The October 2026 PERM Suspension: What Federal Records Reveal About Eight Technology Employers

The U.S. government’s decision to suspend eight major technology companies from the Permanent Labor Certification program has raised a question that the announcement itself did not answer: how many workers and immigration cases are actually exposed?

The available evidence provides several ways to measure the companies’ historical involvement in PERM. It does not provide one reliable count of employees affected by the October 8, 2026 decision.

An Ivvora analysis of published employer-level PERM records identifies 5,344 labor-certification determinations in FY2025 across selected legal-entity profiles for Microsoft, Adobe, Cognizant, Infosys, Tata Consultancy Services, Wipro, HCL and Capgemini. That represents approximately 3.61% of the 148,227 PERM applications processed nationally during the fiscal year.

The same profiles accounted for 5,133 determinations in FY2024, approximately 4.48% of the national total.

This produces a useful finding: although the selected companies’ combined historical determination volume increased slightly, their share of national processing decreased.

A separate examination of live case-tracking information identifies 2,499 recently filed applications reported as pending across six of those employer profiles as of October 9, 2026. That is a vendor-tracked subset, not an official count of cases frozen by the government.

These numbers measure different populations. Understanding those differences is essential to evaluating the suspension’s significance.

What Changed on October 8, 2026?

On October 8, Vice President JD Vance and Labor Secretary Keith Sonderling announced restrictions on eight technology companies’ participation in the U.S. Permanent Labor Certification program.

The companies publicly named were:

• Microsoft
• Adobe
• Cognizant
• Infosys
• Tata Consultancy Services
• Wipro
• HCL
• Capgemini

According to Reuters’ reporting on the announcement, the Labor Department said it would stop accepting new PERM applications involving the companies and stop processing pending applications.

The government raised allegations concerning the use of foreign-worker programs and their effects on employment opportunities for U.S. workers.

Those allegations should not be treated as established findings of wrongdoing. Microsoft disputed the implication that its use of immigration programs amounted to replacing U.S. workers with lower-paid foreign employees. The company stated that approximately 80% of its recent H-1B filings involved existing employees.

That response concerns H-1B filings, which are distinct from PERM labor-certification applications.

As of October 10, the available public reporting does not establish a definitive suspension duration or a complete company-by-company list of affected legal entities. This investigation also could not independently inspect a formal agency order specifying all procedural exceptions, review rights or reinstatement conditions.

The distinction matters because company names in a public announcement do not necessarily identify every subsidiary, affiliate or historical employer name appearing in Department of Labor data.

What PERM actually does

PERM is a labor-certification process administered by the U.S. Department of Labor.

For many employer-sponsored EB-2 and EB-3 permanent-residency cases, an employer must obtain a prevailing wage determination, conduct applicable recruitment and receive labor certification before proceeding with an immigrant petition.

The Department of Labor evaluates whether sufficient qualified, available U.S. workers exist for the offered position and whether employing the foreign worker would adversely affect the wages and working conditions of similarly employed U.S. workers.

PERM certification is not itself a green card. It is also not an H-1B visa, an approved immigrant petition or permanent residence.

The official process is described by the Department of Labor’s FLAG system.

How Much Historical PERM Activity Did the Eight Employers Represent?

The first challenge in measuring the suspension is deciding what to count.

A PERM application can be filed in one fiscal year and decided in another. Consequently, the number of applications processed during a fiscal year is not the number newly submitted during that year.

The table below measures historical DOL decisions attributed to selected employer profiles, not workers currently affected by the suspension.

PERM determinations by employer, FY2024 to FY2026

Selected employer profile	FY2024 decisions	FY2025 decisions	FY2026 YTD decisions
Microsoft Corporation	1,703	3,158	1,683
Adobe Inc.	89	466	183
Cognizant Technology Solutions US Corporation	1,235	None listed	None listed
Infosys Limited	87	None listed	None listed
Tata Consultancy Services Limited	1,467	513	2
Wipro Limited	169	523	None listed
HCL America Inc.	95	323	59
Capgemini America Inc.	288	361	98
Total across selected profiles	5,133	5,344	2,025

Source: Ivvora calculations using published ImmiLane employer profiles derived from Department of Labor disclosures. FY2026 values are labeled year-to-date by the data provider. Their precise comparability with the government’s June 30 reporting cutoff requires case-level reconciliation.

The selected profiles are not verified corporate-family aggregates. The table should not be interpreted as including every related subsidiary or alternative legal name.

The group’s national share declined despite higher decision volume

The Department of Labor’s FY2024 statistics report 114,550 processed PERM applications.

Its FY2025 statistics report 148,227.

Combining those official national totals with the selected employer profiles produces the following comparison.

Measure	FY2024	FY2025
National PERM applications processed	114,550	148,227
Selected eight-company determinations	5,133	5,344
Selected group as share of national processing	4.48%	3.61%
Change in selected group volume	—	+4.1%
Change in national processing volume	—	+29.4%

Calculation: Selected group share = selected employer determinations ÷ national processed applications × 100.

National processing activity grew substantially faster than the selected employers’ combined historical decision volume.

Their share declined by approximately 0.88 percentage points, even though the absolute number of selected decisions increased by 211.

This does not establish that the companies reduced new sponsorship. Determinations reflect earlier filing activity, agency processing times, withdrawals and other administrative factors.

It does establish that a simple company-level decision count can tell a different story from the corresponding national share.

Microsoft accounted for most of the selected FY2025 activity

Microsoft Corporation recorded 3,158 PERM determinations in FY2025 within the examined profile.

That represented approximately 59.1% of the combined selected-company total, up from 33.2% in FY2024.

Microsoft’s disclosed decisions rose from 1,703 to 3,158 between the two fiscal years, an increase of approximately 85.4%.

Tata Consultancy Services moved in the opposite direction. Its selected profile declined from 1,467 decisions in FY2024 to 513 in FY2025, a decrease of approximately 65%.

These different trajectories demonstrate why the eight companies should not be treated as a single immigration-dependent employer category.

Their historical use of PERM varies substantially, and recent filed cases may tell a different story from completed decisions.

Why TCS Can Report Single-Digit Filings Despite 513 Decisions in FY2025

One of the most revealing differences in the available data concerns Tata Consultancy Services.

In an October 9, 2026 stock-exchange statement, TCS reported that it had submitted a single-digit number of PERM applications during the preceding two years.

The company said it did not expect the suspension to affect its workforce strategy or customer engagements. It also reaffirmed plans to hire 15,000 additional employees in the United States over five years.

Yet the TCS employer profile shows 513 PERM determinations during FY2025, including 506 certifications.

At first glance, these figures appear inconsistent.

They are measuring different stages of the process.

New filings measure applications submitted during a period. Determinations measure applications decided during a period, including cases originally submitted much earlier.

A company can sharply reduce new applications while the Labor Department continues deciding a substantial historical backlog.

The available profile illustrates that possibility particularly clearly:

TCS measure	Reported value
FY2024 PERM determinations	1,467
FY2025 PERM determinations	513
FY2026 year-to-date determinations	2
Recently filed cases in the live tracker	8
Of those recently filed cases, reported pending	7
Company’s description of new filings over the past two years	Single digits

The profile and TCS’s statement are not necessarily contradictory. The historical determination count reflects decisions, while the corporate statement concerns recent applications.

The live tracker also covers only its documented recent filing population.

The broader lesson is significant for immigration-impact analysis: the date a case was decided cannot be substituted for the date it was filed.

Any investigation estimating the current effect of the suspension needs to distinguish those dates before drawing conclusions.

How Many Pending PERM Applications Can Actually Be Identified?

Historical determinations cannot establish the number of applications pending on October 8.

The Department of Labor’s disclosure files contain information about completed decisions. A recently certified case is generally no longer part of the active PERM decision queue, while a case awaiting review may not appear in the historical final-determination files.

A separate source is necessary to examine pending applications.

ImmiLane maintains a live tracker of recent PERM filings. Its employer profiles reported the following as of October 9, 2026.

Recently tracked pending applications

Employer profile	Reported pending cases	Tracker coverage
Cognizant Technology Solutions US Corporation	1,597	Recent filings beginning December 2025
Microsoft Corporation	574	Recent filings beginning November 2024
Capgemini America Inc.	162	Limited recent filing cohort
Adobe Inc.	156	Recent filings beginning November 2024
Tata Consultancy Services Limited	7	Recent filings beginning September 2025
HCL America Inc.	3	Limited recent filing cohort
Infosys Limited	Not shown	No cases in the available live tracker
Wipro Limited	Not shown	No cases in the available live tracker
Total for six profiles with reported pending cases	2,499	Incomplete, mixed-coverage vendor tracking

Source: Employer-specific ImmiLane case trackers accessed for this analysis. Coverage windows vary and are not a complete government inventory.

Cognizant accounts for approximately 63.9% of these reported tracked pending cases. Microsoft accounts for approximately 23.0%.

The result is notably different from the historical FY2025 determination distribution, where Microsoft dominated and Cognizant’s selected profile listed no determinations.

This difference is a warning against using historical processing to estimate current exposure.

Why 2,499 is not an affected-worker count

There are several limitations.

First, the tracker does not establish that every potentially affected employer legal entity is represented.

Second, its filing coverage varies among employers, and a profile with no tracked cases does not establish that the entire corporate group has no pending applications.

Third, a PERM record is an administrative application, not a verified count of distinct current employees.

Fourth, these tracker statuses have not been reconciled against an official October 8 company-specific suspension inventory.

Finally, the precise legal scope of the announced action has not been independently matched to every employer identifier in the dataset.

The 2,499 figure is therefore best described as a partial, third-party view of recent pending activity across selected employer profiles.

It should not be published as the number of workers frozen out of the green-card process.

The national backlog provides scale, not company-specific exposure

The Labor Department’s FY2026 third-quarter PERM statistics report approximately 120,429 active applications remaining as of June 30, 2026.

This is a national figure measured more than three months before the October announcement.

The public summary does not identify how many of those applications belonged to each of the eight named employers.

It cannot be directly compared with the October 9 vendor tracker to calculate a meaningful current share. The dates, coverage and reporting methods differ.

A credible estimate of the affected population would require a current agency inventory identifying the applications subject to the suspension, their precise employer entities and procedural statuses.

That information has not been established by this investigation.

What FY2025 and FY2026 Processing Data Reveal About the Backlog

The national PERM figures reveal why historical determination counts can remain high even when new applications decline.

National PERM measure	FY2024	FY2025	FY2026 through June 30
Applications received	151,773	117,849	82,234
Certified	102,036	138,093	104,028
Denied	5,031	3,404	3,879
Withdrawn	7,483	6,730	4,643
Total processed	114,550	148,227	112,550
Processed minus received	-37,223	+30,378	+30,316

Source: Department of Labor FY2024, FY2025 and FY2026 Q3 selected statistics. FY2026 is an incomplete fiscal year.

In FY2024, the agency received 37,223 more applications than it processed.

In FY2025, the relationship reversed: the agency processed 30,378 more applications than it received.

Through June 2026, it processed another 30,316 more applications than were received during that nine-month period.

These differences are not an independently reconciled measure of the change in the agency’s pending inventory. Case adjustments and reporting conventions also matter.

However, they demonstrate that annual decisions and annual receipts describe different activities.

The same distinction applies at employer level.

A decline in newly filed PERM applications need not produce an immediate decline in certifications, particularly when older cases remain in the processing queue.

Which Technical Jobs Appear Most Frequently in the Employer Records?

The companies’ historical PERM portfolios also differ by occupation.

The published employer profiles identify the following prominent job titles across their FY2020-to-FY2026 disclosure records.

Employer	Leading reported PERM job title	Cases with that exact reported title
Microsoft	Software Engineer	12,795
Adobe	Software Development Engineer	729
Cognizant	Computer Systems Analyst – V	6,588
Infosys	Technology Lead (Open Systems) – US	928
TCS	Technical Lead	3,244
Wipro	Lead Software Engineer – (Multiple Openings)	428
HCL America	Senior Systems Analysts	1,288
Capgemini America	Manager	2,190

Source: Published employer-profile job-title summaries, which cover historical disclosure records rather than only FY2025. The entries are employer-reported titles, not standardized occupation categories.

These titles show why it would be inaccurate to describe all eight employers’ historical applications as software-developer cases.

Some portfolios emphasize software engineering, while others contain substantial analyst, management, architecture, testing and consulting roles.

Job-title labels also create analytical problems.

For example, “Software Engineer,” “Software Engineer II,” and “Software Engineering” may describe related work but appear as separate text values.

Conversely, two employers may use the same title for jobs with different duties, experience requirements and occupational classifications.

A rigorous cross-employer occupational comparison should therefore use official Standard Occupational Classification codes rather than rely only on job-title strings.

National occupation data show why technical sponsorship matters

The Department of Labor reported 23,499 certified PERM cases for software developers during the first three quarters of FY2026.

That represented approximately 22.6% of all certified applications in the period.

Computer systems analysts accounted for another 4,594 certifications, approximately 4.4%.

These are national numbers, not the eight employers’ contributions.

They establish that software-related occupations represent a substantial part of the permanent labor-certification program, while also demonstrating that the program extends well beyond technology.

The selected employers’ exact occupation shares require a comparable case-level analysis using the same classification and reporting period.

Where Were the Sponsored Positions Reported?

Another important limitation emerges from the geographic fields in the historical records.

Published primary-worksite summaries show that several outsourcing companies report extremely high concentrations of PERM cases in individual states or cities.

Employer profile	Leading reported primary worksite	Cases in that worksite	Share of profile’s geographic sample
Microsoft	Washington	15,106	85.5%
Adobe	California	1,282	73.3%
Cognizant	College Station, Texas	3,144	100.0%
Infosys	Richardson, Texas	4,607	Approximately 100%
TCS	New York, New York	7,980	Approximately 100%
Wipro	East Brunswick, New Jersey	1,768	100.0%
Capgemini	Chicago, Illinois	3,133	99.7%

Source: ImmiLane primary-worksite summaries from FY2020 through FY2026 Q2 disclosures. Different employer profiles have different sample sizes. The table is not a geographic distribution of all current employees.

The degree of concentration deserves scrutiny.

Cognizant’s examined geographic sample shows all 3,144 cases in College Station, Texas. TCS shows 7,980 of 7,983 cases associated with New York state, and Wipro’s sample is entirely concentrated in East Brunswick, New Jersey.

These results should not be interpreted as demonstrating that nearly all of those companies’ sponsored employees worked physically in those places.

The fields may reflect the way employers described or reported primary worksites, including centralized office or other location-reporting arrangements. Establishing the explanation would require inspection of the underlying cases and reporting requirements.

This is particularly important for IT services companies whose employees may work at client locations or under arrangements involving multiple worksites.

For workforce-cost research, taking those geographic fields literally could produce distorted regional salary comparisons.

A reliable location study would need to inspect primary and secondary worksite fields, roving-worksite indicators, client-location descriptions and changes in disclosure formats.

Do Offered-Wage Records Support Claims About Cheaper Foreign Labor?

The suspension follows a political dispute over whether technology companies use foreign-worker programs to undercut U.S. wages or replace domestic employees.

The available PERM data can contribute to that debate, but it cannot resolve it on its own.

Employer profiles contain offered-wage information for certified cases. For six selected employers with FY2025 determinations, the reported medians are:

Selected employer	FY2025 median annualized PERM offered wage
Adobe	$176,000
Microsoft	$145,745
TCS	$139,693
Capgemini America	$131,498
HCL America	$126,402
Wipro	$109,283

Source: ImmiLane FY2025 employer profiles. These are medians from certified PERM applications, not actual total employee compensation or full employer expenditure.

A difference between two employer medians does not demonstrate that one employer pays comparable workers less.

Their case portfolios may have different occupations, seniority levels, locations, job requirements and sample sizes.

An employer’s PERM wage median also cannot be treated as its H-1B workforce’s median salary. The programs measure different populations.

For example, Microsoft’s published FY2025 profile reports a median PERM offered wage of $145,745 while its FY2025 certified H-1B LCA data report a median offered salary of $174,006.

That difference is not evidence that compensation fell, rose or was discriminatory. It reflects two distinct collections of job offers.

What an actual wage test would require

To investigate whether a specific employer consistently offers lower wages for comparable work, a researcher would need to match records on at least occupation, work location, wage unit, offered wage, relevant prevailing wage and defensible indicators of job level.

The analysis would also need to distinguish PERM and H-1B requirements and account for the fact that neither dataset represents all workers employed in a position.

Even a carefully adjusted comparison would not directly establish whether an employer unlawfully displaced another worker.

That question would require additional evidence concerning recruitment, actual employment decisions, applicable legal duties and potentially agency investigative findings.

The public offered-wage records alone cannot substantiate broad claims about worker replacement.

Why PERM, H-1B and Green-Card Statistics Cannot Be Added Together

Several different government systems appear in public discussion of the suspension.

Their numbers are not interchangeable.

Data source	What the record measures	What it does not establish
PERM applications received	New labor-certification applications submitted	Green cards granted
PERM determinations	Applications certified, denied or withdrawn	Distinct currently affected workers
Prevailing wage requests	Requests for wage determinations	Completed PERM applications
Labor Condition Applications	Employer labor attestations and positions requested	H-1B visas issued
USCIS H-1B petitions	Petitions for immigration benefits, including continuing employment	Necessarily unique newly hired workers
Form I-140 petitions	Employer or other qualifying immigrant petitions	Approved permanent residence
Form I-485 applications	Requests to adjust immigration status	Automatic green-card approval

Consider an employer requesting a prevailing wage, completing recruitment, submitting PERM, obtaining certification, filing Form I-140 and later supporting an adjustment-of-status application.

These are separate administrative events along a potentially lengthy process.

Counting each event as an additional employee would dramatically inflate the population.

Similarly, using an H-1B petition count to estimate new employment ignores extensions, amendments and other continuing-employment filings.

The Department of Labor’s FY2026 Q3 data report 104,028 PERM certifications through June 30.

That figure cannot be added to H-1B LCA positions to estimate the number of foreign employees hired nationally.

The correct unit of analysis depends on the question. For the October 8 suspension, the most relevant initial unit is the pending PERM application attached to a legally affected employer entity.

Which Immigration Stages Are Directly Affected?

The announced restrictions concern the Department of Labor’s PERM program.

Their effect on any particular employee depends on where that employee is in the immigration process and the precise terms of the government action.

Immigration stage	What can currently be said
Employer has not begun PERM	The announced halt to accepting new applications may prevent filing by a covered employer while the restriction applies
Prevailing wage requested	A prevailing wage determination is separate from PERM certification; the announcement’s full procedural effect requires clarification
Recruitment underway	Employers may face disruption, but validity periods, recruitment compliance and next steps depend on applicable rules and timing
PERM filed and awaiting decision	The announced suspension directly concerns processing of pending applications involving covered employers
PERM certified before October 8	Existing certification is not established to be automatically revoked by the public announcement
Form I-140 pending	USCIS adjudication is a separate process; no universal automatic denial has been established
Form I-140 approved	The announcement does not itself establish automatic revocation
Form I-485 pending	Adjustment-of-status proceedings are separate, with individualized eligibility and processing questions
Employee currently holds H-1B status	The PERM suspension is not an automatic cancellation of H-1B status

Some employees may also have questions about extending H-1B status beyond the usual maximum period, retaining priority dates or changing employment while an adjustment application is pending.

Those rules have specific statutory and regulatory requirements. In certain circumstances, for example, USCIS recognizes adjustment-of-status portability when the application has been pending for at least 180 days and the other conditions are satisfied.

However, eligibility cannot be determined from an employer-level PERM table.

Nor does every employment-based immigration category require PERM labor certification. Some immigrant classifications have different requirements or exceptions.

The reported action should therefore not be described as a nationwide H-1B ban, a blanket green-card revocation or a requirement for all affected employees to leave the United States.

What the Suspension Means for Employer Workforce Planning

For employers, the immediate planning issue is more specific than the number of historical applications.

The relevant questions concern employees whose future immigration options depend on a PERM application that the Labor Department will not currently accept or process.

That creates several distinct operational risks.

One is uncertainty surrounding the timing of cases already filed. Employers may have planned subsequent immigration steps around expected certification dates that are now uncertain.

Another is the timing of new sponsorship. Where PERM filing is an expected part of a long-term retention plan, a restriction can affect how confidently employers communicate future immigration milestones.

A third is individual employee eligibility. Some workers may have alternative immigration options, while others may be approaching status deadlines or depend on particular statutory extension provisions.

Those circumstances require case-specific legal review rather than assumptions based on company averages.

Employers can improve their internal understanding by separating personnel into clearly documented procedural cohorts:

1. Employees with no PERM filing yet.
2. Employees in prevailing-wage or recruitment stages.
3. Employees with pending PERM applications.
4. Employees with certified PERM but pending immigrant petitions.
5. Employees with approved immigrant petitions.
6. Employees with pending adjustment applications or other relevant immigration proceedings.

The purpose of such a review is to establish which individuals depend on which administrative actions.

It is not possible to replace that exercise with a historical count of PERM certifications.

For companies considering additional engineering capacity, the broader question of where to expand their workforce is a separate financial and operational analysis. It should compare equivalent roles, legal employment arrangements, actual statutory costs and operating constraints.

International hiring is neither a direct substitute for resolving an existing employee’s immigration situation nor an automatic consequence of this suspension.

What Remains Unknown About the Eight-Company Suspension?

Several questions are still unresolved as of October 10, 2026.

The exact affected legal entities. Public reporting identifies eight corporate names, but a complete match to historical DOL employer identifiers requires the relevant government instrument or authoritative entity list.

The number of pending cases covered. The available national data and third-party trackers do not establish an exhaustive October 8 inventory.

The duration of the action. No verified end date has been established for this investigation.

Procedures for review or reinstatement. The complete legal and administrative conditions have not been independently verified from a publicly accessible formal order.

The number of distinct employees affected. Administrative application counts cannot be treated as employee counts without further matching and verification.

The relationship to any ultimately established violations. Government allegations and investigative activity should not be conflated with final adjudicated findings.

The longer-term effect on hiring and retention. Historical records do not establish future employment decisions, attrition or business losses attributable to the suspension.

These gaps are not minor qualifications. They determine what kind of conclusion the available evidence can actually support.

Data Sources, Calculation Methodology and Limitations

This analysis combines three categories of sources.

The first is official Department of Labor reporting, principally the FY2024 and FY2025 PERM selected statistics, the FY2026 Q3 report and the Office of Foreign Labor Certification disclosure-data directory.

Those sources provide authoritative national processing totals, application receipts and administrative definitions.

The second is published ImmiLane employer profiles, which reproduce and aggregate historical PERM disclosure information and maintain recent case-status trackers. Eight selected profiles were examined, with the exact employer names linked in the tables above.

The third consists of contemporary reporting, including Reuters’ October 8 investigation and TCS’s October 9 stock-exchange statement.

How the figures were calculated

Selected employer total: Sum of fiscal-year determinations reported for the eight specifically identified employer profiles.

National share: Selected employer determinations divided by the official national PERM processed total for the same completed fiscal year.

Year-over-year change: Difference between FY2025 and FY2024 totals divided by FY2024 totals.

Concentration: An employer’s selected determinations divided by the combined eight-profile total.

Pending tracker subset: Sum of reported pending cases across the six employer profiles displaying a positive recent pending count.

Processing difference: National applications processed minus applications received during the same reporting period.

All percentage results were rounded after calculation.

Important restrictions on interpreting the findings

The historical employer totals are derived from a third-party aggregation of government disclosures. The underlying case-level spreadsheets were not successfully downloaded and independently reconstructed for this version of the analysis.

Consequently, the employer mapping, deduplication and fiscal-year classification have not received a complete independent audit.

The FY2024 and FY2025 national shares use completed fiscal years. The FY2026 employer-profile figures are year-to-date and should not be interpreted as full-year results or directly compared with FY2025 without period alignment.

The selected corporate names are narrower than fully verified corporate-family definitions. Subsidiaries and historical affiliates have not been automatically combined.

Pending-case tracking is incomplete and its employer-specific coverage varies.

Job-title and geographic tables reflect historical administrative records and may contain reporting patterns that are not representative of current employees or actual operational locations.

Wage medians describe offered wages on certified applications. They are not measures of actual employee earnings, total compensation or employer costs.

These limitations are material to the conclusions, not merely technical footnotes.

What the Federal Records Establish, and What They Do Not

The October 2026 PERM suspension affects a program with a substantial national processing backlog and a complicated relationship between new filings, completed decisions and individual immigration outcomes.

The examined employer records show that the eight named companies did not have uniform histories.

Microsoft represented most of the selected FY2025 determinations. Tata Consultancy Services showed a steep decline in completed decisions, alongside a corporate statement indicating very limited recent applications. Cognizant showed substantial historical activity and a comparatively large recently tracked pending population despite having no FY2025 determinations listed in the selected profile.

At the national level, PERM processing increasingly reflected decisions on cases filed in earlier periods, underscoring why historical determinations cannot be used as a direct estimate of newly sponsored workers.

These findings offer a more precise picture of the companies’ historical administrative activity.

They do not establish how many employees will lose immigration opportunities, how long processing will remain suspended or whether any specific employer engaged in unlawful conduct.

The most consequential missing data is a current, authoritative inventory of the pending applications covered by the government’s action.

Until that exists, estimates of the suspension’s affected workforce should remain clearly qualified.

For employers and researchers, the essential distinction is between what federal records measure, what company statements describe and what individual workers may actually experience.

Combining those categories without checking their definitions creates numbers that appear more certain than the evidence allows.