries in 2025. Greyhound Research searched New York’s layoff notice dashboard on October 14, 2026, for notices from April 1, 2025, and found none. Notices are required only for layoffs of at least set sizes at a site. Other states, and any notices the subsidiaries filed in Washington, were not read. The 3,876 is therefore a floor for the positions notified across the US in 2025, not a count of layoffs. It can neither confirm nor refute a nationwide 6,000.

The two 2026 notices, 605 positions in July and 277 in September, are likewise a Washington floor for the positions notified this year. LinkedIn’s May 2026 notice in California and ZeniMax’s two July 2026 notices in Maryland add 985 positions, for 1,867 across the states read. A press report of July 7, 2026, says a ZeniMax notice filed in Texas covers 158 more positions. That notice is not in the Texas file read, which ends with notices of June 23, 2026. California’s notices from July 1, 2026, were not read.

The Department of Labor holds or can obtain records relevant to part of the 6,000 figure. Microsoft answered yes to the PERM layoff question on 8,463 cases certified, denied, or withdrawn from fiscal 2022 to June 2026, 2,495 of them in fiscal 2025. For each, 20 CFR 656.17(k) requires it to document that it notified and considered potentially qualified US workers it had laid off. The Department can require that documentation in an audit under 20 CFR 656.20. A yes is the employer’s own disclosure, not a finding of a violation.

Each labor condition application states the number of workers sought, so one company can show three numbers, each counting something different. Microsoft had 20,686 positions certified on those forms in fiscal 2025, 20,577 of them for H-1B, including 11,500 on 115 forms for 100 positions each. It withdrew 86 of those forms on September 29, 2025. The Senate Judiciary Committee’s letter gives it 5,189 H-1B approvals that year, against 6,258 in a press relay of USCIS figures. Microsoft itself speaks of “approximately 6,000 H-1B visa applications we submitted in the last fiscal year.”

Microsoft’s statement adds that 80 percent of its approximately 6,000 H-1B applications were for existing employees, and that the new hires were about 1 percent of its US workforce. Nationally, 69 percent of H-1B petitions approved in fiscal 2023 were for continuing employment, the Congressional Research Service reports.

Greyhound Research grades Vance’s 6,300 H-1B visas and Microsoft’s count alike as consistent with approvals. The 6,300 Vance cited is close to the 6,258 approvals one press report attributed to USCIS figures, and to the approximately 6,000 applications Microsoft says it submitted. On Greyhound Research’s reading, all three count H-1B petitions over a year, but units and years may differ. Microsoft counts applications in “the last fiscal year,” which it did not define, and the press report counts approvals in the government’s fiscal year. Approvals include extensions and are not visas issued or people hired.

On the nearly 3,000 green cards he cited, Greyhound Research’s grade is a related measure. They are close to the 2,929 PERM certifications the Department’s file records for Microsoft in fiscal 2025. A certification is not a green card. In searches on October 10, 2026, Greyhound Research could not locate a public employer-level count of green cards granted, though the agencies that grant them may hold one.

One account has Vance alleging that, at Microsoft, “around 1,000 of its 3,682 PERM applications involved positions that appeared to overlap with jobs eliminated in layoffs.” A second account reports the same two figures, also attributed to Vance. As reported, neither figure came with a published dataset or a definition of overlap, so the public record cannot test either. Greyhound Research could not match 3,682 to a count in the Department’s public file by fiscal year of decision or year of filing, a file that omits pending cases.

The file does show a disclosure. Microsoft answered yes to the layoff question on 2,495 of its 3,161 cases decided (certified, denied, or withdrawn) in fiscal 2025, and the Department certified 2,929 of the 3,161. A yes records a layoff in the occupation before filing, not an overlap between a filed case and an eliminated job. The documentation behind each yes, which the Department can require in an audit, would show more.

On pay, the public record can test neither side’s statement. Vance said an H-1B worker earns USD 20,000 less than “an American citizen hired in the same position,” as reported. He also said, as reported, that workers brought in by “one of these foreign outsourcing firms” earn USD 48,000 less than “an American citizen in a similar position.” Microsoft says “We pay our H-1B employees the same as any other employees doing comparable work.”

None of the three came with published pay data, and a test of any of them would compare workers in the same occupation, place, level, and hours. The public case files record only the wages offered, not what workers or their colleagues were paid, and agencies may hold pay records that are not public.

What the public counts cannot show: displacement

On Greyhound Research’s reading, the public counts, whether cited on October 8 or in the agencies’ files, cannot alone be added up into a replacement ratio. One worker can appear over several years in an H-1B approval, a PERM certification, and an I-140 approval, so adding events risks counting the same person more than once. A displacement test would match eliminated and replacement jobs by occupation, worksite, timing, and employment relationship. Layoff totals alone do not carry those details.

Research does not settle the question either. Kirk Doran, Alexander Gelber, and Adam Isen, in a 2022 Journal of Political Economy article, find that “winning one additional H-1B visa crowds out about 1.5 other workers at the firm.” A Federal Reserve Bank of Richmond working paper by Parag Mahajan and coauthors, revised in March 2025, does “not find evidence for displacement of native-born, college-educated workers at the firm level, on net.” Neither measures any named supplier’s 2026 filings.

Every per-company PERM or H-1B count not attributed to a named source or press report is Greyhound Research’s tabulation of the Department’s and USCIS’s files. No public case file can show displacement: a case record does not say whether a US worker lost a job to it. The administration may hold evidence that is not public, such as investigation and audit files.

The companies’, industry’s, and governments’ own figures

Table 8 sets six company statements, from accounts since October 8 to earlier remarks on visa use, beside the same public record. Three fit that record, two visa figures give no unit, and one pay statement is untested. None is audited. Officials may draw on agency records that are not public, one reason the public record cannot test some of their figures.

Greyhound Research grades the TCS and Infosys statements consistent with the Department’s decided cases. TCS said on October 9 that its PERM applications were in single digits over two years, and Infosys said in an October 10 filing that it does not expect a material impact. Those cases show two certifications at TCS and none at Infosys in the nine months to June 2026, and almost no decided TCS cases filed since March 2024 (Table 8). Pending cases, which the public file omits, could change either grade.

As for Wipro’s and HCLTech’s visa remarks, Greyhound Research grades them not reconciled with the files, because neither gives its unit. Wipro’s October 2025 remark of “250-odd H1-Bs in the past five years” and HCLTech’s of “a few hundred visas a year” sit beside 1,172 and 1,260 initial H-1B approvals in fiscal 2022 alone in USCIS’s files. Different units could explain the gap, and only the companies can close it.

HCLTech and Wipro, which said on October 12 and 13 that they expect no material impact, gave no counts in the accounts Greyhound Research could read. The Department’s decided cases show 66 certifications at HCLTech and one at Wipro in the nine months to June 2026, against 350 and 518 in fiscal 2025. Pending cases, which the public file omits, would show whether the recent pipelines are larger.

Industry, a foreign government, and a member of Congress also made points the record can check, alongside views on policy it cannot. Table 9 separates the two for NASSCOM, the Indian technology industry body, India’s Ministry of External Affairs, and Representative Pramila Jayapal. It also shows the four Indian services firms’ share of initial H-1B approvals dipping and rising between their fiscal 2012 to 2014 peak and fiscal 2022.

Greyhound Research grades NASSCOM’s point that few workers move from H-1B to PERM as supported for the services firms, whose certifications per initial H-1B approval are low. Its second point, that Indian technology companies have significantly reduced their dependence on H-1B visas, is partly consistent, though the relayed statement gave no measure. In USCIS’s files, Infosys, TCS, Wipro, and HCLTech took 12 to 14 percent of national initial H-1B approvals at their fiscal 2012 to 2014 peak and 6.0 percent in fiscal 2022. That is a fall from the peak, not a steady decline.

India’s Ministry of External Affairs said the suspension “does not, by itself, affect the validity of existing H-1B visas,” as one report relayed it. That reading is consistent with the immigration practitioners cited in section 1. Pramila Jayapal called PERM “the first step toward an employment-based green card for countless workers.”

On Greyhound Research’s grading, that statement is consistent with the Department’s count of 104,028 certifications for all employers in the nine months to June 2026, since certification precedes many EB-2 and EB-3 petitions.

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Ten Years Of Filings: The October 8 List And The Public Files

Since the public counts cannot by themselves show misuse, the next test is whether the agencies’ public files explain why these eight were named. Officials tied the action to alleged fraud and, for Adobe and Microsoft, to active federal investigations, whose records are generally not public. As of October 20, 2026, Greyhound Research had found no published criteria for any of the eight. Greyhound Research tabulated every PERM case the Department decided from fiscal 2008 to June 2026 in its disclosure files, and employer H-1B approvals for fiscal 2009 to 2023 in USCIS’s files.

For the fiscal 2026 file, released on August 14, the tabulation matches the Department’s published totals exactly, down to 3,879 denials and 4,643 withdrawals. The fiscal 2025 tabulation falls 0.2 percent short of the Department’s published fiscal 2025 totals.

Who left PERM and who stayed

Among decided cases, the six IT services firms had largely stopped filing PERM by 2025. They received 7,999 certifications in fiscal 2016, 1,708 in fiscal 2025, and 116 in the first nine months of fiscal 2026. Their share of national certifications fell with the count, as Exhibit 2 shows.

Infosys filed its last sizable batch in July to September 2022, Cognizant in April to June 2023, and TCS in January to March 2024. Capgemini still filed 65 in late 2025, all later withdrawn. Many cases filed in 2025 were still undecided at June 30, 2026. Pending cases are not in the public files, though the Department holds them, so recent certifications are the best public guide to the pipelines the suspension stops.

Microsoft did not leave. Its share of national certifications ranged from 1.3 to 4.5 percent across the decade, as Exhibit 2 shows, and among decided cases its filings continued at volume up to its May 2025 layoff announcement. Of the 707 cases it filed in April to June 2025 that the Department had decided by June 2026, 702 were filed before that layoff announcement. Filing dates alone neither show nor rule out any issue with these cases, which the Department assesses from case records that are not public.

Amazon, Google, Meta, and Apple largely left too. Their combined share of national certifications fell from 13.3 percent in fiscal 2023 to 0.3 percent in the first nine months of fiscal 2026. Among decided cases, Google filed one after March 2023, in line with its decision, reported on January 31, 2023, to pause new PERM filings to comply with the Department’s rules after layoffs.

Layoff disclosures on the PERM form

From fiscal 2015 on, the PERM files record the employer’s answer to the layoff question the PERM form asks, though a few cases leave it blank. Under the PERM rule on layoffs, an employer that laid off workers in the job’s occupation, or a related one, in the area in the previous six months must do more. It must document that it notified and considered every potentially qualified laid-off US worker. Cyrus Mehta’s law firm reads it the same way. Nationally, 4.3 percent of cases decided from fiscal 2022 to June 2026 answered yes.

Microsoft answered yes on 69.9 percent of its 12,108 cases. Wipro, TCS, Capgemini, and Infosys answered yes on most of theirs, Wipro on nearly every one. Each yes is the employer’s own disclosure, not a finding of a violation, and it triggers the rule’s extra steps for laid-off workers. Exhibit 3 sets the eight named and eight unnamed employers on one scale against the national rate.

Microsoft and those four are five of the six employers with the most yes answers in the period. The sixth is Oracle America, third with 1,809, and Intel is seventh with 1,028. Neither is on the list. Adobe, Cognizant, and HCLTech, which are on it, answered yes on none, and Amazon, Google, Meta, and Apple on fewer than 1 percent of theirs. The public files do not show which employers are under investigation.

Google answered yes on none of its cases and had all but stopped filing after its 2023 pause on new PERM filings. Amazon had nearly stopped too, with one certification in fiscal 2025, before receiving 86 in the latest nine months. A January 2025 press report, crediting an earlier report, said Amazon had “reportedly restarted” green card applications after “a two-year hiatus.” That fits the low count, though the article does not mention PERM.

The Department’s decisions are consistent with treating a yes as a disclosure, not a violation. It certified 92.0 percent of the yes cases it decided from fiscal 2022 to June 2026, against 90.8 percent of the rest. A certification records the decision on the file as submitted, not what any later investigation may find.

Microsoft’s own share of yes answers moved over time. It answered yes on 60 to 80 percent of cases filed in 2021 and on 14 to 21 percent in April to September 2022. From October 2023 to June 2025 it answered yes on 75 to 93 percent in every quarter. The Department certified Microsoft’s yes cases at about the rate it certified cases generally.

What the employers attest on their H-1B forms

The labor condition application, the H-1B form filed with the Department, carries attestations of its own. An employer states whether it is H-1B dependent, with 15 percent or more of its US workforce on H-1B, and whether the worker will be placed at another company’s site. It also states whether each position is new employment or an existing worker’s extension or transfer.

Greyhound Research tabulated the applications certified in fiscal 2025 and in the nine months to June 2026 for the eight named employers and nine that were not. Table 10 shows that all six services firms attest H-1B dependence and that Microsoft and Adobe do not.

All six services firms attested dependence on all or nearly all of their applications, as did Meta and the three unnamed Indian services peers. Microsoft and Adobe attested that they are not dependent, as did Amazon, Google, Apple, Oracle America, and Intel. The services firms placed 45 to 92 percent of their applications at client sites, the product companies almost none. Dependence is attested at six of the eight named and four of the nine unnamed, so it does not by itself separate the groups or cover the list’s two largest recent PERM filers.

The forms also show the services firms’ H-1B filings turning from hiring to renewal. In fiscal 2025, new employment was 12 to 40 percent of the positions the six certified. Over the nine months to June 2026 it was 0.2 percent at Cognizant, 11 positions of 5,794. It was 5 to 8 percent at Infosys, Tata Consultancy Services, Wipro, and Capgemini, and 26 percent at HCLTech.

The nine-month window opens just after the USD 100,000 H-1B fee Greyhound Research wrote about in September 2025 (section 10). Unnamed Indian services peers fell too, Tech Mahindra from 34 to 5 percent, LTIMindtree from 15 to 1, and L&T Technology Services from 27 to 15. The filings alone cannot show whether the fee, client demand, or each firm’s own choices drove the change.

Microsoft’s share fell from 62 to 30 percent over the same periods, and Adobe’s held at 43 to 45 percent. The Microsoft share for fiscal 2025 is raised by 115 forms for 100 new positions each, 86 of them withdrawn on September 29, 2025. Without the withdrawn forms it was 34 percent, against 30 percent in the nine months. These shares count positions on labor condition applications, the step before a petition. They neither confirm nor contradict Microsoft’s statement that 80 percent of its H-1B applications were for existing employees.

Nationality: who the suspension reaches

The suspension reaches workers of many nationalities. For cases filed before June 2023, the PERM form recorded each worker’s citizenship: more than 120 countries and territories among the eight named employers’ certifications, and nearly 200 across all employers. Table 11 shows Indian nationals receiving most of the eight’s recorded certifications in fiscal 2016 to 2024, and Chinese nationals nearly one in five of Microsoft’s.

The recorded share of Indian nationals is high at most of the eight, and also at several employers not named. Indian nationals received 83 percent of the eight’s recorded certifications in fiscal 2016 to 2024, 57,075 of 68,635, against 53 percent across all employers.

At the six services firms the recorded share was 97.8 percent or more, at Adobe 66 percent, and at Microsoft 52 percent, close to the national rate. It was also high at employers not named: 74 percent at Intel, 66 at Oracle America, 99 at Tech Mahindra, and 99.5 at LTIMindtree. A high share of Indian nationals is therefore found at seven of the eight named and six of the eight not named, so it does not distinguish the two groups.

Chinese nationals were the second-largest group, with 6.6 percent of the eight’s recorded certifications against 10.7 percent nationally. They received 19 percent of Microsoft’s and 12 percent of Adobe’s. At Google and Meta, neither of them named, they were the largest group, at 44 and 42 percent. Canadians came third among the eight, with 2.4 percent, and received 7 percent of Microsoft’s.

Cases filed since June 2023 sit on the current form, which does not record nationality, so the public files no longer show it, though the agencies may hold it in other records. Greyhound Research can therefore only estimate, applying each company’s recorded fiscal 2016 to 2024 share to its recent certifications. Over the nine months to June 2026, that puts Indian nationals at about 56 percent of the eight’s certifications, against 53 percent recorded nationally on the old form. More than three-quarters of those certifications are Microsoft’s.

Over fiscal 2025 and the nine months together, the eight received 6,998 certifications, and the same estimate puts about two-thirds with Indian nationals, mostly because of the services firms’ fiscal 2025 certifications. Greyhound Research uses the nine-month window for its estimate. It is the latest, and it leaves out those fiscal 2025 certifications, which came from cases filed before the services firms largely stopped filing, so it is the better guide to the cases still pending.

The same estimate puts Chinese nationals at about 17 percent of the nine months’ certifications, Canadians at about 6 percent, and Mexicans at about 2.5 percent, mostly through Microsoft’s mix.

Greyhound Research reads the suspension as reaching mainly Indian and Chinese nationals, in proportion to where the eight’s recent filings sit, and not one nationality alone.

Named and unnamed employers compared

Greyhound Research set the list beside six measures in the public files. Three concern a company’s recent PERM certifications, the share of its cases that disclosed a layoff, and the share of its past certifications that went to Indian nationals. The fourth is PERM certifications per initial H-1B approval, and the fifth total PERM certifications since fiscal 2009, the total officials cited for the eight as a group. Sixth is the H-1B dependence attested in Table 10. Officials gave alleged fraud under investigation as the basis, and investigation records are generally not public.

On the first four measures, Table 12 shows the eight named employers overlapping with eight that were not named. These are Amazon, Apple, Google, and Meta, the four technology companies in the Senate figures not on the list. They are joined by Oracle America and Intel, the two unnamed employers with the most layoff disclosures, and by Tech Mahindra and LTIMindtree, two Indian services peers.

In the public files, none of the six measures separates the named employers from the unnamed. On Greyhound Research’s tabulation since fiscal 2009, Amazon ranks first of the sixteen with 39,268 certifications, ahead of Microsoft and Cognizant. Google, Intel, Apple, Meta, and Oracle America each received more than Adobe, Wipro, HCLTech, or Capgemini. None of those six is on the list. The total officials cited was for the eight combined. Two figures coincide by chance: Amazon’s 87 certifications in Table 12 and its 87 layoff disclosures in Exhibit 3 are different counts.

The public files cannot show the basis for the list, only how the named employers compare on the measures those files carry. Six of the eight are services firms whose past certifications went almost entirely to Indian nationals, a pattern that can invite a nationality reading of the list. Yet those firms’ PERM filings had largely ended by 2025. They had also long received fewer certifications per initial H-1B approval than the large product companies, on the ratio section 4 gives.

Officials cited alleged fraud, and an investigation of past filings naturally comes after those filings. So the timing argues against reading the list as a response to current PERM use, though not against reading it as a response to alleged past conduct. Layoff disclosures do not separate the named from the unnamed either.

On a Greyhound Research estimate from recent certifications, the weight of the action is likely to fall mostly on Microsoft and on Indian nationals at a little above their 53 percent national share. Chinese nationals follow, at about 17 percent.

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The Demand Side: Delivery Runs Through Named People

For a CIO, the question the action raises is not which brands were named but which contracted work depends on people whose green card cases sit with a named employer. Nothing in the announcement, as reported, suggests a product outage for buyers of Microsoft or Adobe software. Their exposure is the continuity of named engineering, support, or services staff inside an account. A long suspension could make retaining sponsored engineers a product question for those customers (section 7), which the public record does not yet show. Table 13 maps exposure for each way of buying.

The map runs from almost no exposure to direct dependency. Staff augmentation and onsite time-and-materials work depend most on identifiable individuals, because the client often knows the people by name. Managed services sit between: the supplier controls staffing, while the client holds the service levels and the key-personnel terms. Product subscriptions and cloud services sit at the low end.

Buyers of the six services firms face a more direct dependency. Staff-intensive delivery runs through individuals, some sponsored by the supplier for permanent residence. One practitioner, Samper Law, advises organizations whose workers are employed “at, or placed through,” one of the eight to inventory each sponsored worker. The inventory covers the H-1B start date, the time left before the six-year H-1B limit, and the status of any PERM case or I-140. It says to “Prioritize workers within 18 months of six years with no PERM on file.”

The reason is a hard stop. “A worker whose PERM was never filed now cannot get one filed by this employer,” the same firm writes, and such a worker may run out of H-1B time. The suspension does not touch H-1B on its terms, but one practitioner has raised a concern about extensions in practice. Reddy Neumann Brown reports having “noticed problems involving certain companies where H-1B extensions are not being approved as routinely as before,” while cautioning that this “should not be confused with an officially announced blanket extension ban.”

The figure that matters to a buyer is one the supplier holds and the public record does not show. A supplier’s H-1B total says little about how many of the people serving an account sit in a stopped PERM queue. Even a company with thousands of H-1B approvals can have almost no PERM cases. Table 4 shows most of the services firms’ own US entities in that position, judging by their recent certifications. What a buyer needs is the count of sponsored workers by service and stage.

The contract levers and who bears the cost

The supplier request is the first lever, and it should be specific and go out within 30 days. It goes to every supplier that sponsors workers for permanent residence, named on October 8 or not. The request asks for aggregate PERM-stage exposure: the service, the sponsoring legal entity, the affected role cohort, the earliest deadline, the authorized staffing alternatives, and the contractual remedy. Aggregated exposure answers the business question. Personal case details belong with authorized HR and legal teams.

Price is the second lever. A price adjustment should be tied to demonstrated incremental cost and an agreed mitigation plan. Generic visa surcharges establish neither the cost nor the continuity of the contracted service, and neither does a reassurance about global headcount.

The rules already allocate much of the cost. An employer carries the cost of its own PERM cases. Under the rule on who may pay for a PERM case, an employer “must not seek or receive payment of any kind for any activity related to obtaining permanent labor certification,” with one exception. A payer may cover the employer’s PERM costs only when the worker’s work “would benefit or accrue to the person or entity making the payment,” based on an established business relationship with the employer.

The second rule covers workers kept on the payroll without work, known as benching. In Fact Sheet 62I, the Department of Labor states that H-1B workers must be paid for nonproductive time caused by “lack of assigned work.” Berardi Immigration Law puts it plainly: “It is not permitted to bench H-1B employees without pay.” The duty ends only with a bona fide termination under the H-1B wage rule. Cyrus D. Mehta & Partners describes that as ending the employment, notifying the immigration agency, USCIS, and paying for the trip home where the rules require it.

Greyhound Research reads the first rule narrowly, as Cyrus D. Mehta & Partners does: the exception is for “a party with a legitimate, pre-existing business relationship with the employer,” not a routine way for a client to fund a supplier’s PERM costs. It found no practitioner, in the analyses it reviewed to October 19, 2026, who endorses client funding as a response to the suspension. The second rule keeps the cost of a benched worker with the supplier.

Moving work offshore is a documented response to H-1B limits. Britta Glennon, in research published in Management Science in 2024, finds in its working-paper version that firms “respond to restrictions on H-1B immigration by increasing foreign affiliate employment.” A supplier’s proposal to move work offshore should meet the same test as a price adjustment and should show the staffing constraint behind it. The client’s data-access, security, and service terms govern any such move.

What a buyer may and may not ask

One tempting response would create a new legal risk. A buyer worried about continuity may want suppliers to staff its account only with US citizens or green card holders, or to avoid visa holders. The federal law against citizenship-status discrimination bars employers, and those who recruit or refer for a fee, with four or more employees from discriminating on citizenship status against protected individuals. Protected individuals include US citizens and nationals, refugees, asylees, and, in the Justice Department’s words, “recent lawful permanent residents.”

The Justice Department’s guidance permits citizenship-only hiring only where a law, regulation, executive order, or government contract requires it. By statute, a narrow Attorney General exception also applies for government business.

The Justice Department’s employer fact sheet gives “Only U.S. Citizens or Green Card Holders” and “H-1Bs or OPT Candidates Preferred” as examples of language that risks violating the law. OPT is optional practical training, work permission for recent foreign graduates. A preference in either direction therefore carries risk. Littler Mendelson describes a case where a client asked its staffing agency to withdraw an offer because the worker lacked US citizenship, and the Justice Department found the client discriminated. Mayer Brown adds that visa holders, though outside the citizenship-status protection, remain protected against national-origin discrimination.

The same fact sheet says an employer may generally ask whether a person has the right to work in the United States and will need sponsorship for a visa. That guidance addresses employers rather than their clients.

On Greyhound Research’s reading, a buyer’s request is on firmer ground when it concerns continuity, skills, work authorization, and notice of staffing changes. It should not concern citizenship or visa status unless a law, regulation, executive order, or government contract requires it. No official guidance that Greyhound Research located by October 12, 2026, addresses a request to exclude visa holders as such, so any restriction a buyer believes it needs belongs with its counsel first.

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The Supply Side: Eight Suppliers, Uneven Pipelines

What a buyer can learn from a supplier depends on that supplier’s pipeline, and the Department’s public files show the eight named suppliers’ pipelines differ widely. As of October 20, 2026, Greyhound Research had located no published change to any of the eight suspensions. Greyhound Research tests each supplier on PERM use and, in Table 14, on dependence on US delivery and the visa reliance its own filings disclose.

The two software companies

Adobe and Microsoft each earn about half their revenue in the United States. Microsoft’s 10-K for its fiscal year to June 30, 2026, its annual report to the Securities and Exchange Commission, puts 121,000 of about 223,000 full-time staff in the United States. Its US revenue figure includes billings to equipment makers (OEMs) and certain multinational organizations, so revenue does not size Microsoft’s exposure to the suspension. The same filing says the company is “limited in our ability to recruit internationally by restrictive domestic immigration laws.”

Adobe reports half of its 31,360 staff in the United States as of November 28, 2025, and warns of “intensified restrictions on immigration or the availability of work visas.” By October 20, 2026, in the statements and press accounts Greyhound Research read, Microsoft had answered on H-1B and, through its president, on green cards in general terms, but not with PERM counts. For both, the operating question is retention of sponsored engineers and specialists, the commercial question whether customer-facing teams depend on them.

The six services firms

TCS’s October 9 exchange filing is the services firms’ clearest company evidence. TCS says, “Our PERM applications were in single digits in the last two years,” and expects no effect on its workforce strategy or customer engagements. It “will comply with any directive from the Department of Labor,” and intends to hire 15,000 more US staff over five years. The filing does not say whether the count is annual or combined, or which US entities it covers.

Its count is consistent with the Department’s file. Among decided cases, TCS filed 512 PERM cases in January to March 2024 and three in the rest of 2024, and none filed in 2025 had been decided by June 2026. The 512 were filed more than two years before the statement.

North America gave 48.3 percent of revenue in the September quarter. One press report of US immigration data put TCS second among employers of approved H-1B beneficiaries in fiscal 2026, which counts H-1B use, not PERM cases.

Cognizant’s 2025 10-K says its principal US subsidiary “utilizes a high number of skilled workers holding H-1B and L-1 visas,” the L-1 being the visa for employees transferred within a company. Its North America headcount fell from 42,800 at the end of 2024 to 41,600 a year later, while its India staff grew. The same report shows about three-quarters of revenue coming from North America, the delivery base on which its onsite H-1B and L-1 staffing rests.

Cognizant also carries the Inspector General’s September statements, set out in section 1, that its PERM filings were suspended and its visa applications suspended pending a criminal investigation. Separately, in Palmer v. Cognizant, a federal court’s findings of December 5, 2025, record a 2024 jury verdict of intentional discrimination. The court itself concluded that Cognizant’s “Visa Readiness,” “Visa Utilization,” and related policies and practices had a disparate impact. Disparate impact means that a facially neutral policy falls more heavily on one group.

Infosys’s quarterly financial statements to June 30, 2026, disclose a separate matter. The Department of Justice “is conducting an investigation regarding how the Company classified certain H-1B visa-recipient employees working for one of its clients in immigration documents,” they say, and Infosys cannot yet predict the outcome.

Its 20-F, a foreign company’s annual report to the Securities and Exchange Commission, puts North America at 56.1 percent of revenue in its fiscal year to March 31, 2026. Neither filing links the investigation to PERM or to October 8, and as of October 20, 2026, the public record did not show whether it was among the investigations officials cited. Infosys’s 2013 civil settlement of USD 34 million resolved allegations concerning earlier conduct, and nothing in the public record reviewed links it to the cases now stopped.

On October 10, Infosys said in an exchange filing that it does not anticipate a material impact from the suspension. It welcomes the opportunity to work with the Department of Labor and related agencies and will make further disclosures if required. The filing gives no count of pending or certified cases and names no US entities.

Wipro’s chief human resources officer said in October 2025 that “More than 80% of people are localized.” The same executive cited “250-odd H1-Bs in the past five years,” and Wipro’s 20-F puts the Americas at about 62 percent of IT services revenue in its fiscal year to March 31, 2026.

HCLTech’s chief executive said in October 2025 that its visa dependence was “down to a few hundred visas a year,” against a USA share of 56.1 percent of services revenue in the September 2026 quarter.

Neither self-description is audited or says whether it counts new petitions, approvals, or travel. Set against fiscal 2022 initial approvals in section 4, neither reconciles with USCIS’s files. The counts the press relayed from USCIS figures for April to September 2024, 1,634 for Wipro and 2,953 for HCL America, tell the same story, though the relay defines neither unit. Only the companies’ units can reconcile them.

Both have since spoken, as press reports relayed and section 1 sets out: HCLTech on October 12 on its workforce plans, and Wipro on October 13 on its business, each expecting no material impact. Wipro’s filing, as relayed, added that the action “relates to a specific permanent residency pathway.” Neither account Greyhound Research could read gave a count of cases or named the US legal entity concerned, and neither company’s results release mentions PERM.

The Department’s file records one unusual pattern at Wipro. All 410 cases it decided for Wipro in fiscal 2021 were filed in the first half of December 2019, and 399 were denied. On Greyhound Research’s arithmetic, the national denial rate that year was 3.8 percent. The public file does not record the reasons, which sit in the Department’s case records, and a denial is not a finding of misconduct.

In fiscal 2024 the Department denied 169 Wipro cases and recorded 101 withdrawals, with no certifications. Wipro’s 518 certifications in fiscal 2025 show the pipeline continued past those decisions. Those 518 came from cases Wipro filed before it and its peers largely stopped filing, so they do not contradict the finding that the services firms had largely left PERM. For a buyer the pattern is a question for Wipro, not a finding.

Capgemini drew 29 percent of 2025 revenue from North America and had 66 percent of its workforce offshore in June 2026. The documents reviewed say nothing on visa use, so its exposure cannot be read from its record.

Adobe, Cognizant, HCL Technologies, Wipro, and Capgemini did not immediately respond to press inquiries on October 8. Greyhound Research found no statement from Adobe, Cognizant, or Capgemini as of October 20, 2026, including on Adobe’s newsroom. Silence says nothing about pipeline size. NASSCOM said moves from H-1B to permanent residence through PERM are relatively limited, and the Department’s counts in Table 4 support that for the services firms.

What a supplier must show

The layoff rule, set out in section 5, makes occupation, location, dates, and the recruitment record the facts in issue, for the Department and for the supplier’s clients. A compliant paper trail is evidence to examine, not a substitute for examining the hiring decisions behind it.

On pay, the Department’s Fact Sheet 62G describes the H-1B required wage as “the higher of the prevailing wage or the employer’s actual wage (in-house wage) for similarly employed workers.” A meaningful comparison aligns work, seniority, geography, hours, and compensation before assigning a cause. The pending wage proposal would change the floor itself, so a buyer modeling supplier costs should keep enforcement of the current floor apart from a possible new one.

On the Department’s file, few of the services firms’ certified PERM jobs were at entry level. Each PERM job carries one of four prevailing wage levels, Level I the entry level and Level IV the highest. The Department assigns it by comparing the job’s stated requirements with those usual for the occupation, not by the worker’s pay, as its wage guidance and Reddy Neumann Brown describe.

In Greyhound Research’s tabulation of certifications in fiscal 2019 to 2024 with a recorded level, Level I applied to 26.0 percent nationally, 27.2 percent at Microsoft, and 8.1 percent or less at each services firm. All but one of TCS’s 8,933 cases with a recorded level were at Level IV, the highest. These jobs therefore sat above entry level on the Department’s scale, with the higher wage floors those levels set. The level reflects each job’s stated requirements, not the wages actually paid or any conduct under investigation.

A supplier should therefore show, by legal entity and occupation, its PERM cases by stage, its layoffs before each filing, how it considered laid-off US workers, and its offered wages against the required wage. It should hold the same evidence for H-1B, one of the two programs the Inspector General’s strike team will focus on.

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Beyond The List: The Same Questions For Every Sponsor

A place on the list does not size a supplier’s exposure, and absence from it does not clear one: the October 8 list leaves out several of the largest H-1B sponsors. The Senate figures, published in September 2025 for ten employers including seven technology companies, make the point, though they may cover part of the year. Three of the seven were named on October 8: Microsoft, Tata Consultancy Services, and Cognizant. Amazon, Apple, Google, and Meta were not. Table 15 shows four large H-1B sponsors off the list: volume alone did not decide it.

The four unnamed companies, as one report relayed it, can still file PERM cases. Amazon led the seven with 10,044 approvals and is not on the list. Cognizant had the fewest of the seven, 2,493, and is on it. The pattern fits the officials’ stated basis rather than selection by H-1B volume: alleged fraud and, for Adobe and Microsoft, investigations whose records are generally not public. Public files cannot exclude other criteria. By October 20, 2026, among the eight, the only official release Greyhound Research located tying a suspension to a criminal investigation names Cognizant.

The Department’s files show how little PERM the four unnamed technology companies now use. Google had all but stopped receiving PERM certifications by fiscal 2025. Amazon fell to one certification that year, then received 86 in the nine months to June 2026.

Apple received 31 PERM certifications in the same nine months, and Meta 153, close to Adobe’s 182. Oracle America and Intel continued to file PERM cases, many with layoff disclosures, and are not on the list. A layoff disclosure is the employer’s own answer, not a finding, and Table 12 compares both on the agencies’ files. Table 15 holds the peers whose public record reaches beyond those files, through a reported visa count, an enforcement record, or a company statement.

Meta and Apple resolved earlier PERM enforcement claims through settlements in 2021 and 2023, years before the 2026 suspensions. In 2021 the Justice and Labor Departments settled with Facebook, now Meta, over claims that it “routinely reserved jobs for temporary visa holders through the PERM process.” The terms were a USD 4.75 million civil penalty and up to USD 9.5 million for workers.

In 2023 Apple agreed to pay up to USD 25 million. The Justice Department said Apple “did not advertise positions Apple sought to fill through the PERM program on its external job website.” Neither release records an admission of liability.

The settlements continue. In August 2026 the Justice Department described its settlement with OpenAI, over an alleged preference for visa holders in PERM recruitment, as “the thirteenth settlement since the Department re-launched its Protecting U.S. Workers Initiative in 2025.” For peers, the record therefore shows two enforcement tracks. One is negotiated settlements over recruitment practice. The other is suspensions tied to investigations, and the October 8 list shows only the second. Cloudera’s case touched both, a suspension followed by a settlement of a recruitment complaint.

Among Indian services peers, the public record is thinner. A press relay of USCIS figures put approved H-1B beneficiaries for Tech Mahindra Americas at 951 as of June 2025, beneficiaries being the workers on approved petitions. Tech Mahindra drew 48.5 percent of its revenue from the Americas in the quarter to September 30, 2026.

The company said, as a press report of October 16 relayed it, that it had received no communication from the US government about suspending its PERM applications. That is a company statement, not an official record, and it does not show whether any other unnamed employer is suspended. LTIMindtree’s chief executive said in an interview relayed on December 1, 2025, that “we are not going to make any new applications on H-1B” and “we are hiring locally.”

L&T Technology Services paid USD 9,928,000 in 2023 to resolve allegations under the False Claims Act. The allegation was that from 2014 to 2019 it underpaid visa fees by obtaining B-1 visas, the business visitor visa, rather than H-1B visas. L&T Technology Services denied liability. It drew 60.4 percent of its revenue from North America in the quarter to June 30, 2026.

Greyhound Research names a peer only where the public record carries a visa or labor certification count, an enforcement record, or the company’s own statement on visa use. Firms whose filings show only US revenue concentration are not named. Greyhound Research does not describe any of the peers it names as a target of the investigations.

The closed cases in the Department’s enforcement database

The Department’s enforcement record is public in one more place: the Wage and Hour Division’s database of concluded cases, which records the violations found and the back wages agreed. Greyhound Research tabulated every concluded case with H-1B findings: 2,944 nationally, with USD 125.7 million in back wages for 13,702 workers. Table 16 shows that such cases at the seventeen employers of Table 10 are few on both sides of the list.

These closed cases are separate from the investigations officials cited. The eight named employers account for 17 cases and about USD 886,000 in back wages agreed, more than half of it in one 2008 Cognizant case covering 67 workers. Infosys’s 2025 case, USD 128,551 agreed for one worker, is the only one at a named employer whose findings period ended in the last five years. In the file downloaded on October 12, 2026, Adobe and TCS have no case with H-1B findings. Tech Mahindra, unnamed, carries a larger back-wage record than seven of the eight.

The counts follow the names each company files under, with iGATE counted in Capgemini. They leave out two cases at Patni Computer Systems, one in 2005 with USD 2.4 million agreed for 607 workers, larger than any case in Table 16. In 2011 iGATE acquired Patni Computer Systems Limited, and in 2015 Capgemini acquired iGATE. All of these are closed wage cases, not the open investigations or the PERM settlements.

The open investigations

No official statement found as of October 20, 2026, says that the list will be extended, but the public statements on the investigations do not confine them to the eight. The Inspector General’s September 18 release said investigators had issued “dozens of subpoenas and executed search warrants” and that “No company is too powerful.”

His office announced an audit of the PERM program on July 14, 2026, to examine “the extent to which U.S. workers have been recruited for PERM job vacancies.” Its October 9 release described the Visa Fraud Strike Team, set out in section 1, whose focus on H-1B and J-1 reaches beyond PERM.

Scrutiny of layoffs reaches every H-1B sponsor, named or not. Executive Order 14431, signed September 18, 2026, directs the Departments of State, Labor, and Homeland Security to “take into account” whether an H-1B employer sponsor “directly or indirectly engaged in layoffs within the previous year.” The clause continues, “or plans future layoffs that negatively affect the employment of similarly situated United States workers.” It also directs the Secretary of Labor, through the Wage and Hour Division, to begin reviewing data on previously submitted labor condition applications within 30 days. The order does not mention PERM.

For an unnamed peer the prudent assumption is scrutiny, not suspension. On Greyhound Research’s reading, the evidence an investigator or a client would ask for first is the peer’s recruitment files, layoff records, and wage comparisons for its pending and recently certified PERM cases. A peer that can produce them in aggregate will answer a buyer’s question faster than one that cannot.

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Eight Clocks: The Deadlines Inside Each Worker’s Case

Whether or not a sponsor is on the list, its workers’ exposure becomes a deadline only inside each worker’s case, and those deadlines keep running whatever the suspension’s length. A worker’s case has eight clocks, four in the green card case and four in the worker’s own immigration status.

Clocks inside the green card case

Table 17 carries the four clocks inside the case. The first is the life of a certification, a point the October 8 statements, as reported, did not address. An employer has 180 calendar days from the grant to file it with an I-140, or it expires, under the PERM rule on the life of a certification, as Visa-Pros also states. Because the suspension stops the Department’s processing, not this clock, the workers exposed first are those whose certifications are nearing the limit.

The second clock protects an approved I-140, with exceptions. Under the rule on revoking an approved petition, a petition the employer withdraws 180 days or more after approval “remains approved unless its approval is revoked on other grounds.” It is revoked automatically under the same rule if the labor certification behind it is invalidated, so the workers exposed are those whose certification an investigation might invalidate.

The third clock is the priority date, the date that fixes the worker’s place in the green card queue. A worker loses it if the approval is revoked for fraud or willful misrepresentation, for material error, or over a revoked or invalidated certification, under the priority date rule, as Troutman Sanders explains. In a fraud investigation, invalidation is therefore the risk to watch: it takes both the petition and the queue place.

Clocks in the worker’s status and the ways out

The first status clock is time in H-1B status, capped by law at six years unless an extension applies. Both paths to more time, one-year and three-year extensions, rest on the law known as AC21, and the Department of Homeland Security described them in its 2016 final rule. The H-1B rule on extensions beyond the sixth year carries them into practice. Samper Law cites it, and Greyhound Research could not open its text.

Under the one-year path, as Troutman Sanders explains, a labor certification or I-140 must be filed at least 365 days before the extension would take effect. A stop on new PERM filings delays the day that period can start, so the workers exposed are those near the six-year limit with no PERM on file. Samper Law advises putting workers within 18 months of the limit first. That leaves roughly six months to prepare a filing that must be made at least 365 days before the extension would take effect.

Greyhound Research reads a further proposal as bearing on both extension paths. If the October 14 proposal set out in section 2 is adopted, each extension that keeps a worker in status while a stopped green card case waits would be decided without deference to prior approvals. It is a proposal, not a rule in force.

The second status clock works in the worker’s favor: a worker whose I-140 is approved but held back by the visa limits can take three-year extensions, so that worker can wait. Table 18 shows how the four clocks in the worker’s own status decide who can wait, who can move, and who runs out of time.

The third status clock runs when a worker moves to a new H-1B employer. Under the H-1B portability law, the worker may start work as soon as the new employer files a petition with a genuine basis, which the law calls nonfrivolous, as Reddy Neumann Brown confirms. The petition must be filed before the authorized stay ends, and the worker must have been lawfully admitted and not worked without authorization. Whether the green card case moves too depends on Table 17’s last clock, a job change once an adjustment application has been pending 180 days.

The adjustment of status application is the final application for the green card itself, filed in the United States. Once it has been pending 180 days, the I-140 stays valid for a new job “in the same or a similar occupational classification,” under the law on keeping a petition after a job change.

Without that protection, the new employer must run its own PERM, as Lehigh Valley Immigration Law advises, because a certification is valid only for its particular job, worker, and area under the certification rule. An approved I-140 generally keeps the priority date for the new employer’s petition, under the rule on keeping a priority date. The State Department’s October 2026 Visa Bulletin puts the queue dates in 2013 and 2014 for India and in 2021 and 2022 for mainland China. Many Indian-born and Chinese-born workers cannot soon reach the adjustment stage that unlocks a move.

The fourth status clock is the grace period described in section 2, the up to 60 days a worker may stay after H-1B employment ends, which the September 11 proposal would remove. On Greyhound Research’s reading, if the suspension persists and the proposal is adopted, a worker in a stopped PERM queue would have fewer safe ways to change employer and depend more on the sponsor. That is a mechanism to watch, not a measured outcome.

Moving a worker to an affiliate or a client is no simple workaround. Under the PERM definition of an employer, the employer is the entity that “proposes to employ a full-time employee” in the United States. It must hold its own Federal Employer Identification Number (FEIN), the federal tax number that identifies a US employer.

Greyhound Research reads the definition as letting an affiliate or a client sponsor only as the worker’s real intended employer, with its own job and recruitment. Whether the Department would treat such a filing as “involving” a suspended employer is an open question no practitioner had addressed in the analyses Greyhound Research reviewed to October 19, 2026.

On Greyhound Research’s reading, being related to the original employer does not by itself let a company use an existing certification. A different employer can use one only as a successor in interest, an employer that has taken over the business behind the job and may rely on the earlier certification. As Capitol Immigration Law Group describes it, the successor must document the takeover, show the job unchanged, and prove its own eligibility.

The Department’s 2019 guidance says a withdrawn application can be refiled for the same worker and job only after the Department confirms the withdrawal. It predates the move of PERM filing to the Department’s current system, known as FLAG, so the mechanics may have changed. A filing by another entity starts a new case and, as Berardi Immigration Law warns, loses the earlier wage determination and recruitment.

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Proportionate Action: A Buyer Playbook And A Supplier Playbook

The clocks make the response a matter of named roles and dated evidence rather than a supplier-wide reaction. Operationally, the main risk is uncertainty about people who hold scarce knowledge or critical access. It can become attrition, a missed filing deadline, a delayed transfer, or an inability to staff a location, and it reaches a contracted service only where such people sit in it.

For the workers concerned, a suspended route to permanent residence cuts two ways. A worker with portable status may leave for an employer that can still file PERM. One without it has fewer safe ways to move and stays dependent on temporary sponsorship. Both are plausible mechanisms, not measured results, and both playbooks begin by finding where such people sit.

The buyer playbook

The buyer playbook has eight steps, each with an owner and evidence of completion. Table 19 gives the first three, and the first decides the rest. A buyer that knows which services depend on which sponsored roles, at which entity and stage, can size the problem directly, while one starting from brands must find the entities and cases behind them. The written position comes second because only the supplier holds the figure that matters. Third comes the staffing guardrail, keeping requests to continuity, skills, and work authorization within the limits set out in section 6.

Table 20 gives the five steps to 90 days and the review after them, and each guards against a reaction. Contract terms do much of the work: the clauses that step four checks already say who bears the risk of losing named staff. The step tests them against the dependency map from step one before any change is agreed. Price discipline exists because a generic surcharge establishes neither the cost nor the continuity of the service. Scoring on reconciled evidence means that no statement moves a score until a buyer can check it.

An October 15 analysis by Mayer Brown points the same way. It advised companies that use staffing firms to place H-1B workers to review those relationships, and added: “Vendor contracts should include audit, cooperation, and indemnification rights.” Such rights are for each buyer to test with counsel, and the advice is not a finding about any supplier.

The supplier playbook

Suppliers, named or not, have eight steps too, each with an owner and a record of completion, and Table 21 gives the first four. The case inventory comes first because it protects workers and contracts at once, and the next two steps run off it. Filing follows because each certified case runs on its own clock. The worker briefing should tell no one that a change of employer or category is open to everyone. Records come fourth: the rules already require them, so the step readies existing files for an audit.

Supplier step four, audit-ready records, rests on existing duties. The PERM rule on record keeping sets how long each application and its supporting documents are kept, a duty Mintz stresses, and the rule on audits sets the time to produce them. For H-1B, the rule requires a public access file, kept open to public inspection for each labor condition application, within one working day of filing. The Department can order supervised recruitment, in which its certifying officer approves the advertisement and receives applications. Ogletree Deakins adds that applications go to the Department, not the employer.

Table 22 gives the remaining four supplier steps, which reach clients, payroll, the legal structure, and the controls an investigator would test. Three of the four turn on rules the supplier must already follow, so most of the work is evidence, not new policy. The traps are timing and shortcuts. Disclosure to clients should come before quarterly results calls invite the question in public. Benching a worker does not pause the duty to pay, and moving a filing to an affiliate is not a safe workaround (sections 6 and 9).

Supplier step six, pay the bench and terminate properly, turns on a bona fide termination, which section 6 describes. Until then an H-1B worker without assigned work must still be paid, under the H-1B wage rule on ending employment.

Owners and review points

Ownership is fixed on both sides. On the demand side, the CIO owns the service dependency map, procurement obtains evidence of replacement capacity, handover obligations, and escalation arrangements, and finance models retention, backfill, relocation, and transition costs separately. For the supplier, the delivery head owns the account exposure, and the chief human resources officer (CHRO) and immigration counsel own the worker case inventory. Boards on both sides need thresholds for intervention, such as a critical role without an eligible successor.

Review should be triggered by evidence, not by elapsed time. The playbooks are controls and review points, not a forecast of how the suspensions will end. Exhibit 4 attaches a trigger, a buyer response, a supplier response, and owners to each of five review points from October 8, at 30 days, 90 days, 12 months, 24 months, and 36 months. On Greyhound Research’s arithmetic, the 30-day point falls on November 7, after Infosys’s, Cognizant’s, and Capgemini’s scheduled results and before the November 10 grace-period comment deadline.

Three outcomes remain plausible: restrictions narrow as cases are clarified, prolonged investigations create sustained friction, or additional measures broaden the constraint. No probabilities are assigned, because the operative notices and case evidence were not public as of October 20, 2026, though the agencies may hold them. A calendar passing is not by itself evidence that any scenario has occurred. What should move the assessment is evidence: published notices, any documented remediation, court orders, actual staff departures, backfill performance, and changes in US hiring.

Greyhound Research’s September 2025 H-1B position

The reading that immigration risk is an operating risk is not new. Writing in September 2025 about the USD 100,000 H-1B fee, Greyhound Research argued: “Immigration risk can no longer be managed as an HR function. It now sits alongside cyber, supply chain, and energy as a board-level resilience issue.” A second piece the next day added that “the surcharge has shifted visa exposure from an HR compliance metric to a board-level resilience test.”

The PERM suspensions apply that pressure at a later stage of the immigration pipeline. On both sides of the contract the same conclusion follows: the response belongs with the people who own delivery, not with HR alone.

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Questions Ahead: Open Points For The Suppliers, Their Peers, And The Department

The playbooks run under uncertainty that only the Department of Labor, the White House, the named employers, and their peers can reduce. Thirteen questions remain open on the public record as of October 20, 2026. Two matter most, the authority cited for refusing new filings (question 1) and entity scope (question 4), because they decide who is exposed and from what date. Some answers sit in investigation files that agencies do not normally publish. Greyhound Research has not put these questions to the parties and records no answers.

1/ Which legal authority will the written notices cite for not accepting new filings, alongside the suspension of processing? Officials had not publicly cited a regulation as of October 20, 2026. On Greyhound Research’s reading, the provision that fits the announcement, 20 CFR 656.31(b), addresses the processing of applications, and the Department may rely on other provisions or notices not yet public. A written notice citing the authority would show employers and their clients whether new filings are handled under a regulation or a notice, and which review route applies.

2/ What conduct is alleged against each employer, and what would lead to processing resuming? Officials cited alleged fraud, and Vance spoke of representations he called fundamentally illegitimate, but as of October 20, 2026, the specific conduct alleged had not been published. A statement of conduct, when one can be made public, would show whether the issue is recruitment, wages, misrepresentation, or something else, and what, if anything, an employer would need to change.

3/ Are PERM suspensions in place for any employer that has not been publicly named? Cognizant’s suspension reached the public through the Inspector General before the October 8 list did, and investigations can limit what agencies make public. Tech Mahindra, which is not on the list, has said it received no suspension notice. An answer, where one can be given, would show how far buyers can rely on the published list when assessing suppliers not on it.

4/ Which legal entities and application cohorts does each suspension cover, from what date, and does it reach filings by affiliates or clients for a named employer’s workers? A certification belongs to a legal employer and a job, not to a brand, so the answer would settle whether subsidiaries and acquired businesses are inside each suspension and when each initial period ends. It would also settle whether the Department treats a filing by an affiliate or a client as one “involving” a suspended employer.

5/ How will the Department handle an initial period that ends without a settlement? Partly resolved. Cloudera’s case was resolved by the settlement announced on October 16, a negotiated two-year bar, although the agreement does not say whether its May suspension was lifted or extended. For the eight, the Department’s handling of an initial period that ends without a settlement would show whether it extends, lifts, or narrows a suspension and what it states when it does.

6/ Which datasets and counting rules underlie the figures officials cited on October 8? The datasets and counting rules had not been published, and the government may hold records the public cannot see. Microsoft’s president said, as a press report relayed it, that the Vice President was not accurately informed about Microsoft’s numbers. Published datasets would show how the 6,000 layoffs Vance cited, Sonderling’s almost 3 million requests, and Vance’s USD 20,000 and USD 48,000 pay gaps were counted. They would also show what defined the 1,000 applications that, in two accounts, Vance said appeared to overlap layoffs.

7/ What unit do the suppliers’ own visa figures count, and for which legal entities? A visa figure without its unit and its legal entities cannot be reconciled with the agencies’ files, so stated units and entities would let clients reconcile the companies’ accounts with USCIS’s and the Department’s records.

8/ Which matched jobs and workers stand behind the displacement allegations, by occupation and area? The layoff rule turns on a match of occupation, area, and a six-month window. Agencies may hold matched records that are not public, and they would settle whether the rule was followed at any named employer.

9/ Beyond the alleged fraud and the investigations officials cited for Adobe and Microsoft, how were the eight employers identified, and do layoff disclosures play any part? In the public files Greyhound Research tabulated, layoff disclosures do not separate the named employers from the unnamed, and the investigations officials cited are not public. A further account of the basis, where one can be given, would show whether the list follows disclosures, investigations, or other information, and whether suppliers not on it could be affected on the same basis.

10/ How large is each named employer’s PERM pipeline, stage by stage and by client service? Pending cases are not in the public files, and while the Department holds the applications filed with it, only the suppliers can tie them to each worker’s deadlines and to client services. Their counts by stage and service would settle where deadlines fall, how many workers they reach, and which clients depend on them. TCS’s single-digit PERM count over two years leaves stage, service, and entity open.

11/ Which customer obligations face a demonstrated staffing constraint, and what evidence supports any proposed cost change? The named employers’ public statements do not yet tie their cases to client services, so their specific answers would show whether clients face a staffing constraint, a cost change, both, or neither.

12/ Does the Justice Department investigation Infosys has disclosed relate to the PERM suspension? Infosys’s own filings do not connect the investigation to PERM. An answer from Infosys, or from the Justice Department or the Department of Labor where they are able to comment, would settle whether its clients face one issue or two.

13/ What explains Wipro’s 399 denials among its 410 cases decided in fiscal 2021, and its 169 denials in fiscal 2024, and does any of it touch the cases now stopped? The public file does not record the reasons for denials, which sit in the Department’s case records, and a denial is not a finding of misconduct. An answer from Wipro would show buyers whether the pattern bears on the cases now stopped.

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A Delivery Problem And A Pipeline Test: The Final Greyhound Standpoint

Greyhound Research’s final judgment is that the October 8 suspensions are a delivery problem for buyers, located in named people. For suppliers, named or not, they test whether their PERM pipelines and the evidence behind their recruitment and pay would stand scrutiny.

Greyhound Research credits enforcement on the programs’ own terms for what it shows buyers: whose recruitment and pay records stand up. A supplier whose records fail that test can be debarred, a continuity risk for its clients, so buyers should ask now for the evidence behind those records. Suspension terms that remain unpublished still add to buyers’ planning uncertainty. Buyers should treat neither the administration’s public counts as proof that any named company replaced American workers, nor the companies’ statements as proof that none did.

The judgment rests on three findings. First, the action is a processing suspension whose employer-level terms had not been published as of October 20, 2026. Second, the publicly testable figures officials cited count filings, approvals, and layoffs, not matched jobs, and the public accounts of the one overlap figure did not give the detail a matched test requires. As of October 20, 2026, the public official and company records reviewed showed neither the US layoff count cited for Microsoft nor a basis for reading the list as an H-1B ranking.

Third, on Greyhound Research’s count of the Department’s files, recent certifications are concentrated at Microsoft, 84 percent of the eight’s, with four services firms’ own-name US entities near zero. Pending cases, which the Department holds and its public file omits, could change that concentration.

On the agencies’ files, the recent weight of the action is likely to fall mostly on Microsoft, although four of the six services firms named are headquartered in India. A Greyhound Research estimate puts Indian nationals at about 56 percent of the eight’s latest certifications, a little above their 53 percent national share, and Chinese nationals at about 17 percent. Filing data describe outcomes and say nothing about intent, so Greyhound Research reads this distribution only as an outcome of the filing record.

Progress toward the aim officials stated, protecting US workers from displacement and lower pay, can be observed over time. Suppliers can recruit locally, retain staff, or move work, and the research cited in section 6 documents the last, so the mix cannot be assumed. Whether stopping these filings produces equivalent US hiring is an empirical question. Greyhound Research will track it through suppliers’ US hiring, added dependence on temporary sponsorship, recruitment and wage findings for US and sponsored workers in published enforcement records, and the costs to buyers, suppliers, and workers.

The judgment would move toward the concerns officials stated if notices, charging documents, or court records disclosed matched evidence of displacement, misrepresentation, or underpayment at named employers. It would move the other way if investigations closed, or courts ruled, without findings of such conduct at named employers. A long suspension, or an extension of any initial period, would add to buyers’ planning uncertainty without by itself showing the investigations’ outcome.

Greyhound Research will revisit this position at the first notice, a named supplier’s PERM counts by entity and stage, the Department’s next disclosure file, or a public decision on any initial period, whichever comes first.

For buyers the decision rule has four steps: map the business dependency, verify the sponsoring legal entity, obtain the supplier’s case counts by stage for each dependent service, and fund a proportionate continuity response. The same questions go to every sponsoring supplier, named or not, and they ask for PERM counts rather than H-1B totals.

↑ Back to the section guide

Annex: The Record Behind The Report

The annex holds the record behind the analysis: the supplementary H-1B counts, every legal and immigration point with its official text and practitioner verification, the method and its limits, and the terms used.

Supplementary counts: H-1B rankings

The H-1B rankings in circulation measure H-1B use, not PERM exposure, and each counts something different. They are the Senate and press rankings, the 2024 counts the press relayed from USCIS figures, and the Department’s labor condition application counts for fiscal 2024 and 2025 and the first half of fiscal 2026.

In fiscal 2025 the Senate figures rank TCS and Microsoft second and third, behind Amazon. One press report of US immigration data put TCS, Infosys, and Microsoft among the five largest employers of approved H-1B beneficiaries in fiscal 2026.

The Department’s statistics for fiscal 2025 rank employers by positions certified on labor condition applications, which also cover two smaller visa types. Only two of the eight appear in the top ten: Microsoft at 20,686 positions and Infosys Limited at 16,328, behind Amazon.com Services LLC at 60,036.

In fiscal 2024 three of the eight were in the top ten: Infosys, Cognizant at 11,305 positions, and Microsoft at 10,379. None was in the first half of fiscal 2026.

The other 2024 H-1B counts in circulation are also press relays of USCIS figures: 4,725 approvals for Microsoft, 6,321 for Cognizant, and 2,795 for Capgemini America. None says whether it counts initial employment, extensions, or both.

Legal and immigration points, with their verification

Each point is listed with the official text that states or anchors it and the practitioner analysis that reads it the same way. Verification ran from October 9 to 12, 2026, and cited regulations were re-read through October 20, 2026, as each reference’s access date shows. A basis line marks a point that rests on practitioners or on the official text alone, or on Greyhound Research’s own reading where no practitioner had addressed it. None of it is legal advice for an individual case.

1/ H-1B degree requirement. A specialty occupation needs at least a bachelor’s degree in the specific specialty or its equivalent. Official: 8 U.S.C. 1184(i). Practitioners: Watson Immigration Law and Lincoln-Goldfinch Law.

2/ H-1B cap and six-year limit. 65,000 new cap-subject workers a year plus 20,000 for holders of US master’s or higher degrees, and admission of up to six years. Official: 8 U.S.C. 1184(g). Practitioners: Watson Immigration Law and Lincoln-Goldfinch Law.

3/ Labor condition application before the petition. The employer obtains the Department’s certification of the application, then files its H-1B petition. Official: 20 CFR 655.700(b). Practitioners: Klasko Immigration Law Partners.

4/ Seven-day review for completeness and obvious errors. The Department reviews applications within seven working days for completeness and obvious errors and is not the guarantor of their accuracy. Official: 20 CFR 655.740. Practitioners: Klasko Immigration Law Partners. Basis: Klasko Immigration Law Partners addresses the seven-day review only, and the guarantor limb rests on the regulation.

5/ No H-1B recruitment duty for most employers. Only H-1B-dependent employers and willful violators must recruit US workers, and not for applications used only for exempt workers. Official: Fact Sheet 62O, Fact Sheet 62C, and 20 CFR 655.737. Practitioners: Reddy Neumann Brown.

6/ PERM labor market test. The Secretary of Labor must certify two things. First, that there are “not sufficient workers who are able, willing, qualified (or equally qualified in the case of an alien described in clause (ii)) and available.” Second, that the employment will not adversely affect the wages and working conditions of similarly employed US workers. Official: 8 U.S.C. 1182(a)(5)(A). Practitioners: Headman Law Group, for the first test.

7/ PERM recruitment window. The job order and two Sunday advertisements run at least 30 and no more than 180 days before filing. Three further steps are required, none more than 180 days before filing and at most one wholly within the last 30 days. Official: 20 CFR 656.17(e). Practitioners: Reddy Neumann Brown.

8/ Layoff disclosure. An employer with a layoff in the area within six months of filing, in the occupation or a related one, must document that it notified and considered all potentially qualified laid-off US workers. The PERM form asks the question. Official: 20 CFR 656.17(k) and the Form ETA-9089 instructions. Practitioners: Cyrus D. Mehta & Partners and Richards and Jurusik Immigration Law. Basis: that a yes on the form records a disclosure rather than a finding, and that a denial decides an application rather than finding misconduct, is Greyhound Research’s own reading.

9/ Priority date and visa limits. The priority date is the date the Department accepted the labor certification application for processing. EB-2 and EB-3 each get 28.6 percent of the employment-based worldwide level of at least 140,000 a year, and one country is capped at 7 percent. Official: 8 CFR 204.5(d), 8 U.S.C. 1151(d), 8 U.S.C. 1153(b), and 8 U.S.C. 1152(a)(2). Practitioners: Headman Law Group and Shusterman Law.

10/ Certification validity and 180-day filing limit. A certification is valid only for its job, worker, and area, and expires unless filed with an I-140 within 180 calendar days. Official: 20 CFR 656.30. Practitioners: Visa-Pros and Headman Law Group.

11/ Extensions beyond six years. One-year extensions need a qualifying filing at least 365 days before the extension would take effect, and three-year extensions need an approved I-140 held back by visa limits. Official: Public Law 106-313 and the 2016 final rule. The implementing regulation, 8 CFR 214.2(h)(13)(iii)(D) and (E), is cited by practitioners and could not be opened. Practitioners: Troutman Sanders and Lehigh Valley Immigration Law.

12/ Suspension of processing. The Department may suspend processing for an employer it refers for investigation, or learns is under investigation, for possible fraud or willful misrepresentation in connection with PERM, initially for up to 180 days. Official: 20 CFR 656.31(b). Practitioners: WR Immigration and Colombo & Hurd, which reports that officials did not name the regulation. Basis: likely authority. Officials had not cited it publicly as of October 20, 2026, and any written notices to employers were not public.

13/ Debarment. A bar of up to three years requires a written notice. Official: 20 CFR 656.31(f). Practitioners: Samper Law.

14/ Suspension is not a finding and does not end H-1B status. Official: 20 CFR 656.31(b), which concerns applications only. Practitioners: Reddy Neumann Brown, Lehigh Valley Immigration Law, Visa-Pros, and, on the first point only, Samper Law. Basis: the regulation does not address H-1B status, so this point rests on practitioners, with the regulation’s scope as the official anchor.

15/ I-140 revocation and priority date. An approval 180 days old survives withdrawal but not invalidation of the certification, and the priority date is lost on revocation for fraud, misrepresentation, material error, or revoked or invalidated certification. Official: 8 CFR 205.1(a)(3)(iii) and 8 CFR 204.5(e)(2). Practitioners: Troutman Sanders.

16/ Portability. An H-1B worker in status may start with a new employer once a new, nonfrivolous petition is filed before the authorized stay ends. Once adjustment has been pending 180 days, an I-140 stays valid for a similar job. Without that, the new employer files its own PERM, though an approved I-140 generally keeps its priority date. Official: 8 U.S.C. 1184(n), 8 U.S.C. 1154(j), and 8 CFR 204.5(e). Practitioners: Reddy Neumann Brown and Lehigh Valley Immigration Law.

17/ Grace period. Up to 60 consecutive days or the end of the authorized stay, whichever is shorter, once per validity period, discretionary, and without work unless otherwise authorized. A proposal to remove it is not yet in effect, and the current rule stays in place until a final rule. Official: 8 CFR 214.1(l)(2) and the September 11 proposal. Practitioners: Cozen O’Connor, Berry Appleman & Leiden, and Troutman Sanders.

18/ Deference to prior approvals in extensions. Current 8 CFR 214.1(c)(5) generally gives deference to a prior approval involving the same facts when USCIS decides an extension, and a proposal of October 14, 2026, would remove it. Official: the proposed rule. Practitioners: the American Immigration Lawyers Association, which records its publication and the November 13 comment deadline. Basis: the description of the current rule is the proposal’s own, since the regulation’s text was not opened.

19/ Wage proposal. Level I would rise from the 17th to the 34th percentile, comments closed on May 26, 2026, and no final rule had appeared on the Federal Register’s public inspection lists through October 19, 2026. Official: the proposed rule and the regulatory agenda. Practitioners: Fragomen.

20/ Wage levels. The level follows the job’s stated requirements against the occupation’s, not the worker’s pay. Official: prevailing wage guidance. Practitioners: Reddy Neumann Brown.

21/ Pay for benched H-1B workers and bona fide termination. Nonproductive time caused by lack of work must be paid until a bona fide termination. Practitioners describe it as ending the employment, notifying USCIS, and paying for the trip home where required, though they differ on some of the steps. Official: Fact Sheet 62I and 20 CFR 655.731(c)(7)(ii). Practitioners: Berardi Immigration Law and Cyrus D. Mehta & Partners.

22/ Payments for PERM costs. An employer may not take payment for PERM work, with a narrow exception for a party that benefits through an established business relationship. Official: 20 CFR 656.12(b). Practitioners: Cyrus D. Mehta & Partners. Greyhound Research found no practitioner, in the analyses it reviewed to October 19, 2026, who endorses client funding as a response to the suspension.

23/ Records and public access file. PERM files are kept at least five years from filing, and an H-1B public access file is available within one working day of filing. Official: 20 CFR 656.10(f) and 20 CFR 655.760. Practitioners: Mintz for PERM records and Reddy Neumann Brown for the public access file.

24/ Audits and supervised recruitment. The Department may audit any case with 30 days to respond and may order supervised recruitment. Official: 20 CFR 656.20 and 20 CFR 656.21. Practitioners: Ogletree Deakins.

25/ Employer identity, successors, and refiling. A PERM employer needs its own FEIN. Successors must document their takeover of the business, show the job is unchanged, and prove eligibility. Under 2019 guidance that predates the FLAG system, a withdrawn case is refiled for the same worker and job only after the Department confirms the withdrawal. Official: 20 CFR 656.3 and PERM FAQ Round 14. Practitioners: Capitol Immigration Law Group and Berardi Immigration Law. Basis: the successor rule rests on practitioners, since neither official text states it. That an affiliate or client could file only as the worker’s real intended employer is Greyhound Research’s own reading of 20 CFR 656.3. Whether such a filing “involves” a suspended employer is an open question no practitioner had addressed in the analyses reviewed to October 19, 2026.

26/ Anti-discrimination limits on staffing requests. Citizenship-only hiring is lawful only where a law, regulation, executive order, or government contract requires it, or the Attorney General determines it essential to doing business with a government agency. Employers, and those who recruit or refer for a fee, are covered when they have four or more employees. The Justice Department warns that preferences for visa holders also risk violating the law. Official: 8 U.S.C. 1324b, the Justice Department’s guidance and fact sheet. Practitioners: Littler Mendelson and Mayer Brown. Basis: no official guidance that Greyhound Research located by October 12, 2026, addresses a client’s request to exclude visa holders, so on its reading such a request is a matter for counsel.

27/ New filings. Sonderling said new applications involving the eight would not be accepted. The suspension provision addresses the processing of applications, and debarment requires a written notice. Officials had not publicly cited the authority for the step on new filings as of October 20, 2026, and the Department may rely on provisions or notices not yet public. Official: 20 CFR 656.31(b) and (f). Practitioners: WR Immigration, which advises confirming the authority in the written notices, and Meltzer Hellrung. Basis: the practitioners listed treat the authority as unconfirmed. That the text does not expressly address new filings outside debarment is Greyhound Research’s own reading of the public text, and the written notices may cite authority that settles the point.

28/ Layoff scrutiny for H-1B sponsors. Executive Order 14431, signed September 18, 2026, directs the Departments of State, Labor, and Homeland Security to “take into account” whether an H-1B employer sponsor “directly or indirectly engaged in layoffs within the previous year.” That clause continues, “or plans future layoffs that negatively affect the employment of similarly situated United States workers.” The order does not mention PERM. Official: Executive Order 14431. Practitioners: Morgan Lewis.

29/ H-1B required wage. The employer pays the higher of the prevailing wage and its actual wage for similarly employed workers. Official: 8 U.S.C. 1182(n), 20 CFR 655.731, and Fact Sheet 62G. Practitioners: Klasko Immigration Law Partners.

Research method and limitations

Greyhound Research reviewed the White House listings at 3:05 a.m. ET on October 11, 2026, and the Department of Labor’s channels and the Federal Register at 3:17 a.m. ET. News coverage was reviewed to the end of that day. The Federal Register’s public inspection list was unavailable until October 13, and the Department of Labor’s newsroom listing showed no current pages. From 3:12 to 3:27 a.m. ET on October 12, 2026, Greyhound Research reviewed the official, company, lawmaker, litigation, rulemaking, and peer channels it had searched before and found nothing new.

Greyhound Research’s initial work ran over four days. On October 9, it reviewed the published record, Greyhound Research’s own published positions, and the figures in circulation that it identified. Its October 10 work covered new developments, the named suppliers’ filings, unnamed peers, the rules governing workers’ cases, official program data, press counts, layoff and headcount figures, and the legal differences between H-1B and PERM. Later that day it tabulated the agencies’ PERM and H-1B employer files. On October 11, it confirmed that every finding was still current and verified every legal point.

October 12 brought a repeat of that confirmation and three further official sources, obtained as downloads that day. The first two are the Department’s labor condition application files for fiscal 2025 and the first three quarters of fiscal 2026, and its Wage and Hour Division’s compliance action file, both tabulated. Third come the seven layoff notices Microsoft filed with Washington State from May 2025 to September 2026, each read in full. State records for California, Maryland, and Texas followed on October 14. Each tabulation is defined in its table or exhibit.

Counted across all visa classes, the labor condition application tabulation reproduces the Department’s published fiscal 2025 position totals for Microsoft and Oracle America. Table 10 counts H-1B forms only: Microsoft’s 9,192 forms cover 20,577 positions, against the published 20,686.

Every company grouping in that tabulation was checked name by name against the employer names filed. In its author archive and web searches to October 19, 2026, Greyhound Research found no earlier published position of its own on PERM. Its pieces of September 20 and 21, 2025, on the H-1B fee, cited in section 10, do not address it. No interviews, surveys, or direct outreach were conducted, and no Greyhound Pulse or Greyhound Fieldnotes evidence is cited.

On October 19, 2026, Greyhound Research searched the same channels for developments since October 12. It also read the Federal Register’s public inspection lists for October 9 and October 13 to 16, and re-read the cited sources most likely to change. The search found the Cloudera settlement, statements by HCLTech, Wipro, and Microsoft’s president, two lawmakers’ statements of October 8 and 9 it had missed, a proposed rule, and an executive order. A final check ending at 2:13 a.m. ET on October 20, 2026, found no new development on the suspensions.

Operative employer notices, matched payroll records, an entity map, and a deduplicated count of affected workers were not public as of October 20, 2026, though agencies and companies may hold them.

The PERM files record decisions, not cases pending at June 30, 2026, and publish nationality and wage level only for cases filed before June 2023. They rest on employers’ own answers, and the USCIS files after fiscal 2022 were partial or unavailable in the format read. The labor condition application files record applications and positions sought, not workers hired, and the Wage and Hour Division’s public file records concluded cases only, not open investigations.

A finding that something was not found means not found in the channels named and on the pages Greyhound Research could reach at each search. It could not open reuters.com, uscis.gov, nasscom.in, or mea.gov.in directly. Instead, it read their content through the republications, reports, and downloaded files the reference list names. Agencies and companies hold records that are not public, such as investigation and audit files, and the findings describe only the public record.

Some channels could not be reached at all. Greyhound Research could not open the Senate Judiciary Committee’s press pages on October 19 and 20 or search court dockets. Its nil findings on lawmakers’ statements and lawsuits therefore rest on news, practitioner, and lawmaker sources. New York’s layoff notice dashboard shows notices only in an interactive viewer, so the October 14 search could not be repeated or retained in a later read.

Terms used in this research report

AC21. The American Competitiveness in the Twenty-first Century Act of 2000, which allows H-1B extensions beyond six years for workers in the green card process.

Attestation. A promise an employer makes on a form, such as the wage it will pay. The Department of Labor reviews it for completeness and obvious inaccuracies and can examine it later through investigations and audits.

Bona fide termination. The ending of an H-1B employment that stops the employer’s duty to pay the required wage. Practitioners and the Department of Labor describe it as ending the employment, notifying USCIS, and paying for the trip home where the rules require it, and practitioners differ on some of the steps.

CFR. Code of Federal Regulations.

CHRO. Chief human resources officer.

CIO. Chief information officer.

Debarment. A bar of up to three years from the PERM program, imposed by written notice.

DHS. US Department of Homeland Security.

DOJ. US Department of Justice.

DOL. US Department of Labor.

EB-2, EB-3. Employment-based second and third preference green card categories, which generally require a labor certification.

ET. Eastern Time, the US time zone in which this research report gives times (daylight time in October 2026).

Exempt H-1B worker. An H-1B worker paid at least USD 60,000 a year or holding a master’s or higher degree related to the job. H-1B-dependent employers need not make the extra recruitment and non-displacement promises on an application used only for such workers.

FEIN. Federal Employer Identification Number, the tax number that identifies a US employer.

Fiscal year. The US government year from October 1 to September 30, unless a company’s own year is named. Fiscal 2026 began on October 1, 2025. Microsoft’s fiscal year ends on June 30, and Infosys’s and Wipro’s on March 31.

FLAG. The Foreign Labor Application Gateway, the Department of Labor’s online system for filing labor certification applications.

Grace period. A discretionary period of up to 60 consecutive days, or until the authorized stay ends if sooner, after H-1B employment ends. During it, a worker may stay, without working unless otherwise authorized, while seeking a change.

H-1B. A temporary work classification for specialty occupations.

H-1B dependent employer. An employer whose workforce includes a high share of H-1B workers, which must make extra promises on recruitment and non-displacement.

HCLTech. HCL Technologies, which trades as HCLTech. Its US subsidiary is HCL America.

HR. Human resources.

I-140. The employer’s immigrant petition, filed after a labor certification is granted. Approval is not itself a green card.

IER. The Justice Department’s Immigrant and Employee Rights Section, which enforces the law against citizenship and national-origin discrimination in hiring.

Initial and continuing approvals. USCIS counts of H-1B petitions approved for new employment, and for extensions, amendments, or changes of employer.

L-1. A temporary classification for employees transferred within a company.

LCA. Labor condition application, the employer’s H-1B wage and working-conditions attestation to the Department of Labor.

NASSCOM. The Indian technology industry body.

OEM. Original equipment manufacturer.

OFLC. The Department of Labor’s Office of Foreign Labor Certification.

PERM. Program Electronic Review Management, the Department of Labor’s permanent labor certification process.

Portability. A worker’s ability to change employers while keeping status or a pending green card case, under defined conditions.

Prevailing wage level. One of four Department of Labor wage levels assigned to a job from its stated requirements, Level I being entry level and Level IV the highest.

Principal entity. The US employer names Greyhound Research grouped under each company after a name-by-name review. For the eight named employers, Tech Mahindra, and LTIMindtree, these are the entities filing under the company’s own name, including same-brand subsidiaries such as Infosys Public Services, HCL America Solutions, and Wipro VLSI Design Services. Earlier names count too: Tata America International for TCS and iGATE for Capgemini. The other comparison employers are grouped under their main operating entities, with A2Z Development Center for Amazon. Businesses filing under other names, such as Microsoft’s LinkedIn and GitHub and, in the PERM file, Cognizant’s TriZetto Corporation, are excluded unless stated.

Priority date. The date that fixes a worker’s place in the green card queue, generally the date the labor certification was filed.

Public access file. The records an H-1B employer must make available for public inspection for each labor condition application.

Secondary entity. The labor condition application’s term for a company other than the employer at whose worksite the H-1B worker will be placed, called a client site in the tables.

Successor in interest. An employer that has taken over the business behind a job. As practitioners describe it, such an employer may rely on the earlier labor certification if it documents the takeover, shows the job is unchanged, and proves eligibility, including ability to pay.

Supervised recruitment. Recruitment run under the direction of a Department of Labor certifying officer, who approves the advertisement and receives the applications.

TCS. Tata Consultancy Services.

USCIS. US Citizenship and Immigration Services.

Visa Bulletin. The State Department’s monthly list of the priority dates that may receive green cards, by category and country.

Wage and Hour Division. The Department of Labor division that enforces the H-1B program’s wage and attestation rules and publishes a database of its concluded cases.

WARN notice. A notice under the Worker Adjustment and Retraining Notification Act, which requires an employer to give the state and the workers affected 60 days’ notice of a mass layoff.

↑ Back to the section guide

Sources And References: Every Document Behind Every Claim

Public sources reviewed through October 20, 2026 are grouped by what each class of evidence can establish. Every source named in a sentence is hyperlinked there as well as listed here. Where this research report states that something was not found or is not public, the statement is bounded by the documents listed and the dates shown. It does not extend to records the agencies or companies may hold. Where a publisher’s page refused automated retrieval, its entry says so and names the republication, report, or downloaded file read instead.

A. Official records

These establish what an authority published or a court found, within its jurisdiction and as of its date. They cannot establish records an agency holds but has not published, such as investigation and audit files. Pages that change, such as current regulations and notice files, show the date they were read.

California Employment Development Department (2026) Worker Adjustment and Retraining Notification (WARN). Files “2024-2025 WARN Report from July 01, 2024 through June 30, 2025” and “2025-2026 WARN Report from July 01, 2025 through June 30, 2026”. WARN page, files retrieved October 14, 2026. Accessed October 20, 2026. Available at: https://edd.ca.gov/en/jobs_and_training/Layoff_Services_WARN/

Congressional Research Service (2025) The H-1B Visa for Specialty Occupation Workers. In Focus IF12912, version 2, February 18, 2025. Available at: https://www.congress.gov/crs_external_products/IF/PDF/IF12912/IF12912.2.pdf

Electronic Code of Federal Regulations (2026a) 8 CFR 204.5 Petitions for employment-based immigrants. Paragraphs (d) and (e). Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-8/chapter-I/subchapter-B/part-204/subpart-A/section-204.5

Electronic Code of Federal Regulations (2026b) 8 CFR 205.1 Automatic revocation. Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-8/chapter-I/subchapter-B/part-205/section-205.1

Electronic Code of Federal Regulations (2026c) 8 CFR 214.1 Requirements for admission, extension, and maintenance of status. Current text, up to date as of October 15, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-8/chapter-I/subchapter-B/part-214/subpart-A/section-214.1

Electronic Code of Federal Regulations (2026d) 8 CFR 214.2 Special requirements for admission, extension, and maintenance of status. Current text, up to date as of October 16, 2026. Section heading only: paragraph (h)(13)(iii) could not be retrieved. The H-1B extension rules are therefore described from the 2000 law and the 2016 final rule behind them. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-8/chapter-I/subchapter-B/part-214/subpart-A/section-214.2

Electronic Code of Federal Regulations (2026e) 20 CFR 639.3 Definitions. Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/chapter-V/part-639/section-639.3

Electronic Code of Federal Regulations (2026f) 20 CFR 655.700 What statutory provisions govern the employment of H-1B, H-1B1, and E-3 nonimmigrants and how do employers apply for H-1B, H-1B1, and E-3 visas? Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/section-655.700

Electronic Code of Federal Regulations (2026g) 20 CFR 655.730 What is the process for filing a labor condition application? Current text, up to date as of October 15, 2026. Accessed October 19, 2026. Available at: https://www.ecfr.gov/current/title-20/section-655.730

Electronic Code of Federal Regulations (2026h) 20 CFR 655.731 What is the first LCA requirement, regarding wages? Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/section-655.731

Electronic Code of Federal Regulations (2026i) 20 CFR 655.737 What are “exempt” H-1B nonimmigrants, and how does their employment affect the additional attestation obligations of H-1B-dependent employers and willful violator employers? Current text, up to date as of October 15, 2026. Accessed October 19, 2026. Available at: https://www.ecfr.gov/current/title-20/section-655.737

Electronic Code of Federal Regulations (2026j) 20 CFR 655.740 What actions are taken on labor condition applications? Current text, up to date as of October 15, 2026. Accessed October 19, 2026. Available at: https://www.ecfr.gov/current/title-20/chapter-V/part-655/subpart-H/section-655.740

Electronic Code of Federal Regulations (2026k) 20 CFR 655.760 What records are to be made available to the public, and what records are to be retained? Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/section-655.760

Electronic Code of Federal Regulations (2026l) 20 CFR 656.3 Definitions, for purposes of this part, of terms used in this part. Current text, up to date as of October 15, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/chapter-V/part-656/subpart-A/section-656.3

Electronic Code of Federal Regulations (2026m) 20 CFR 656.10 General instructions. Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/section-656.10

Electronic Code of Federal Regulations (2026n) 20 CFR 656.12 Improper commerce and payment. Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/chapter-V/part-656/subpart-C/section-656.12

Electronic Code of Federal Regulations (2026o) 20 CFR 656.17 Basic labor certification process. Current text, up to date as of October 15, 2026. Also rechecked on October 13, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/chapter-V/part-656/subpart-C/section-656.17

Electronic Code of Federal Regulations (2026p) 20 CFR 656.20 Audit procedures. Current text, up to date as of October 16, 2026. Also rechecked on October 13, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/section-656.20

Electronic Code of Federal Regulations (2026q) 20 CFR 656.21 Supervised recruitment. Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/section-656.21

Electronic Code of Federal Regulations (2026r) 20 CFR 656.30 Validity of and invalidation of labor certifications. Current text, up to date as of October 15, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/chapter-V/part-656/subpart-C/section-656.30

Electronic Code of Federal Regulations (2026s) 20 CFR 656.31 Labor certification applications involving fraud, willful misrepresentation, or violations of this part. Current text, up to date as of October 16, 2026. Accessed October 20, 2026. Available at: https://www.ecfr.gov/current/title-20/chapter-V/part-656/subpart-C/section-656.31

Executive Office of the President (2026) Enhancing Program Integrity and Interagency Coordination in the Administration of the H-1B Nonimmigrant Visa Program. Executive Order 14431, September 18, 2026. Public inspection document 2026-19555, published September 23, 2026. Available at: https://public-inspection.federalregister.gov/2026-19555.pdf

Grassley, C. E. and Durbin, R. J. (2025) Letter to Satya Nadella, Chief Executive Officer, Microsoft Corp., on H-1B hiring (untitled letter). US Senate Committee on the Judiciary, September 24, 2025. Available at: https://www.grassley.senate.gov/download/grassley-durbin-to-microsoft_-h-1b?download=1

Maryland Department of Labor (2026) Work Adjustment and Retraining Notification (WARN) and Other Dislocation Notices. Logs for 2025 and 2026. Division of Workforce Development and Adult Learning, retrieved October 14, 2026. Accessed October 19, 2026. Available at: https://labor.maryland.gov/employment/warn.shtml

New York State Department of Labor (2026) WARN Dashboard. Notices filed in New York State, searched October 14, 2026. Accessed October 20, 2026. Available at: https://dol.ny.gov/warn-dashboard

Office of Information and Regulatory Affairs (2026) Improving Wage Protections for the Temporary and Permanent Employment of Certain Foreign Nations in the United States. Title as served, “Nations” for “Nationals”. RIN 1205-AC30. Unified Agenda entry, page headed “View Rule”, Publication ID 2026 (agenda publication 202510). Accessed October 20, 2026. Available at: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=1205-AC30

Office of the Federal Register (2026) Public Inspection. Document lists for October 9, 13, 14, 15, 16, and 19, 2026. Federal Register public inspection desk. Accessed October 20, 2026. Available at: https://www.federalregister.gov/public-inspection/2026/10/13

Texas Workforce Commission (2026) Worker Adjustment and Retraining Notification (WARN) Notices. Data set, Texas Open Data Portal, rows updated July 7, 2026, retrieved October 14, 2026. Accessed October 20, 2026. Available at: https://data.texas.gov/d/8w53-c4f6

United States Code (2023a) 8 U.S.C. 1152, Numerical limitations on individual foreign states. Subsection (a)(2). 2023 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2023-title8/html/USCODE-2023-title8-chap12-subchapII-partI-sec1152.htm

United States Code (2023b) 8 U.S.C. 1154, Procedure for granting immigrant status. Subsection (j). 2023 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2023-title8/html/USCODE-2023-title8-chap12-subchapII-partI-sec1154.htm

United States Code (2023c) 8 U.S.C. 1184, Admission of nonimmigrants. Subsection (n), Increased portability of H-1B status. 2023 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2023-title8/html/USCODE-2023-title8-chap12-subchapII-partII-sec1184.htm

United States Code (2023d) 8 U.S.C. 1324b, Unfair immigration-related employment practices. 2023 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2023-title8/html/USCODE-2023-title8-chap12-subchapII-partVIII-sec1324b.htm

United States Code (2024a) 8 U.S.C. 1151, Worldwide level of immigration. Subsection (d). 2024 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2024-title8/pdf/USCODE-2024-title8-chap12-subchapII-partI-sec1151.pdf

United States Code (2024b) 8 U.S.C. 1153, Allocation of immigrant visas. Subsections (b)(2) and (b)(3). 2024 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2024-title8/html/USCODE-2024-title8-chap12-subchapII-partI-sec1153.htm

United States Code (2024c) 8 U.S.C. 1182, Inadmissible aliens. Subsections (a)(5)(A) and (n)(1). 2024 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2024-title8/html/USCODE-2024-title8-chap12-subchapII-partII-sec1182.htm

United States Code (2024d) 8 U.S.C. 1184, Admission of nonimmigrants. Subsections (g) and (i). 2024 edition. Available at: https://www.govinfo.gov/content/pkg/USCODE-2024-title8/html/USCODE-2024-title8-chap12-subchapII-partII-sec1184.htm

United States Congress (2000) American Competitiveness in the Twenty-first Century Act of 2000. Public Law 106-313, sections 104(c), 106(a) and 106(b), October 17, 2000. Available at: https://www.govinfo.gov/content/pkg/PLAW-106publ313/html/PLAW-106publ313.htm

US Attorney’s Office, District of South Carolina (2023) Larsen & Toubro Technology Services Pays $9,928,000 To Resolve False Claims Act Allegations. Press release, April 10, 2023. Available at: https://www.justice.gov/usao-sc/pr/larsen-toubro-technology-services-pays-9928000-resolve-false-claims-act-allegations

US Citizenship and Immigration Services (n.d.) H-1B Employer Data Hub. Export files, fiscal years 2009 to 2023. Files retrieved October 10, 2026. The hub page could not be opened by automated retrieval. Accessed October 10, 2026. Available at: https://www.uscis.gov/tools/reports-and-studies/h-1b-employer-data-hub

US Department of Homeland Security, US Citizenship and Immigration Services (2016) Retention of EB-1, EB-2, and EB-3 Immigrant Workers and Program Improvements Affecting High-Skilled Nonimmigrant Workers. Final rule, 81 FR 82398, November 18, 2016. Available at: https://www.federalregister.gov/documents/2016/11/18/2016-27540/retention-of-eb-1-eb-2-and-eb-3-immigrant-workers-and-program-improvements-affecting-high-skilled

US Department of Homeland Security, US Citizenship and Immigration Services (2026a) Eliminating the Discretionary 60-Day Grace Period. Proposed rule, 91 FR 57807, Docket USCIS-2026-0364, September 11, 2026. Available at: https://www.federalregister.gov/documents/2026/09/11/2026-18631/eliminating-the-discretionary-60-day-grace-period

US Department of Homeland Security, US Citizenship and Immigration Services (2026b) Removing Deference to Prior USCIS Determinations of Eligibility. Proposed rule, public inspection document 2026-20941, RIN 1615-AD26, published October 14, 2026, at 91 FR 65119. Available at: https://public-inspection.federalregister.gov/2026-20941.pdf

US Department of Justice, Civil Rights Division, Immigrant and Employee Rights Section (2015) Types of Discrimination. Web page, published August 6, 2015, updated January 18, 2017. Available at: https://www.justice.gov/crt/types-discrimination

US Department of Justice, Civil Rights Division, Immigrant and Employee Rights Section (2024) Information for Employers About Citizenship Status Discrimination. Employer fact sheet, updated April 2024. Available at: https://www.justice.gov/crt/page/file/1080256/dl

US Department of Justice, Civil Rights Division, Immigrant and Employee Rights Section, US Department of Labor and Cloudera, Inc. (2026) Settlement Agreement. United States v. Cloudera, Inc., OCAHO Case No. 2026B00044. Signed by Cloudera (dated October 8, 2026, as the text reads), the Department of Labor (October 12, 2026), and the Justice Department (October 13, 2026, the effective date). Available at: https://www.justice.gov/crt/media/1465571/dl

US Department of Justice, Office of Public Affairs (2021) Justice, Labor Departments Reach Settlements with Facebook Resolving Claims of Discrimination Against U.S. Workers and Potential Regulatory Recruitment Violations. Press release, October 19, 2021. Available at: https://www.justice.gov/opa/pr/justice-labor-departments-reach-settlements-facebook-resolving-claims-discrimination-against

US Department of Justice, Office of Public Affairs (2023) Justice Department Secures $25 Million Landmark Agreement with Apple to Resolve Employment Discrimination Allegations Based on Citizenship Status. Press release 23-1261, November 9, 2023. Archived page, updated February 6, 2025. Available at: https://www.justice.gov/archives/opa/pr/justice-department-secures-25-million-landmark-agreement-apple-resolve-employment

US Department of Justice, Office of Public Affairs (2026a) Civil Rights Division Secures Settlement with OpenAI for Discriminating Against U.S. Workers. Press release 26-884, August 4, 2026. Available at: https://www.justice.gov/opa/pr/civil-rights-division-secures-settlement-openai-discriminating-against-us-workers

US Department of Justice, Office of Public Affairs (2026b) Civil Rights Division Sues Cloudera for Excluding U.S. Workers from Applying to High-Paying Technology Jobs. Press release 26-409, April 28, 2026. Available at: https://www.justice.gov/opa/pr/civil-rights-division-sues-cloudera-excluding-us-workers-applying-high-paying-technology

US Department of Justice, Office of Public Affairs (2026c) U.S Departments of Justice and Labor Secure Settlement with Cloudera, Enforce Two-Year PERM Debarment & Back Pay Following Discrimination Against U.S. Workers. Press release 26-1166, October 16, 2026. Available at: https://www.justice.gov/opa/pr/us-departments-justice-and-labor-secure-settlement-cloudera-enforce-two-year-perm-debarment

US Department of Justice, US Attorney’s Office for the Eastern District of Texas (2013) Indian Corporation Pays Record Amount To Settle Allegations Of Systemic Visa Fraud And Abuse Of Immigration Processes. Press release, October 30, 2013. Updated March 12, 2015. Available at: https://www.justice.gov/usao-edtx/pr/indian-corporation-pays-record-amount-settle-allegations-systemic-visa-fraud-and-abuse

US Department of Labor (2026) US departments of Labor, Justice announce enforcement actions against Cloudera Inc. for alleged Immigration and Nationality Act violations. News release 26-734-NAT, May 12, 2026. Available at: https://www.dol.gov/newsroom/releases/eta/eta20260512

US Department of Labor (n.d.) Secretary of Labor Keith Sonderling. Office of the Secretary page. Accessed October 20, 2026. Available at: https://www.dol.gov/agencies/osec

US Department of Labor, Employment and Training Administration (2009) Prevailing Wage Determination Policy Guidance, Nonagricultural Immigration Programs. Revised November 2009. Available at: https://www.dol.gov/sites/dolgov/files/eta/oflc/pdfs/npwhc_guidance_revised_11_2009.pdf

US Department of Labor, Employment and Training Administration (2023) Application for Permanent Employment Certification, Form ETA-9089: General Instructions. OMB Control Number 1205-0451, file dated June 1, 2023. Available at: https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/Form%20ETA-9089%20-%20General%20Instructions%20-%20508%20Compliant%20-%2006.01.2023.pdf

US Department of Labor, Employment and Training Administration (2026) Improving Wage Protections for the Temporary and Permanent Employment of Certain Foreign Nationals in the United States. Proposed rule, 91 FR 15454, Docket ETA-2026-0001, March 27, 2026. Available at: https://www.federalregister.gov/d/2026-06017

US Department of Labor, Office of Foreign Labor Certification (2019) 2019 PERM FAQs Round 14: Withdrawals, Requests for Reconsideration or BALCA Review, and Pay Differentials. May 13, 2019. Available at: https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/PERM_FAQ-Round-14_051419.pdf

US Department of Labor, Office of Foreign Labor Certification (2024) LCA (H-1B, H-1B1, and E-3) Temporary Specialty Occupations Program, Selected Statistics, Fiscal Year (FY) 2024. Statistical report, data as of September 30, 2024. Available at: https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/LCA_Selected_Statistics_FY2024_Q4.pdf

US Department of Labor, Office of Foreign Labor Certification (2025a) LCA (H-1B, H-1B1, and E-3) Temporary Specialty Occupations Program, Selected Statistics, Fiscal Year (FY) 2025. Statistical report, data as of September 30, 2025. Available at: https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/LCA_Selected_Statistics_FY2025_Q4.pdf

US Department of Labor, Office of Foreign Labor Certification (2025b) PERM Selected Statistics FY2025 Q4. Statistical report, data as of September 30, 2025. Available at: https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/PERM_Selected_Statistics_FY2025_Q4.pdf

US Department of Labor, Office of Foreign Labor Certification (2026a) LCA (H-1B, H-1B1, and E-3) Temporary Specialty Occupations Program, Selected Statistics, Fiscal Year (FY) 2026 Q2. Statistical report, data as of March 31, 2026. Available at: https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/LCA_Selected_Statistics_FY2026_Q2.pdf

US Department of Labor, Office of Foreign Labor Certification (2026b) OFLC Releases Public Disclosure Data and Selected Program Statistics for Q3 of Fiscal Year 2026. Announcement, August 14, 2026. Available at: https://www.dol.gov/agencies/eta/foreign-labor/news

US Department of Labor, Office of Foreign Labor Certification (2026c) Performance Data. PERM Program disclosure files, fiscal years 2008 to 2026 (third quarter), with the FY2026 Q3 record layout. Files retrieved from the Performance Data page on October 10, 2026. Accessed October 20, 2026. Available at: https://www.dol.gov/agencies/eta/foreign-labor/performance

US Department of Labor, Office of Foreign Labor Certification (2026d) Performance Data. LCA Programs (H-1B, H-1B1, E-3) disclosure files, fiscal year 2025 (four quarterly files) and fiscal year 2026 (third quarter), with the record layouts. Files retrieved from the Performance Data page on October 12, 2026. Accessed October 20, 2026. Available at: https://www.dol.gov/agencies/eta/foreign-labor/performance

US Department of Labor, Office of Foreign Labor Certification (2026e) Permanent Employment Program Selected Statistics, Fiscal Year (FY) 2026 Q3. Statistical report, data as of June 30, 2026. Available at: https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/FY26Q3/PERM_Selected_Statistics_FY2026_Q3.pdf

US Department of Labor, Office of Foreign Labor Certification (2026f) Processing Times. Foreign Labor Application Gateway, PERM as of October 5, 2026. Accessed October 20, 2026. Available at: https://flag.dol.gov/processingtimes

US Department of Labor, Office of Foreign Labor Certification (2026g) Program Debarments. Web page, no last-updated date shown. Accessed October 20, 2026. Available at: https://dol.gov/agencies/eta/foreign-labor/program-debarments

US Department of Labor, Office of Foreign Labor Certification (n.d.) H-1B, H-1B1 and E-3 Specialty (Professional) Workers. Program page. Accessed October 19, 2026. Available at: https://www.dol.gov/agencies/eta/foreign-labor/programs/h-1b

US Department of Labor, Office of Inspector General (2026a) Audit of the Employment and Training Administration’s Permanent Labor Certification Program. Audit project announcement, Project No. 06-P26-001-03-321, July 14, 2026. Available at: https://www.oig.dol.gov/public/oaprojects/PERM%20Recruitment%20Process_071426.pdf

US Department of Labor, Office of Inspector General (2026b) DOL Inspector General D’Esposito Announces Historic Fraud Investigation into University J-1 Visa Programs. Press release, October 9, 2026. Available at: https://www.oig.dol.gov/public/Press%20Releases/OIG-Press-Release-100926.htm

US Department of Labor, Office of Inspector General (2026c) Inspector General Anthony P. D’Esposito: President Trump Takes Historic Action to Combat Foreign Labor Fraud. Press release, September 18, 2026. Available at: https://oig.dol.gov/public/Press%20Releases/OIG-Press-Release-091826.htm

US Department of Labor, Wage and Hour Division (2008a) Fact Sheet #62C: Who is an H-1B-dependent employer? Revised July 2008. Available at: https://www.dol.gov/agencies/whd/fact-sheets/62c-h1b-dependent-employer

US Department of Labor, Wage and Hour Division (2008b) Fact Sheet #62G: Must an H-1B worker be paid a guaranteed wage? Revised July 2008. Available at: https://www.dol.gov/agencies/whd/fact-sheets/62g-h1b-required-wage

US Department of Labor, Wage and Hour Division (2016) Fact Sheet #62I: Must an H-1B employer pay for nonproductive time? Revised November 2016. Available at: https://www.dol.gov/agencies/whd/fact-sheets/62i-h1b-nonproductive-time

US Department of Labor, Wage and Hour Division (2025) Fact Sheet #62O: Must an H-1B employer recruit U.S. workers before seeking H-1B workers? Revised January 2025. Available at: https://www.dol.gov/agencies/whd/fact-sheets/62o-h1b-recruitment

US Department of Labor, Wage and Hour Division (2026a) H-1B Debarred/Disqualified List of Employers. Web page, last updated September 30, 2026. Accessed October 20, 2026. Available at: https://www.dol.gov/agencies/whd/immigration/h1b/debarment

US Department of Labor, Wage and Hour Division (2026b) whd_whisard. Compliance action data, concluded cases with findings to 2026. Enforcement Data site, file generated October 12, 2026, retrieved October 12, 2026. Accessed October 12, 2026. Available at: https://enforcedata.dol.gov/views/data_summary.php

US Department of State, Bureau of Consular Affairs (2026) Visa Bulletin For October 2026. Number 19, Volume XI. Available at: https://travel.state.gov/content/travel/en/legal/visa-law0/visa-bulletin/2027/visa-bulletin-for-october-2026.html

US District Court for the Central District of California (2025) Findings of Fact and Conclusions of Law re Plaintiffs’ Disparate Impact Claim. Palmer et al. v. Cognizant Technology Solutions Corp., Case No. CV 17-6848-DMG, document 714, December 5, 2025. Available at: https://docs.justia.com/cases/federal/district-courts/california/cacdce/2:2017cv06848/689138/714

US Senate Committee on the Judiciary (2025) Grassley, Durbin Take Aim at Tech, Finance and Retail Sectors for Favoring H-1B Visa Holders over American Workers. Press release, September 25, 2025. Available at: https://www.judiciary.senate.gov/press/rep/releases/grassley-durbin-take-aim-at-tech-finance-and-retail-sectors-for-favoring-h-1b-visa-holders-over-american-workers

Washington State Employment Security Department (2026) Worker adjustment and retraining notification (WARN) layoff and closure database. Notices filed by Microsoft Corporation, received May 13, 2025 to September 22, 2026 (seven notices). WARN notice database, retrieved October 12, 2026. Accessed October 20, 2026. Available at: https://esd.wa.gov/about-employees/WARN

The White House (2026) Vice President JD Vance Holds Press Conference on Fighting Visa Fraud. Video, October 8, 2026. Available at: https://www.whitehouse.gov/videos/vice-president-jd-vance-holds-press-conference-on-fighting-visa-fraud/

B. Company statements and filings

These establish what each company said or reported, as its own account rather than as independently verified fact. They cannot establish what a company has not disclosed, and a figure taken from them remains the company’s own figure.

Adobe (2026) Form 10-K for the fiscal year ended November 28, 2025. Annual report filed with the US Securities and Exchange Commission, January 15, 2026. Available at: https://www.sec.gov/Archives/edgar/data/796343/000079634326000003/adbe-20251128.htm

Capgemini (2015) Capgemini Completes the Acquisition of US-Based IGATE Corporation. Press release, July 1, 2015, filed as Exhibit 99.1 to IGATE Corporation’s Form 8-K with the US Securities and Exchange Commission. Available at: https://www.sec.gov/Archives/edgar/data/1024732/000119312515246906/d15249dex991.htm

Capgemini (2026) Capgemini upgrades its 2026 outlook. Press release, Paris, July 30, 2026. Available at: https://www.capgemini.com/news/press-releases/capgemini-upgrades-its-2026-outlook/

Cognizant (2026) Cognizant Schedules Third Quarter 2026 Earnings Release and Conference Call. Press release, October 2, 2026. Available at: https://news.cognizant.com/

Cognizant Technology Solutions (2025) Form 10-K for the fiscal year ended December 31, 2024. Annual report filed with the US Securities and Exchange Commission, February 12, 2025. Available at: https://www.sec.gov/Archives/edgar/data/1058290/000105829025000017/ctsh-20241231.htm

Cognizant Technology Solutions (2026) Form 10-K for the fiscal year ended December 31, 2025. Annual report filed with the US Securities and Exchange Commission, February 12, 2026. Available at: https://www.sec.gov/Archives/edgar/data/1058290/000105829026000008/ctsh-20251231.htm

Coleman, A. (2026) The latest in our company transformation. July 6, 2026. The Official Microsoft Blog. Available at: https://blogs.microsoft.com/blog/2026/07/06/the-latest-in-our-company-transformation/

HCL Technologies (2026a) Investor Relations: HCLTech Announced the Results for Q2 FY27 on October 12. Investor relations page. Until October 12, 2026, it announced the scheduled date. Accessed October 20, 2026. Available at: https://www.hcltech.com/investor-relations

HCL Technologies (2026b) Investor Release, Q2 FY27. Quarter ended September 30, 2026, published October 12, 2026. Available at: https://www.hcltech.com/sites/default/files/document/open/quarter-results/2026-10/hcltech-Q2-fy27-Investor-release.pdf

HCLTech (2025) Earnings call transcript, Q2 FY26. Transcript, October 13, 2025. Available at: https://www.hcltech.com/sites/default/files/document/open/call-trans/2025-10/HCLTech-Earnings-Q2FY26-transcript.pdf

iGATE Corporation (2012) Form 10-K for the fiscal year ended December 31, 2011. Annual report filed with the US Securities and Exchange Commission, 2012. Available at: https://www.sec.gov/Archives/edgar/data/1024732/000119312512114351/d277314d10k.htm

Infosys (2026a) Annual Report on Form 20-F for the fiscal year ended March 31, 2026. Filed with the US Securities and Exchange Commission, June 15, 2026. Available at: https://www.sec.gov/Archives/edgar/data/0001067491/000119312526270520/infy-20260331.htm

Infosys (2026b) Condensed consolidated interim financial statements, three months ended June 30, 2026. Exhibit 99.7 to Form 6-K, July 28, 2026. Available at: https://www.sec.gov/Archives/edgar/data/0001067491/000106749126000038/exv99w07.htm

Infosys (2026c) Letter to all stock exchanges giving notice of the Board meeting of October 22 and 23, 2026 (untitled letter), September 15, 2026. Available at: https://www.infosys.com/investors/documents/exchange-filings/2026/notice-board-meeting-15sep2026.pdf

Infosys Limited (2026) Company statement on the U.S. Permanent Labor Certification Program. Filing with BSE, the National Stock Exchange of India and the New York Stock Exchange, October 10, 2026. Available at: https://nsearchives.nseindia.com/corporate/INFY_10102026224330_Infosys_October102026.pdf

L&T Technology Services (2026) Q1FY27 Investor Release. Investor release, July 14, 2026. Available at: https://www.ltts.com/system/files/2026-07/LTTS-Q1FY27-Investor-Release.pdf

Microsoft (2021) Form 10-K for the fiscal year ended June 30, 2021. Annual report filed with the US Securities and Exchange Commission, July 29, 2021. Available at: https://www.sec.gov/Archives/edgar/data/789019/000156459021039151/msft-10k_20210630.htm

Microsoft (2024) Form 10-K for the fiscal year ended June 30, 2024. Annual report filed with the US Securities and Exchange Commission, July 30, 2024. Available at: https://www.sec.gov/Archives/edgar/data/789019/000095017024087843/msft-20240630.htm

Microsoft (2025) Form 10-K for the fiscal year ended June 30, 2025. Annual report filed with the US Securities and Exchange Commission, July 30, 2025. Available at: https://www.sec.gov/Archives/edgar/data/789019/000095017025100235/msft-20250630.htm

Microsoft (2026a) Form 10-K for the fiscal year ended June 30, 2026. Annual report filed with the US Securities and Exchange Commission, July 29, 2026. Available at: https://www.sec.gov/Archives/edgar/data/0000789019/000119312526323660/msft-20260630.htm

Microsoft (2026b) Microsoft Comment on Recent Immigration Questions. Microsoft On the Issues, October 8, 2026. Read through Microsoft’s On the Issues feed until the page opened directly on October 19, 2026. Available at: https://blogs.microsoft.com/on-the-issues/2026/10/08/microsoft-comment-on-recent-immigration-questions/

Microsoft (2026c) Subsidiaries of Registrant. Exhibit 21 to Form 10-K for the fiscal year ended June 30, 2026, filed with the US Securities and Exchange Commission, July 29, 2026. Available at: https://www.sec.gov/Archives/edgar/data/789019/000119312526323660/msft-ex21.htm

Tata Consultancy Services (2026a) International Growth and Strategic Wins Underpin TCS’ Q2. Press release, Mumbai, October 8, 2026. Available at: https://www.tcs.com/who-we-are/newsroom/press-release/tcs-financial-results-q2-fy-2027

Tata Consultancy Services (2026b) Statement of the Company regarding the announcement by the US Government on the Permanent Labor Certification Program. Exchange filing TCS/SE/104/2026-27, October 9, 2026. Available at: https://nsearchives.nseindia.com/corporate/TCS_CORPCS_09102026080757_SE_TCS_Statement_f.pdf

Tech Mahindra (2026) Earnings Presentation Q2 FY27. Investor presentation, undated, for the quarter ended September 30, 2026, with results released October 15, 2026. Available at: https://insights.techmahindra.com/investors/tml-q2-fy-27-earnings-presentation.pdf

Wipro (2025) Wipro Limited Q2 FY’26 Earnings Conference Call. Transcript, October 16, 2025. Available at: https://www.wipro.com/content/dam/nexus/en/investor/quarterly-results/2025-2026/q2fy26/q2fy26-earnings-transcript.pdf

Wipro (2026a) Annual Report on Form 20-F for the fiscal year ended March 31, 2026. Filed with the US Securities and Exchange Commission, June 2, 2026. Available at: https://www.sec.gov/Archives/edgar/data/0001123799/000119312526253514/wit-20260331.htm

Wipro (2026b) Wipro announces results for the Quarter ended September 30, 2026. Press release, East Brunswick, N.J. and Bengaluru, October 15, 2026. Available at: https://www.wipro.com/content/dam/nexus/en/investor/quarterly-results/2026-2027/q2fy27/press-release-q2fy27.pdf

Wipro (2026c) Wipro Limited to announce results for the second quarter ended September 30, 2026 on October 15, 2026. Press release, October 7, 2026. Available at: https://www.wipro.com/newsroom/press-releases/2026/wipro-limited-to-announce-results-for-the-second-quarter-ended-september-30-2026-on-october-15-2026/

C. Academic research

These establish findings within each study’s method, period, and population. They are historical evidence on the H-1B program, and none tests the October 2026 suspensions. Where a journal’s own page could not be read in full, the entry names the version read.

Doran, K., Gelber, A. and Isen, A. (2022) The Effects of High-Skilled Immigration Policy on Firms: Evidence from Visa Lotteries. Journal of Political Economy, 130(10), pp. 2501 to 2533. Read through the journal’s abstract and NBER Working Paper 20668, because the journal’s full text is paywalled. Available at: https://www.journals.uchicago.edu/doi/10.1086/720467

Glennon, B. (2024) How Do Restrictions on High-Skilled Immigration Affect Offshoring? Evidence from the H-1B Program. Management Science, 70(2), pp. 907 to 930. Working paper version: NBER Working Paper 27538. Read through the NBER abstract and publication note, because the journal’s page refused automated retrieval. Available at: https://www.nber.org/papers/w27538

Mahajan, P., Morales, N., Shih, K., Chen, M. and Brinatti, A. (2025) The Impact of Immigration on Firms and Workers: Insights from the H-1B Lottery. Federal Reserve Bank of Richmond Working Paper 24-04R, revised March 2025. Available at: https://www.richmondfed.org/publications/research/working_papers/2024/wp_24-04

D. Reporting, practitioner interpretation, and organizations’ statements

These establish what was said at an event, or in a statement whose own page could not be opened or identified, as the reporter relays it. Practitioner analysis establishes what counsel advised, not what the law requires. Statements by organizations, such as an industry body or a professional association, establish what each organization said, as its own account.

Alvarado, F. (2026) DOL Announces PERM Suspensions for Microsoft, Adobe, and Major IT Firms. October 8, 2026. WR Immigration. Available at: https://wolfsdorf.com/dol-announces-perm-suspensions-for-microsoft-adobe-and-major-it-firms/

American Immigration Lawyers Association (2026) USCIS NPRM on Removing Deference to Prior USCIS Determinations of Eligibility. AILA Doc. No. 26101464, October 14, 2026. Available at: https://www.aila.org/library/uscis-nprm-on-removing-deference-to-prior-uscis-determinations-of-eligibility

ANI (2026a) Politically motivated decisions will deeply harm US: Indian-American Congressman Thanedar on Trumps H-1B, Green Card move. October 10, 2026. webindia123. Available at: https://news.webindia123.com/news/Articles/World/20261010/4509180.html

ANI (2026b) “Steps by US don’t advance shared ambitions”: MEA responds to US barring Tech majors from Green Card program. October 9, 2026. ANI. The Ministry of External Affairs statement was read through this report because the Ministry’s own page could not be opened. Available at: https://aninews.in/news/business/steps-by-us-dont-advance-shared-ambitions-mea-responds-to-us-barring-tech-majors-from-green-card-program20261009125434/

Bailey, M. et al. (2026) DOL Announces Enforcement Actions Against Employers in H-1B and PERM Fraud Probe. October 15, 2026. Mayer Brown, Insights. Available at: https://www.mayerbrown.com/en/insights/publications/2026/10/dol-announces-enforcement-actions-against-employers-in-h-1b-and-perm-fraud-probe

Berardi Immigration Law (2022a) Benching of H-1B & L-1 Visa Employees. December 28, 2022. Available at: https://berardiimmigrationlaw.com/benching-of-h-1b-l-1-visa-employees/

Berardi Immigration Law (2022b) How Corporate Changes Impact PERM. August 2, 2022. Available at: https://berardiimmigrationlaw.com/how-corporate-changes-impact-perm/

Berry Appleman & Leiden (2026) United States: DHS proposes eliminating 60-day grace period for certain employment-based nonimmigrants. September 11, 2026. Available at: https://www.bal.com/immigration-news/united-states-dhs-proposes-eliminating-60-day-grace-period-for-certain-employment-based-nonimmigrants/

Bishop, T. (2025) Microsoft will cut nearly 2,000 jobs in Washington state as part of broader layoffs. May 13, 2025. GeekWire. Available at: https://www.geekwire.com/2025/microsoft-will-cut-nearly-2000-jobs-in-washington-state-as-part-of-broader-layoffs/

Bishop, T. (2026) Microsoft’s Brad Smith pushes back on Vice President JD Vance’s visa fraud accusations. October 15, 2026. GeekWire. Available at: https://www.geekwire.com/2026/microsofts-brad-smith-pushes-back-on-vice-president-jd-vances-visa-fraud-accusations/

Brown, S. (2019) What records are required to be kept for H-1B nonimmigrant employees? May 3, 2019 (last modified March 3, 2021). Reddy Neumann Brown PC. Available at: https://www.rnlawgroup.com/688-what-records-are-required-to-be-kept-for-h-1b-nonimmigrant-employees/

Brown, S. (2022a) What’s the Wage Again: Determining the Right H-1B Wage Level. September 2, 2022. Reddy Neumann Brown. Available at: https://www.rnlawgroup.com/whats-the-wage-again-determining-the-right-h-1b-wage-level

Brown, S. (2022b) Who is an H-1B Dependent Employer: Time to Reevaluate Come October 1. September 6, 2022. Reddy Neumann Brown. Available at: https://rnlawgroup.com/who-is-an-h-1b-dependent-employer-time-to-reevaluate-come-october-1

Buchanan, B. (2024) Lessons from Recent IER Settlements. September 27, 2024. Littler. Available at: https://www.littler.com/news-analysis/asap/lessons-recent-ier-settlements

Business Today (2025) ‘We are hiring locally, no fresh H-1B visa applications’: LTIMindtree CEO Venu Lambu’s big claim. December 1, 2025. Business Today. Available at: https://www.businesstoday.in/amp/nri/visa/story/we-are-hiring-locally-no-fresh-h-1b-visa-applications-ltimindtree-ceo-venu-lambus-big-claim-504351-2025-12-01

Chang, E. and Hensley, S. B. (2026) Vance suspends Microsoft from a green card program to crack down on alleged fraud. October 8, 2026. ABC News. Available at: https://abcnews.com/Politics/vance-suspends-microsoft-green-card-program-crack-alleged/story?id=137100899

Cohen, S. J. (2018) 8 Best Practices for Managing U.S. Immigration Compliance in 2018 (Part 2 of 5). September 13, 2018. Mintz. Available at: https://www.mintz.com/insights-center/viewpoints/2018-09-8-best-practices-managing-us-immigration-compliance-2018-part-2

Colombo & Hurd (2026) DOL Suspends Microsoft, Adobe and Six IT Firms from PERM Labor Certification. October 9, 2026. Available at: https://www.colombohurdlaw.com/dol-perm-suspension-microsoft-adobe/

Das Gupta, S. (2025) Tech giants Infosys, TCS among top 5 global H-1B visa beneficiaries. January 2, 2025 (updated January 3, 2025). Business Standard. Available at: https://www.business-standard.com/industry/news/tech-giants-infosys-tcs-among-top-5-global-h1-b-visa-beneficiaries-125010200882_1.html

Eisenstadt, M. (2026) DOL Announces PERM Processing Suspensions for Major Technology Companies. October 16, 2026. Greenberg Traurig, Inside Business Immigration. Available at: https://www.gtlaw-insidebusinessimmigration.com/perm/dol-announces-perm-processing-suspensions-for-major-technology-companies/

Espín Stern, E., Rosenman, A. S. and Bailey, M. (2022) Unlawful US Hiring Questions about Visa Status and Citizenship: Are Your Policies in Compliance? A 2022 Primer with Tips on Avoiding Discriminatory Practices. July 22, 2022. Mayer Brown. Available at: https://www.mayerbrown.com/en/insights/publications/2022/07/unlawful-us-hiring-questions-about-visa-status-and-citizenship-are-your-policies-in-compliance-a-2022-primer-with-tips-on-avoiding-discriminatory-practices

Ferreira, B. (2026) U.S. suspends green card path for H-1B workers at Microsoft and Adobe, labor certification program blocked due to alleged fraud. October 8, 2026. Tom’s Hardware. Available at: https://www.tomshardware.com/tech-industry/policy/u-s-suspends-green-card-path-for-h-1b-workers-at-microsoft-and-adobe-labor-certification-program-blocked-due-to-alleged-fraud

Fragomen (2026) United States: DOL Proposes Rule to Increase PERM and H-1B Wage Minimums. March 26, 2026. Available at: https://www.fragomen.com/insights/united-states-dol-proposes-rule-to-increase-perm-and-h-1b-wage-minimums.html

Garvin, L. C. (2026) Federal Government Intensifies Scrutiny of Employers Conducting Layoffs While Sponsoring Foreign Workers. October 15, 2026. Morgan Lewis LawFlash. Available at: https://www.morganlewis.com/pubs/2026/10/federal-government-intensifies-scrutiny-of-employers-conducting-layoffs-while-sponsoring-foreign-workers

Gooding, D. (2026) Green Card Update: Trump Admin Blocks Tech Companies From H-1B PERM Program. October 8, 2026. Newsweek. Available at: https://www.newsweek.com/green-card-update-trump-admin-blocks-tech-companies-h1b-perm-program-microsoft-adobe-12541853

Headman Law Group (2026) PERM Labor Certification: How the Process Actually Works, Step by Step. July 31, 2026. Available at: https://headmanlaw.com/insights/perm-labor-certification-process-guide/

IANS (2026a) Jayapal: Taking A Hammer To Legal Immigration Won’t Fix The System. October 9, 2026. India West. Available at: https://indiawest.com/jayapal-taking-a-hammer-to-legal-immigration-wont-fix-the-system/

IANS (2026b) Microsoft’s Brad Smith hits back at Vance over H-1B, green-card curbs. October 16, 2026. IANS Live. Available at: https://ianslive.in/microsofts-brad-smith-hits-back-at-vance-over-h-1b-green-card-curbs–20261016072403

Ji, J. (2024) H-1B Portability: Your Guide to Switching Employers While Maintaining Status. October 28, 2024. Reddy Neumann Brown. Available at: https://www.rnlawgroup.com/h-1b-portability-your-guide-to-switching-employers-while-maintaining-status/

Joson, C. (2024) Exploring the Basics of PERM Recruitment. February 19, 2024. Reddy Neumann Brown. Available at: https://www.rnlawgroup.com/exploring-the-basics-of-perm-recruitment/

Kannan, U. (2026) HCLTech says US PERM suspension to have no material impact. October 12, 2026. Deccan Herald. Available at: https://www.deccanherald.com/business/companies/hcltech-says-us-perm-suspension-to-have-no-material-impact-4180284

Kerr, C. (2026) Update: 136 workers have been laid off at id Software. July 7, 2026. Game Developer. Available at: https://gamedeveloper.com/business/report-around-half-of-the-id-software-team-have-been-laid-off

Klasko Immigration Law Partners (2009) Say Goodbye to the Days of Quick Turn-Around H-1Bs. June 22, 2009. Available at: https://www.klaskolaw.com/?p=1738

Kreighbaum, A. (2023) Rolling Tech Layoffs Snag Green Card Prospects for H-1B Workers. January 31, 2023. Bloomberg Law. Available at: https://news.bloomberglaw.com/litigation/rolling-tech-layoffs-snag-green-card-prospects-for-h-1b-workers

Kumar, R. (2026) No US PERM Suspension Notice, H-1B Workforce Below 1%: Tech Mahindra. October 16, 2026. Free Press Journal. Available at: https://www.freepressjournal.in/business/no-us-perm-suspension-notice-h-1b-workforce-below-1-tech-mahindra

Lincoln-Goldfinch, K. (2025) H-1B Visas For Professional Workers. Updated March 19, 2025. Lincoln-Goldfinch Law. Available at: https://www.lincolngoldfinch.com/?p=72

Lumetta, C. (2026) Vance Heralds New Fraud Crackdowns. October 9, 2026. RealClearPolitics. Available at: https://www.realclearpolitics.com/articles/2026/10/09/vance_heralds_new_fraud_crackdowns_154576.html

Mehta, C. (2014) DOL Policy on Laid-Off U.S. Workers for PERM Labor Certification Applications. February 28, 2014. Cyrus D. Mehta & Partners PLLC. Available at: https://blog.cyrusmehta.com/?p=104

Mehta, C. (2017) Employer Not Always Obligated To Pay Return Transportation Cost Of Terminated H-1B Worker. March 21, 2017. Cyrus D. Mehta & Partners. Available at: https://blog.cyrusmehta.com/2017/03/employer-not-always-obligated-to-pay-return-transportation-cost-of-terminated-h-1b-worker.html

Meltzer Hellrung (2026) DOL Suspends PERM Processing for Microsoft, Adobe, and Major IT Services Firms. October 9, 2026. Meltzer Hellrung LLC. Available at: https://meltzerhellrung.com/dol-suspends-perm-processing-for-microsoft-adobe-and-major-it-services-firms/

Merrills, A. W. and Smalley, S. H. (2012) Stricter Scrutiny of Labor Certifications: Increase in Audits and Supervised Recruitment by the DOL. November 1, 2012. Ogletree Deakins. Available at: https://ogletree.com/insights/stricter-scrutiny-of-labor-certifications-increase-in-audits-and-supervised-recruitment-by-the-dol

Michailov, D. (2026) Guide to ‘Successor in Interest’ for Employment-Based Green Cards/I-140 Petitions. February 26, 2026. Capitol Immigration Law Group. Available at: https://cilawgroup.com/news/2026/02/26/guide-to-successor-in-interest-for-employment-based-green-cards-i-140-petitions/

Michelena, R. (2026) PERM Suspension 2026: What Affected Workers Should Know. October 9, 2026. Visa-Pros (Weinstock Immigration Lawyers). Available at: https://visa-pros.com/perm-suspension-2026/

Natrin, K. and Rayer, F. (2026) DHS Proposes Eliminating 60-Day Grace Period for Certain Nonimmigrant Workers. Alert, Cozen O’Connor, September 16, 2026. Available at: https://www.cozen.com/news-resources/publications/2026/dhs-proposes-eliminating-60-day-grace-period-for-certain-nonimmigrant-workers

Novet, J. (2025) Microsoft’s Satya Nadella says job cuts have been ‘weighing heavily’ on him. July 24, 2025. CNBC. Republished by NBC4 Washington. Available at: https://www.nbcwashington.com/news/business/money-report/microsofts-satya-nadella-says-job-cuts-have-been-weighing-heavily-on-him/3964172/

Open Bureau (2026) ‘Never-Ending Flow of Cheap Labour’: Vance Clashes With Jayapal Over Green-Card Curbs. October 9, 2026. Open Magazine. Available at: https://openthemagazine.com/world/never-ending-flow-of-cheap-labour-vance-clashes-with-jayapal-over-green-card-curbs

Outlook Business (2025) Infosys, TCS Among Top Firms Hiring H-1B Visa Holders in 2025; Check Full List. March 24, 2025. Outlook Business. Available at: https://www.outlookbusiness.com/news/infosys-tcs-among-top-firms-hiring-h-1b-visa-holders-in-2025-check-full-list

Outlook India (2026) US Suspends Cognizant, Cloudera PERM Filings Amid Visa Fraud Probe. Outlook News Desk, September 9, 2026. Available at: https://www.outlookindia.com/international/us-suspends-cognizant-cloudera-perm-filings-amid-visa-fraud-probe

Pestaina, C.-A. (2012) PERM Audits Request Sworn Declarations Regarding Improper Payments. October 22, 2012. Cyrus D. Mehta & Partners. Available at: https://blog.cyrusmehta.com/2012/10/perm-audits-request-sworn-declarations-regarding-improper-payments.html

Press Trust of India (2025a) Indian-origin tech firms corner 1/5th of H1B visas issued by US. January 5, 2025. The Tribune. Available at: https://www.tribuneindia.com/news/business/indian-origin-tech-firms-corner-1-5th-of-h1b-visas-issued-by-us

Press Trust of India (2025b) TCS second-highest beneficiary of approved H-1B visas; Microsoft, Apple also in top 10. September 20, 2025. The Tribune. Available at: https://www.tribuneindia.com/news/usa-news/tcs-second-highest-beneficiary-of-approved-h-1b-visas-microsoft-apple-also-in-top-10/amp

Press Trust of India (2026a) Green card programme action: Wipro says no material business impact; 80% of US staff locally hired. October 13, 2026. Deccan Herald. Available at: https://www.deccanherald.com/amp/story/business/companies/green-card-programme-action-wipro-says-no-material-business-impact-80-of-us-staff-locally-hired-4181302

Press Trust of India (2026b) Immigration, skilled talent mobility distinct: Nasscom as US suspends IT firms from green card prog. October 8, 2026. ThePrint. The NASSCOM statement was read through this report because its own page on nasscom.in could not be opened. Available at: https://theprint.in/economy/immigration-skilled-talent-mobility-distinct-nasscom-as-us-suspends-it-firms-from-green-card-prog/3066171/

Quillen, S. (2026) ‘Indentured servants’: US green card move will hit thousands of IT workers. October 9, 2026. Al Jazeera. Available at: https://www.aljazeera.com/news/2026/10/9/indentured-servants-us-green-card-move-will-hit-thousands-of-it-workers

Reddy, R. (2026) Employee FAQs: J.D. Vance Announces Immigration Action Against Microsoft & Other Companies. October 8, 2026. Reddy Neumann Brown PC. Available at: https://www.rnlawgroup.com/employee-faqs-j-d-vance-announces-immigration-action-against-microsoft-other-companies/

Reuters (2026) US suspending permanent residency program for Microsoft, Vance says. Reuters, October 8, 2026. First take by Dan Rosenzweig-Ziff, later updated by Akash Sriram and Steve Holland under revised headlines. Read through Reuters-credited republications because the Reuters page could not be opened. Available at: https://www.reuters.com/business/us-suspending-permanent-residency-program-for-microsoft-vance-says-2026-10-08/

Richards, J. (2025) Layoffs and the Green Card Application Process for PERM. Updated April 17, 2025. Richards and Jurusik Immigration Law. Available at: https://rjimmigrationlaw.com/resources/understanding-layoffs-and-their-influence-on-the-green-card-application-process-for-perm/

Samper, L. (2026) The Government Froze Green Card Sponsorship at Microsoft, Adobe and Six IT Firms. Here Is Who Is Exposed. October 8, 2026. Samper Law. Available at: https://www.samperlaw.com/insights/immigration-updates/perm-suspension-microsoft-adobe-it-firms-october-2026

Short, A. (2026) Microsoft, Infosys, Tata and 5 More Suspended From PERM: What H-1B Workers Should Do Now. October 9, 2026. Lehigh Valley Immigration Law. Available at: https://www.lehighvalleyimmigrationlawyers.com/blog/perm-suspension-microsoft-infosys-tata-h-1b-workers-2026

Shusterman, C. (2024) EB2 India Retrogression Why We Need Immigration Reform Now! Published September 10, 2022, updated April 20, 2024. Shusterman Law. Available at: https://www.shusterman.com/?p=92223

Sophia, D. M. and Singh, J. (2026) Explainer-The tech green-card program under attack from Trump. October 9, 2026. Reuters. Republished by The Star. Read through that republication because the Reuters page could not be opened. Available at: https://www.thestar.com.my/tech/tech-news/2026/10/09/explainer-the-tech-green-card-program-under-attack-from-trump

Sutich, J. (2025) Fifth consecutive month of Microsoft layoffs: Seattle tech giant cuts more Redmond positions. September 8, 2025. MyNorthwest. Available at: https://mynorthwest.com/?p=4129427

Thubron, R. (2026) Microsoft and Adobe hit with green-card suspensions as Vance accuses tech firms of sidelining American workers. October 9, 2026. TechSpot. Available at: https://www.techspot.com/news/114154-microsoft-adobe-hit-green-card-suspensions-vance-accuses.html

Troutman Sanders (n.d.) Retention of EB-1, EB-2, and EB-3 Immigrant Workers and Program Improvements Affecting High-Skilled Nonimmigrant Workers. Practice alert on the November 18, 2016, final rule, undated. Accessed October 20, 2026. Available at: https://www.troutman.com/insights/retention-of-eb-1-eb-2-and-eb-3-immigrant-workers-and-program-improvements-affecting-high-skilled-nonimmigrant-workers.html

Velasquez, F. (2025) Amazon is resuming green-card applications under Trump. January 23, 2025. Quartz. Available at: https://qz.com/amazon-green-card-applications-trump-pledge-promise-rto-1851746418

Walsh, J. (2026) 7 highlights from JD Vance’s CBS News town hall: Iran, immigration, corruption and 2028 plans. October 18, 2026. CBS News. Available at: https://www.cbsnews.com/news/jd-vance-cbs-town-hall-highlights-michigan/

Watson Immigration Law (n.d.) H-1B Specialty Occupation Visa Attorney in Seattle. Undated web page. Accessed October 19, 2026. Available at: https://watsonimmigrationlaw.com/visas/h-1b

E. Prior Greyhound Research analysis

These establish Greyhound Research’s own earlier published positions, as published on their stated dates. Both pieces analyze the September 2025 H-1B fee, are cited in section 10, and do not address PERM. They belong to Greyhound Research’s sustained coverage of enterprise technology markets, on which this research report also draws.

Gogia, S. V. (2025a) From Outrage to Architecture: Redesigning IT Services Strategy After the $100,000 H-1B Shock. September 21, 2025 (updated May 29, 2026). Greyhound Research. Available at: https://greyhoundresearch.com/from-outrage-to-architecture-redesigning-it-services-strategy-after-the-100000-h-1b-shock/

Gogia, S. V. (2025b) Trump’s $100,000 Fee for H1B: A Tariff on Talent. September 20, 2025. Greyhound Research. Available at: https://greyhoundresearch.com/trumps-100000-fee-for-h1b-a-tariff-on-talent/

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Disclosures: Independence, Financial, Intended Use, Methodology, Authoring, And Copyright

The evidence in this research report is current through October 20, 2026. Any written response received from an organization named in it after that date is dated where it appears.

Independence Disclosure

Research under the Greyhound Research brand is independent, and no organization holds a right of approval over its content or publication. Greyhound Research did not offer any named organization a pre-publication factual review of this research report. Editorial control remained entirely with Greyhound Research throughout. Greyhound Consilium is the B2B thought-leadership arm of The House Of Greyhound and a sister brand to Greyhound Research. It builds on Greyhound Research’s independent research through collaborations that produce thought-leadership content, research, and practical toolkits for decision-makers. Every Greyhound Consilium publication names its partner on the face of the document. This research report is published under the Greyhound Research brand.

Financial Disclosure

Greyhound Research undertakes advisory and consulting engagements with enterprise buyers and technology providers, and no such engagement confers control over research findings or the decision to publish. This research report was not commissioned, sponsored, or funded by any organization, including Infosys and Oracle, both clients of Greyhound Research. Infosys is one of the eight companies named in the October 8 announcement, and Oracle’s US subsidiary Oracle America appears here as a comparison employer. Greyhound Research and the author hold no financial interest in any of the eight companies. Nor do Greyhound Research or the author have a current commercial relationship with the other seven: Microsoft, Adobe, Cognizant, Tata Consultancy Services, Wipro, HCL Technologies, and Capgemini. Both statements cover the companies’ parent and holding entities, including Tata Sons.

Intended Use

This research report is written for chief information officers and their teams, supplier executives, officials, and the press. It sets the October 8 PERM suspensions beside the public record, to inform delivery, sourcing, and policy decisions. Its statements of law and immigration procedure are summaries for business planning, not legal or immigration advice or a determination of any individual’s case. Greyhound Research is not a law firm, and readers should take any individual case to qualified counsel. This research report is not investment advice, a recommendation to buy, sell, or hold any security, or a view on any company’s share price or valuation. Its assessments rest on documents read on or before October 20, 2026 and can change as agencies and companies publish more.

Research Methodology

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