On October 8, 2026 the DOL stopped accepting and processing PERM applications for Microsoft, Adobe, Cognizant, Infosys, TCS, Wipro, HCL and Capgemini. No end date, no written notice yet. The hard part is not reading the news - it is finding every affected case in time. GlobalCodio runs that.
On October 8, 2026, Vice President JD Vance and Labor Secretary Keith Sonderling announced at a White House news conference that the Department of Labor is suspending eight employers from the PERM labor certification program: Microsoft, Adobe, Cognizant, Infosys, Tata Consultancy Services, Wipro, HCL and Capgemini. The Department will accept no new PERM applications from the eight and will stop processing the ones already in its queue. Officials cited active federal investigations for Microsoft and Adobe and filing volume for the six IT services firms - Sonderling said the group had obtained more than 100,000 permanent labor certifications since 2009. No end date was given.
Four days on, there is still no press release, no Federal Register notice and no written description of which legal entities are covered. Counsel are pointing to 20 CFR 656.31(b), which lets DOL suspend processing during a fraud or willful misrepresentation investigation for up to 180 days with extensions, but the Department has not said that is the authority it used. Existing H-1B status is not touched by the announcement. Everything downstream of PERM is.
The policy is one sentence. The caseload is not.
PERM is the first step of most EB-2 and EB-3 green cards, and the question every corporate immigration team at a named employer woke up to on October 9 was not "what does this mean" - the law firm advisories answered that by lunchtime. It was "which of our cases does this touch, and which one does it touch first." That is not a legal question. It is a data question, the same kind we described when the H-1B lottery became a forms-and-data problem in disguise, and most teams cannot answer it without a spreadsheet exercise that takes a week they do not have.
Split the pipeline by stage and the picture changes at every line. A prevailing wage request not yet filed. Recruitment under way with a Notice of Filing on the wall. A PERM filed and waiting. A PERM certified with the I-140 not yet filed, or filed and pending, or approved and waiting on a priority date. Nobody knows yet how DOL and USCIS will treat the certified cases, and the advisories say so plainly. The operating job is to have every case tagged by stage, by sponsoring entity and by the employee's H-1B clock before the written notice arrives, so that when it does you apply it in an hour rather than a fortnight. CodioCMS holds exactly that structure, because it was built for an operation where the government rewrites the rules mid-case.
The real deadline is the six-year clock, not the suspension
A suspended PERM does not sit still. Under AC21, an H-1B worker can extend past the six-year limit only if a PERM or I-140 was filed at least 365 days before the max-out date, or if an I-140 has been approved. For an employee whose PERM was about to be filed, every month of suspension is a month lost against that window. For one whose PERM is pending, the open question is whether a filing the Department refuses to process still counts as filed for AC21 purposes - and whether the eventual notice says so. We made the same point about corporate files when Duration of Status ended: two adjudications sharing one start date are not two deadlines, they are one deadline with two ways to miss it.
The Deadline Agent tracks the H-1B max-out date for every sponsored employee and the PERM and I-140 filing dates against it. The moment a PERM timing no longer clears the 365-day window, the case is flagged by name and date, so a corporate immigration team sees its exposure on a dashboard on day one instead of discovering it at the extension filing. And for the cases that are already certified, the I-485 that follows carries its own traps - EB cases skip the Affidavit of Support, not public charge - which is one more reason the stage tag has to be right.
There is no written notice yet. There will be one.
When DOL issues its written description of the covered entities and applications, it will need to be read the same day and matched to cases. The entity question matters more than it sounds: the announcement names "Microsoft", but a PERM names a sponsoring entity with its own FEIN, and large employers sponsor through several. The Government Notice Agent reads the notice when it lands, matches the named entities against the sponsoring employer on every open case, and turns the result into a task list - who is covered, who is not, who needs counsel's eyes today. That is also what it does with the audit letters and supervised recruitment notices that tend to follow a suspension.
Because that is what this is. The six IT firms were named for volume, Microsoft and Adobe for open investigations, and a suspension under 656.31(b) is by definition tied to an inquiry. The records that will be asked for are the ones we listed when we said to audit your H-1B and PERM files before the subpoena arrives: Public Access Files available within one working day, Notice of Filing proof for every worksite, recruitment reports, prevailing wage determinations. The Document Validation Agent checks that every one of those is present and consistent on every case, which turns an investigation from a scramble into a retrieval. In the H-1B fraud crackdown your records are your defense, and the same records are your defense here.
Thousands of anxious employees and one inbox
Every sponsored employee at the eight companies read the same headline, and most of them read it before their employer said anything. The mobility team's inbox fills with the same three questions in a thousand phrasings: am I affected, what happens to my green card, can I still extend. Answering each one by hand is a week of work that produces inconsistent answers. The Client Comms Agent sends every employee a case-specific status drawn from the stage tag - your PERM is pending and here is what that means, your I-140 is approved and nothing in the announcement changes that, your filing was planned and here is the date we are watching - and routes the ones that need a human to a human. The same holds for law firms whose corporate clients were named: the firm that can tell a client which of its 400 cases are exposed on the first morning is the firm that keeps the account.
You cannot predict the next eight names
This is not the first suspension - DOL paused Cloudera's PERM processing for 180 days in May 2026 pending a Justice Department investigation - and nothing in the announcement says it is the last. Amazon, Meta and Google were not named on October 8. They may be named later, or never. Counsel are already warning not to assume processing resumes after six months. The teams that get through this are not the ones that predicted it; they are the ones whose caseload was already structured so that any list of employers, any stage cut-off and any notice could be applied in an afternoon. That is the difference between a firm that bought software and a firm whose operation is run for it, which is the point we made about firms adopting AI the wrong way.
You cannot predict the policy. You can be ready for any version of it. GlobalCodio builds and runs that operation in the background for immigration law firms and corporate immigration teams - the case structure, the deadline tracking, the notice handling, the employee communications - so that the next announcement is a morning's work, not a quarter's. If a named employer is in your caseload, we can help you find every affected case this week.