New H-1B Visa Policy: What Finance Talent Leaders Must Know

At a Glance: H-1B Visa Policy Update for Employers 

• $100,000 fee now applies to most new H-1B visa applications from outside the U.S. 
• Existing  H-1B holders and renewals are exempt. 
• Policy will raise hiring costs and limit access to global finance talent. 
• Details, exemptions, and legal challenges remain unresolved. 
• Finance firms should review H-1B hiring, compensation, and talent acquisition strategies. 

On September 19, 2025, the Trump Administration issued a presidential proclamation introducing a major change to the H-1B visa program, including a new fee requirement for many new H-1B applications.  

The 2025 H-1B visa changes present significant challenges for hiring managers and talent acquisition leaders in financial services, especially those recruiting global talent for financial institutions. 

If your firm has concerns over the new ruling, we recommend seeking legal advice. 

 

Overview of the H-1B Visa Announcement 

The new policy requires a one-time payment of $100,000 to accompany or supplement H-1B petitions for certain new applicants. This fee applies only to individuals applying from outside the United States and is not applicable to existing H-1B holders or renewals. The fee is intended to be in effect for one year, from September 21, 2025 to September 21, 2026. Additionally, the proclamation directs the Secretaries of Homeland Security and Labor to revise prevailing wage levels and prioritize higher-skill, higher-pay H-1B applicants. 

Read the official USCIS H-B1 visa policy for more details.  

 

Key Clarifications for Finance Employers 

The fee does not apply to H-1B visa holders whose visas were issued before the effective date, nor does it apply to renewals. There are also provisions for case-by-case exemptions if an applicant or employer can demonstrate that granting the petition without the fee serves the national interest. 

 

Impact on Financial Institutions 

For financial institutions, this policy could significantly reshape global hiring strategies: 

Cost Impact: The $100,000 fee may deter firms from recruiting international talent from outside the U.S., especially for niche or technical roles. 

Mobility Strategy: Overseas candidates planning to transfer into U.S. offices may delay or cancel moves. 

Vendor Risk: Third-party partners in tech, analytics, and operations, many of whom rely on H-1B staffing, may face delays or increased costs, affecting project delivery. 

With mobility strategy potentially impacted, firms may turn to candidates already authorized to work domestically, strengthening relationships with universities, and investing in upskilling initiatives to close emerging skills gaps.  

 

What is Still Unclear About the H-1B Visa Policy Changes 

Because the new H-1B visa policy is based on an executive proclamation with further rulemaking to follow, several important details remain unsettled for finance hiring managers and talent acquisition leaders. Key areas to monitor include: 

• Final guidance from USCIS, U.S. Department of State, and Department of Labor on how the $100,000 fee will be applied, what documentation will be required, and specific processes for verification. 
• How exemptions will be determined, especially for roles deemed in the national interest, or for certain industries.  
• Prevailing wage rule changes, and how those will affect salary bands for H-1B-eligible roles.  
• Potential legal challenges to the H-1B visa policy remain a significant area of uncertainty. Several legal experts and industry commentators have questioned whether the executive branch has the authority to impose such a substantial fee, and it is possible that courts could block, delay, or require modifications to the proclamation. 
  For ongoing legal analysis and updates, see the National Law Review’s H-1B coverage. 

• Secondary impacts such as retention of international staff, travel and visa timeline delays, which could affect onboarding, corporate mobility and compliance. 

For the latest updates, finance hiring leaders should regularly consult official sources such as USCIS, the Department of Labor, U.S. Department of State, and trusted legal advisors.

 

Strategic Hiring Actions to Consider 

It’s important that firms think proactively at this time.  Some key steps hiring managers and talent acquisition leaders in financial services should consider include the following:

1. Audit current and planned H-1B hiring 
Review all roles currently filled or planned to be filled via H-1B from outside the U.S. Estimate the financial and operational impact of the new fee on those positions. 

For tailored guidance on finance and accounting workforce planning, visit our Finance & Accounting Recruitment Specialists page. 

2. Review compensation strategy for H-1B eligible roles 
Given the emphasis on “higher pay / higher skill” in the proclamation, roles that were marginal under previous wage standards may become less viable if cost + prevailing wage + fee makes them unattractive. Reassess which roles may become unviable and adjust your compensation strategy accordingly. 

For benchmarking and compensation trends, explore our Global Compensation Guides.  

3. Consider alternative authorization pathways 
Explore options with official H-1B and alternative visa guidance from the USCIS Working in the United States page. 

4. Invest in domestic and internal talent development 
Invest in upskilling domestic talent to reduce reliance on foreign nationals in roles heavily affected by these changes (for example technology, quant, AI, data science roles). 

5. Engage compliance, HR, legal teams 
Because rulemaking and potential litigation may cause shifts, having internal or external legal counsel monitoring updates is essential. Clear communication with international employees about what changes mean for them will also be essential during this time. 

For compliance and legal hiring insights, see our Compliance Hiring & Career Advice. For ongoing legal commentary and updates, visit the National Law Review’s H-1B coverage. 

 

Conclusion: Key Takeaways for Finance Hiring Leaders 

The Trump administration’s new H-1B policy marks one of the most significant immigration changes in recent years. While it does not affect renewals or current visa holders, the $100,000 petition fee introduces major cost and compliance considerations.  

For finance talent leaders, this is a critical moment to reassess global recruitment strategies, strengthen domestic pipelines, and prepare for regulatory uncertainty. Proactive workforce planning, legal oversight, and internal communication will be essential to navigate the evolving landscape.