Italy Checklist: Sponsoring Highly Skilled Migrant Visas
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Beginning November 1, 2025, the U.S. State Department implemented strict consular district requirements for immigrant visa interviews, fundamentally altering how companies manage green card processing for international employees. Under the new policy, applicants must interview at the U.S. consulate or embassy with jurisdiction over their country of residence—effectively eliminating the flexibility to process cases in third countries where wait times might be shorter or logistics more favorable.
For HR professionals and Global Mobility managers coordinating employment-based green card applications, this represents a significant operational challenge. Employees from countries with limited U.S. consular services—particularly Russia, Iran, Venezuela, and several others—now face dramatically extended timelines and complex logistical hurdles that can delay workforce availability by six to eighteen months.
This analysis examines what the new consular district restrictions mean for your talent pipeline, explores the specific impacts on employees from high-restriction countries, provides guidance on immigrant visa interview procedures, and offers strategic workforce planning adjustments to mitigate delays while maintaining compliance with the new requirements.
The State Department’s policy change eliminates what was previously known as “third-country national” (TCN) processing for immigrant visas—the practice of conducting visa interviews outside an applicant’s country of nationality or permanent residence.
What the new rule means:
🔸 Applicants must interview at the consulate with jurisdiction over their current country of legal residence
🔸 Short-term stays or tourist visits to other countries do not establish eligibility for interview elsewhere
🔸 The rule applies to all employment-based immigrant visa categories (EB-1, EB-2, EB-3, EB-4, EB-5)
🔸 Exceptions are extremely limited and require documented extraordinary circumstances
The State Department cites fraud prevention, security screening consistency, and administrative efficiency as primary drivers. Officials argue that interviewing applicants in their home jurisdictions allows for more thorough background checks and reduces opportunities for document fraud that can occur when applicants process cases in unfamiliar consular districts.
Practical impact: Previously, an employee from Russia working in the U.S. on H-1B status might travel to Warsaw, Poland for their immigrant visa interview after consular processing approval. Under the new rules, they must return to Russia—where U.S. consular services are severely limited—or establish legal residency in another country first, a process that can take months or years.
Certain countries face particularly severe consequences under the new consular district requirements due to limited or suspended U.S. consular operations.
U.S. Embassy Moscow suspended routine visa services in 2021, and as of November 2025, only limited emergency services operate. Russian nationals seeking immigrant visas now face several challenging options:
🔸 Wait for resumed services: No timeline exists for when full consular operations might restart
🔸 Establish residency elsewhere: Requires relocating to a third country and obtaining legal permanent residence status there (typically 6-12 months minimum before consular eligibility)
🔸 Utilize limited slots in nearby posts: Some consulates in neighboring countries may process limited Russian national cases, but appointment availability extends 8-14 months out
Strategic consideration: For companies with Russian employees approaching green card interview stages, immediate action is critical. xpath.global’s immigration case management platform provides real-time tracking of consular appointment availability across multiple jurisdictions, allowing HR teams to monitor when limited slots open and coordinate rapid response booking strategies.
Iranian nationals have historically processed immigrant visas in third countries like Armenia, Turkey, or UAE due to the absence of U.S. consular services in Iran. The November 2025 rule change creates particular hardship:
🔸 Iranian applicants must now establish legal residency in the third country before interview eligibility
🔸 This adds 6-18 months to processing timelines depending on the country’s residency requirements
🔸 Coordination of employment authorization, travel documents, and residency permits across multiple jurisdictions becomes exponentially more complex
U.S. Embassy Caracas operates with minimal staff and severe appointment backlogs extending beyond 24 months for routine immigrant visa interviews. Venezuelan employees face:
🔸 Extended wait times even when in-country processing is attempted
🔸 Safety concerns traveling to Caracas for interviews
🔸 Limited third-country options that require establishing new legal residency
Compliance tracking: Managing employees across multiple immigration systems—maintaining U.S. work authorization while simultaneously tracking residency establishment in third countries for eventual consular processing—demands sophisticated tracking tools. xpath.global’s platform centralizes visa expiration monitoring, work permit renewals, and residency application progress across 183 countries, ensuring no compliance deadlines are missed during extended processing periods.
The consular district restrictions fundamentally alter green card timeline projections, requiring HR teams to recalibrate workforce planning assumptions.
Before November 2025: Employee with approved I-140 petition reaches current priority date → travels to third country with shorter wait times → interviews within 2-4 months → returns to U.S. with immigrant visa → total timeline 3-5 months
After November 2025: Same employee → must establish legal residency in third country (6-12 months) → schedule consular interview in that jurisdiction (3-8 months) → complete interview and return → total timeline 9-20 months
Extended processing timelines create significant retention risks, particularly for employees whose work authorization status may expire before immigrant visas can be issued.
Mitigation strategies:
🔸 File I-485 adjustments when possible: For employees already in the U.S., adjustment of status applications avoid consular processing entirely
🔸 Extend nonimmigrant status: Ensure H-1B, L-1, or other work visas are extended well beyond anticipated green card timelines
🔸 Implement retention incentives: Financial or career advancement commitments that recognize extended uncertainty
🔸 Consider alternative assignments: Temporary assignments to countries where the employee can establish residency and eventually process consular cases
xpath.global’s relocation consulting services (Essential Support, Managed Mobility, and Premium Advisory tiers) include strategic immigration advisory specifically designed for complex scenarios like consular district compliance. Senior consultants with 10+ years of experience can develop individualized strategies for each employee’s circumstances, coordinating work authorization extensions, residency establishment, and eventual consular processing across multiple jurisdictions.
While the consular district restrictions eliminate flexibility, several strategic alternatives can help companies maintain talent pipelines.
For employees already in the United States on valid work visas, adjustment of status (I-485 applications filed with USCIS) bypasses consular processing entirely. This pathway becomes increasingly valuable under the new restrictions.
Strategic implementation: When priority dates become current, immediately file I-485 applications for any employees who might face consular processing challenges. Even if the employee ultimately must depart the U.S., having an I-485 application pending preserves options and demonstrates immigration intent.
Companies can consider establishing legal entities and employment arrangements in countries that serve as practical mobility hubs—locations where employees can establish legal residency while continuing work for the organization, positioning them for eventual consular processing.
Viable hub countries: Canada, UK, Germany, UAE, and Singapore offer relatively streamlined residency pathways and robust U.S. consular services with reasonable appointment availability.
Managing employees across multiple immigration systems simultaneously—U.S. work authorization, third-country residency applications, consular interview scheduling, and ongoing compliance obligations—exceeds the capacity of manual spreadsheets.
xpath.global’s platform provides:
🔸 Centralized case tracking: Visibility across all active immigration matters for each employee regardless of jurisdiction
🔸 Automated deadline monitoring: Alerts for work authorization expirations, residency permit renewals, and consular appointment opportunities
🔸 Vendor coordination: Access to immigration attorneys and relocation specialists across 60,000+ vetted service providers in 183 countries
Identify employees currently in the immigration queue and assess their exposure to the new consular district restrictions:
🔸 Where is each employee’s country of residence for consular jurisdiction purposes?
🔸 What is consular appointment availability in those jurisdictions?
🔸 Do any employees face severe processing restrictions (Russia, Iran, Venezuela)?
🔸 What are contingency timelines if consular processing is delayed 12-24 months?
Factor immigration processing complexity into hiring decisions for roles requiring green card sponsorship:
🔸 Prioritize candidates already in the U.S.: Employees eligible for adjustment of status avoid consular processing challenges
🔸 Assess consular jurisdiction risk: Consider the immigration processing environment in candidates’ home countries during hiring decisions
🔸 Build timeline cushions: Account for 18-24 month green card processing windows for employees from high-restriction countries
Employees affected by the new consular district rules need clear, proactive communication about timeline expectations and available support:
🔸 Provide detailed explanations of how the policy change affects their specific situation
🔸 Outline company support for residency establishment in alternative jurisdictions if needed
🔸 Offer regular status updates through transparent case management platforms
The November 2025 consular district restrictions represent one of the most significant changes to U.S. immigrant visa processing in decades, eliminating flexibility that companies relied upon to manage green card timelines efficiently. For employees from countries with limited U.S. consular services, the impact is particularly severe—potentially adding 12-24 months to already lengthy processing timelines.
Success in this new environment requires proactive planning, sophisticated multi-jurisdiction tracking, and strategic use of alternative immigration pathways where available. Companies that adjust workforce planning assumptions, invest in technology platforms capable of managing complex cross-border immigration coordination, and provide comprehensive support to affected employees will maintain their competitive advantage in attracting and retaining global talent.
Navigate consular district complexity with confidence. xpath.global’s immigration compliance platform, combined with our tiered relocation consulting services, provides the tools and expertise needed to manage extended processing timelines, coordinate residency establishment across multiple countries, and maintain workforce productivity despite administrative challenges. With 60,000+ vetted service providers across 183 countries, ISO-certified security, and automated compliance tracking, xpath.global ensures your global talent pipeline continues flowing smoothly. Explore how our solutions can help you adapt to the new consular district reality in 2026.
Italy Checklist: Sponsoring Highly Skilled Migrant Visas
Grab a copy of a guide to international employee relocation
View E-book