Submitted November 28, 2025

The Center for Law and Social Policy submits this comment opposing in the strongest possible terms the October 30, 2025 Interim Final Rule (“2025 IFR”) eliminating automatic extensions of Employment Authorization Documents (“EADs”). The 2025 IFR unlawfully reverses DHS’s nearly decade-long policy choice of providing automatic EAD extensions; ignores ongoing adjudication delays and economic evidence; disregards reliance interests that DHS itself recognized less than a year ago; rejects feasible alternatives; and relies solely on an unsupported security rationale all while unlawfully bypassing notice-and-comment. The result is a rule that will destabilize the workforce, disrupt employer operations, and inflict severe harm on workers and their families solely due to government processing delays. DHS must withdraw the IFR in full.

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