The Iran travel ban under Presidential Proclamation 10998 represents the most restrictive set of U.S. immigration barriers Iranian nationals have ever faced. Effective January 1, 2026, the proclamation fully suspends both immigrant and nonimmigrant visa issuance for Iranian nationals, including student visas (F-1) that remained available during the first Trump administration. A separate USCIS adjudication hold has frozen pending immigration benefit applications for Iranians already inside the United States, eliminating the adjustment-of-status workaround that previously allowed Iranian professionals to obtain Green Cards domestically. This guide covers the legal framework, every visa category's current status, the remaining exceptions, and practical considerations for Iranian employees, employers, and self-petitioners evaluating their immigration pathway in 2026.
Understanding the legal evolution is critical for Iranian employees and their employers, because the 2026 ban is not simply a reinstatement of the 2017 restrictions. It is a broader, more restrictive framework built on new legal authority that closes loopholes the previous ban left open.
The original travel ban began with Executive Orders 13769 and 13780, both challenged and blocked by federal courts (though EO 13780 was later partially reinstated by the Supreme Court in June 2017). Presidential Proclamation 9645 (September 24, 2017) survived legal challenge and was upheld by the Supreme Court in Trump v. Hawaii, 585 U.S. 667 (2018). Under PP 9645, Iran was subject to a suspension of both immigrant and most nonimmigrant visas, but student and exchange visitor visas (F-1, M-1, J-1) were explicitly exempted as narrow exceptions.
A waiver process existed on paper, but data showed that less than 2% of Iranian applicants received waivers. Through March 2019, the State Department reported that 440 waivers were granted to Iranian nationals (279 nonimmigrant, 161 immigrant) out of approximately 33,900 total Iranian applicants subject to the ban.
The critical gap in the first ban: Adjustment of Status (I-485) was not restricted because it is a domestic USCIS process that does not involve visa issuance or entry. This meant Iranian professionals already in the U.S. in valid nonimmigrant status could file for Adjustment of Status and obtain Green Cards without leaving the country. That pathway functioned as the primary workaround for Iranian professionals throughout the 2017 to 2021 period.
On January 20, 2021, President Biden signed Proclamation 10141 revoking PP 9645. All travel ban restrictions on Iran were lifted immediately. Annual visa issuance to Iranian nationals recovered significantly, though the lowest issuance numbers during the prior period reflected the combined effect of both PP 9645 restrictions and COVID-19 pandemic-related consular closures. Iranian students returned to U.S. universities in significant numbers, and employer-sponsored and self-petitioned Green Card filings surged.
The current administration reinstated and expanded restrictions through three sequential actions:
Executive Order 14161 (January 20, 2025) directed enhanced vetting procedures and ordered a 60-day interagency review to identify countries with deficient information-sharing and vetting standards. This did not immediately impose travel restrictions but signaled their return.
Presidential Proclamation 10949 (June 4, 2025) imposed a full ban on 12 countries including Iran, effective June 9, 2025 (with an additional 7 countries under partial restrictions, for 19 total). This proclamation was already more restrictive than PP 9645 because it banned student visas. However, it preserved an exception for immediate-relative immigrant visas (spouses, children, and parents of U.S. citizens), as well as exceptions for Afghan Special Immigrant Visas and adoptees.
Presidential Proclamation 10998 (December 16, 2025, effective January 1, 2026) expanded the ban to 19 countries under full suspension and 20 under partial suspension (plus holders of Palestinian Authority travel documents). Critically, it removed the immediate-relative immigrant visa exception that PP 10949 had preserved. The proclamation cites INA Sections 212(f) and 215(a), as well as 3 U.S.C. § 301, as statutory authority and has no expiration date, with 180-day review cycles. The first review is due approximately mid-June 2026.
Understanding the ban's scope for employers and HR teams: The visa ban applies based on nationality, while the USCIS adjudication hold applies based on country of birth or country of citizenship. An Iranian-born employee who is a Canadian citizen and travels on a Canadian passport is exempt from the visa ban under the dual-nationality exception. However, that same employee's pending USCIS applications (I-140, I-485, EAD) may still be subject to the adjudication hold under PM-602-0192, which applies to anyone born in or a citizen of a listed country. This means the USCIS hold is broader than the visa ban: a person born in Iran but now a citizen of Canada, or a person born in Canada but who has acquired Iranian citizenship, could both be affected.
The current restrictions are substantially broader than the first travel ban. Understanding these differences is essential for evaluating which strategies from 2017 to 2021 remain viable and which are now obsolete.
Student visas (F-1, M-1, J-1): Available under PP 9645; fully banned under Proclamation 10998. This eliminates the primary entry pathway used by thousands of Iranian students and early-career professionals.
Adjustment of status (I-485): Not restricted under PP 9645, allowing Iranians in the U.S. to obtain Green Cards domestically; frozen under USCIS PM-602-0192, with no final adjudication decisions being issued on most affected applications.
Immediate-relative immigrant visas (IR-1, IR-2, IR-5): Partially available through waivers under PP 9645 and explicitly exempted under PP 10949 (June 2025); exception removed under Proclamation 10998 effective January 1, 2026.
Waiver authority: Consular officers could recommend waivers under PP 9645; Secretary-level (or designee) approval is now required under Proclamation 10998, raising the practical bar significantly.
Scope of USCIS hold: No USCIS processing hold existed under PP 9645; PM-602-0192 and PM-602-0194 now freeze pending USCIS benefit applications for nationals born in or citizens of banned countries, covering I-140, I-129, I-765, I-131, N-400, N-470, and more. PM-602-0194 later carved out limited exceptions for I-90 (green card renewal), N-565, N-600, certain initial asylum-based EADs, and law-enforcement-requested filings.
Number of countries: PP 9645 covered 8 countries total (with varying restriction levels); Proclamation 10998 covers 39 countries (19 full, 20 partial), plus holders of Palestinian Authority travel documents.
Expiration: PP 9645 had review triggers; Proclamation 10998 has no expiration date, with 180-day review cycles that do not require any changes.
The bottom line for planning purposes: strategies that worked during the first ban, such as entering on an F-1 visa and then adjusting status to a green card while in the U.S., are no longer available. Iranian professionals and employers need to adapt to a fundamentally different landscape.
Iran sits on the full suspension list under Proclamation 10998. Both immigrant and nonimmigrant visa categories are banned, with only the narrow exceptions described below. This section covers every major visa type relevant to employment-based immigration.
All employment-based immigrant visa categories are suspended for Iranian nationals. This includes EB-1A (Extraordinary Ability), EB-1B (Outstanding Researcher), EB-1C (Multinational Manager), EB-2 NIW (National Interest Waiver), EB-2 PERM, EB-3 (Skilled Workers), and EB-5 (Investor). Family-based categories (IR-1, CR-1, IR-2, F-1 through F-4) are also banned. The Diversity Visa lottery is separately suspended.
What "banned" means in practice: The Department of State will not issue immigrant visas to Iranian nationals at any consular post worldwide. USCIS will still accept I-140 petition filings (the underlying petition does not require a visa), but the adjudication hold means no final decision will be issued on most affected cases. This is a critical distinction: filing still locks in a priority date, even though approval is frozen.
The sole immigrant visa exception for Iranians is for persecuted ethnic and religious minorities. The Lautenberg Amendment, the closest statutory analog, enumerates Jews, Christians, Baha'is, Sabaean-Mandaeans, and Zoroastrians. Proclamation 10998 itself names no specific groups, referring broadly to ethnic and religious minorities facing persecution. Other groups, including Kurds, Sunni Muslims, and Sufi Muslims, are well-documented persecuted minorities per USCIRF and human rights organizations and may qualify under this exception, though their eligibility is assessed on a case-by-case basis.
All nonimmigrant work visa categories are suspended. This includes H-1B (Specialty Occupation), O-1A and O-1B (Extraordinary Ability), L-1A and L-1B (Intracompany Transfer), TN (USMCA Professional, though Iran is not a party), and E-2 (Treaty Investor, though no U.S.-Iran treaty exists). Student visas (F-1, M-1) and exchange visitor visas (J-1) are also banned, along with B-1/B-2 (business/tourist), K-1 (fiancé), and R-1 (religious worker).
The removal of F-1 availability is one of the most significant changes from the first ban. During the 2017 to 2021 period, IIE Open Doors data shows approximately 12,300 to 12,700 Iranian students were enrolled at U.S. universities, predominantly in STEM fields. Under the current ban, no new Iranian students can obtain visas to enter the United States.
Categories that remain available under Proclamation 10998:
The most consequential shift for Iranian employees and employers already in the United States is not the proclamation itself. It is USCIS Policy Memorandum PM-602-0192 (December 2, 2025), expanded by PM-602-0194 (January 1, 2026). These memos placed an indefinite hold on virtually all pending immigration benefit applications for nationals born in or citizens of the 19 fully banned countries, including Iran.
Under the first Trump travel ban, adjustment of status was not restricted. Iranian professionals used this as their primary pathway to Green Cards. That pathway is now frozen.
The hold applies broadly to benefit requests, including: I-485 (Adjustment of Status), I-140 (Immigrant Petition for Alien Workers), I-129 (Petition for a Nonimmigrant Worker including H-1B extensions), I-765 (Application for Employment Authorization), I-131 (Application for Travel Documents, Parole Documents, and Arrival/Departure Records ), I-751 (Petition to Remove Conditions on Residence), N-400 (Application for Naturalization), N-470 (Application to Preserve Residence for Naturalization Purposes), and essentially every other USCIS benefit type. The memo's examples are explicitly non-exhaustive. PM-602-0194 later carved out limited exceptions for I-90 (Application to Replace Permanent Resident Card (Green Card)), N-565 (Application for Replacement Naturalization/Citizenship Document), N-600 (Application for Certificate of Citizenship), certain initial asylum-based EADs, and law-enforcement-requested filings.
A "hold" means cases may continue processing in the background. RFEs may be issued, biometrics may be collected, and interviews may even occur. But no final decisions will be issued on most affected applications, subject to the limited exceptions noted above. There is no published end date for the hold.
The hold creates immediate workforce planning challenges. Employers sponsoring Iranian nationals for H-1B extensions will not receive approvals. EAD renewals will not be adjudicated (except for enumerated exceptions). The automatic 240-day work authorization extension (triggered by timely filing of an H-1B extension) provides temporary protection, but it is a finite window.
Important note on EAD auto-extensions: The automatic 540-day EAD extension that was made permanent via a December 2024 final rule (89 FR 101200) has since been eliminated by a DHS Interim Final Rule published October 30, 2025 (90 FR 48800). EAD renewal applications filed on or after October 30, 2025 no longer receive any automatic extension. Applications filed before that date retain the 540-day protection. This is a critical consideration for Iranian nationals relying on EAD-based work authorization.
Considerations for employers: Auditing the workforce to identify employees born in or citizens of one of the 19 fully banned countries, filing all pending extensions and renewals to trigger any available automatic extension periods, documenting all filing dates, and maintaining copies of receipt notices are all steps worth evaluating. Consulting immigration counsel about contingency plans for employees whose work authorization may lapse during the hold is also worth considering. Alma's business immigration services can help companies manage affected employee populations with strategic filing timelines and status monitoring.
There is no separate waiver application form. The Department of State instructs applicants to apply for a visa through standard channels and disclose any information that might demonstrate eligibility for an exception during the interview. The consular officer evaluates the case and may forward eligible cases for interagency review.
To qualify for a case-by-case exception, an applicant must demonstrate all three of the following: (1) denying entry would cause undue hardship, meaning an unusual situation requiring immediate travel; (2) the applicant's entry would not pose a threat to national security or public safety; and (3) entry would serve the U.S. national interest, meaning a U.S. person or entity has a significant interest in the applicant's admission.
Data from the first travel ban illustrates the difficulty of the process. Through March 2019, the State Department reported that 440 waivers were granted to Iranian nationals (279 nonimmigrant, 161 immigrant) out of approximately 33,900 total Iranian applicants subject to the ban, a rate approximately under 2%. For spousal visas (CR-1/IR-1), approximately 19 were approved against 644 denials, a roughly 2.9% rate. The current framework raises the bar further by requiring Secretary-level (or designee) approval rather than consular officer discretion.
No public waiver statistics have been released for the 2025 to 2026 ban, and no mandatory reporting requirement exists.
Even when the ban is not in effect, Iranian nationals face extraordinary consular processing hurdles. Security Advisory Opinions (SAOs) are virtually mandatory for all Iranians due to Iran's state-sponsor-of-terrorism designation. Iranian STEM professionals face additional screening. Practical wait times for SAOs range from 2 weeks to over 12 months, though the longer end of that range represents exceptional cases. Since there is no U.S. embassy in Iran, all visa interviews must occur at third-country posts such as U.S. Embassy Ankara (Turkey), Abu Dhabi (UAE), or Yerevan (Armenia).
For Iranian nationals outside the United States, consular processing is effectively shut down. The combination of (1) no U.S. embassy in Iran, (2) a full travel ban, (3) mandatory SAO requirements, and (4) a separate 75-country immigrant visa processing pause announced January 14, 2026 (effective January 21, 2026) creates what amounts to a quadruple barrier.
Since the U.S. has not maintained diplomatic relations with Iran since April 1980 (the embassy was seized in November 1979), all Iranian visa applications must be processed at third-country posts:
Under the full suspension, these posts have ceased issuing visas to Iranian nationals except under the narrow categorical exceptions described above.
For approved immigrant visa petitions, the National Visa Center (NVC) stage adds additional time. Even when visa issuance resumes, applicants can expect the standard NVC timeline: case creation (1 to 2 weeks), fee payment ($345 per person), document submission through the CEAC portal (4 to 8 weeks), document review (4 to 12 weeks), and transfer to the embassy (2 to 4 weeks). Total NVC processing typically runs 3 to 9 months depending on case complexity.
Iranian applicants face specific NVC challenges including: police certificate requirements from Iran (which can take 2 to 4 months to obtain depending on the method of application), document translations requiring certified translators, birth certificate corrections or delayed civil registrations, and the need to coordinate with third-country embassies for interview scheduling.
Even outside the context of the travel ban, Iranian nationals routinely face extended "administrative processing" at consulates. This refers to additional security screening that occurs after the visa interview. Two specific screening programs affect nearly all Iranian applicants:
Visa Condor: A mandatory SAO triggered automatically for nationals of state sponsors of terrorism. Iran has been on the U.S. state sponsor of terrorism list continuously since January 19, 1984. This screening applies regardless of visa category or applicant profile.
Visa Mantis: An additional technology transfer screening applied to STEM professionals. This check evaluates whether an applicant's technical expertise could contribute to weapons proliferation or unauthorized technology transfer. Iranian engineers, scientists, and researchers in fields like nuclear physics, aerospace, advanced materials, and cybersecurity are virtually guaranteed to trigger this screening.
Combined processing times for these checks range from 2 weeks to over 12 months, though most cases are resolved within 6 months. The U.S. Embassy in Ankara instructs applicants to wait at least 180 days before making status inquiries. There is no expedite mechanism for SAOs, and congressional inquiries have limited effect on processing speed.
The travel ban and adjudication hold together create a unique set of challenges for each major employment-based green card pathway. Understanding the specific impact on each category helps employees and employers make informed filing decisions.
The EB-2 NIW has been the most popular self-petition category for Iranian professionals. Iran accounted for 364 I-140 approvals in Q1 FY2025 (7.7% of all EB-2 NIW approvals), making Iranian nationals one of the largest beneficiary groups. The NIW is particularly attractive because it does not require employer sponsorship, meaning employees can file independently regardless of their employer's willingness to support a green card.
Current status: I-140 petitions can still be filed and will be accepted by USCIS. However, adjudication is on hold, meaning no approvals or denials will be issued. Premium processing fees ($2,965 as of March 1, 2026) will be accepted but the 45-business-day clock is effectively paused by the hold. For applicants inside the U.S., I-485 concurrent filing is technically possible but subject to the same adjudication freeze.
Strategic value of filing during this period: Filing locks in a priority date. The April 2026 Visa Bulletin Dates for Filing chart (which USCIS has directed applicants to use) shows EB-2 as "Current" for Iran (which falls under "All Chargeability Areas Except Those Listed"). Notably, EB-2 is now also "Current" on the Final Action Dates chart for all countries except China and India. When the hold lifts, applicants with earlier priority dates will be processed first.
These categories face the same adjudication hold as EB-2 NIW. However, EB-1A has the advantage of generally faster processing times under normal conditions (15 business days with premium processing). Iranian researchers and scientists with strong publication records, citations, and peer review contributions may find EB-1A worth considering as an alternative or parallel filing alongside EB-2 NIW. Having both petitions on file provides flexibility when restrictions change.
The PERM labor certification process through the Department of Labor is not directly affected by the travel ban or the USCIS hold. Employers can still file PERM applications and obtain certifications. However, the resulting I-140 petition will be subject to the USCIS adjudication hold once filed. According to current DOL data, PERM processing alone currently averages approximately 16 to 17 months, with audit-selected cases facing additional delays of 6 to 12 months.
For Iranian employees, the distinction between self-petitioned EB-2 NIW and employer-sponsored EB-2 PERM involves several factors: NIW provides independence from any single employer, faster preparation timelines (approximately 2 weeks with Alma versus 16+ months for PERM), and no risk of invalidation if the employee changes jobs. PERM requires employer cooperation but may be appropriate as a backup strategy if the employee is uncertain about meeting NIW evidentiary standards.
Despite the severity of the restrictions, several strategic actions remain available. The key principle: positioning for the fastest possible outcome if and when restrictions lift.
Even though adjudication is on hold, filing an I-140 (whether EB-1A, EB-2 NIW, or employer-sponsored) locks in a priority date. If and when restrictions lift, an early priority date provides a critical advantage, particularly given that the April 2026 Visa Bulletin shows both EB-1 and EB-2 as "Current" on the Dates for Filing chart and the Final Action Dates chart for all chargeability areas except China and India. Under normal circumstances, this would be an ideal moment for Iranian applicants to file I-485.
How Alma can help: Alma's platform prepares and files I-140 petitions in approximately 2 weeks. Even though final adjudication is on hold, filing during this period secures the earliest possible priority date. Alma attorneys have deep experience with Iranian national cases across EB-2 NIW, EB-1A, and O-1 categories. Schedule a consultation to assess eligibility and filing strategy.
Departure from the U.S. carries the highest practical risk for Iranian nationals. Any Iranian national who departs the U.S. will need a new visa to return, and new visa issuance is fully suspended. Automatic visa revalidation for short trips to Canada or Mexico is unavailable to Iranian nationals because nationals of State Sponsors of Terrorism are categorically ineligible for automatic visa revalidation under 8 CFR 214.1(b) and 22 CFR 41.112(d). Advance parole documents (I-131) are subject to the same adjudication hold, meaning even if filed, the document may not be issued before travel is needed.
Extensions are subject to the hold, but timely filing triggers an automatic 240-day work authorization extension under 8 CFR § 274a.12(b)(20) for H-1B holders. Filing up to six months before expiration maximizes the protected period. For EAD holders: the automatic 540-day extension was eliminated by a DHS Interim Final Rule effective October 30, 2025. EAD renewal applications filed on or after that date no longer receive an automatic extension. Only applications filed before October 30, 2025 retain the 540-day protection per USCIS policy.
For Iranians who are Baha'i, Christian, Jewish, Zoroastrian, or Sabaean-Mandaean, this remains the most viable consular processing pathway. These groups are specifically enumerated under the Lautenberg Amendment framework. Other persecuted groups, including Kurds, Sunni Muslims, and Sufi Muslims, may also qualify under the broader Section 6(b)(vi) exception, which refers to ethnic and religious minorities facing persecution, though eligibility is assessed on a case-by-case basis. Immigration attorneys report active approvals under this exception. Documentation of minority status must be carefully prepared.
Multiple federal lawsuits challenge both the proclamations and the USCIS adjudication holds. As of March 2026, no court has issued an injunction blocking the ban or the holds, but the legal landscape is evolving. The 180-day presidential review report is due approximately mid-June 2026, and any policy changes from that review could alter the current framework.
Read success stories from Alma's clients including researchers, entrepreneurs, and healthcare professionals who filed before and during travel ban periods.
Many law firms take 2 to 4 months for petition preparation and charge fees that vary widely across the market (commonly $4,000 to $15,000 for EB-2 NIW cases). Alma's immigration platform combines experienced attorneys with technology to deliver faster, more transparent service at transparent, flat-fee pricing.
Speed when it matters most: Alma prepares and files I-140 petitions in approximately 2 weeks. In the current environment, where every month of delay means a later priority date, this speed translates directly to a better position in line when restrictions change.
Legal expertise with travel ban cases: Alma attorneys have handled numerous cases with approval rates above 99% for qualified cases (self-reported; prior results do not guarantee similar outcomes). The team understands the unique challenges Iranian nationals face, including SAO processing, third-country consular interview logistics, and the interaction between the travel ban and domestic USCIS filing strategies.
Transparent pricing: Flat-fee structure with no hidden costs. EB-1A, EB-1B, and EB-2 NIW petitions are $10,000 each (or $7,000 for EB-1 or EB-2 NIW with an approved O-1). RFE responses are included in the base fee. Payment plans are available.
Schedule a consultation to discuss immigration options with an experienced attorney.
Iranian nationals in the U.S. can still file I-140 petitions and I-485 applications with USCIS. Filing locks in a priority date and may trigger ancillary benefits such as extended lawful presence. However, under Policy Memorandum PM-602-0192, USCIS has placed an indefinite hold on final adjudication of most immigration benefit applications for nationals born in or citizens of the 19 fully banned countries, subject to limited enumerated exceptions. This means most approvals will not be issued until the hold is lifted, but the filing itself remains strategically valuable. Alma's attorneys can provide information on optimal filing timing and strategy.
No. This is one of the most significant changes from the 2017 travel ban. Under Presidential Proclamation 9645 (2017), F-1 student visas were explicitly exempted, allowing thousands of Iranian students to study at U.S. universities (IIE Open Doors reported approximately 12,300 to 12,700 Iranian students enrolled during that period). Under the current Proclamation 10998, F-1, M-1, and J-1 visas are all fully suspended for Iranian nationals. Current students already in the U.S. on valid F-1 status are not affected as long as they maintain status and do not leave the country.
If an H-1B extension was filed before the current status expired, the filer is protected by the automatic 240-day work authorization extension under 8 CFR § 274a.12(b)(20). This allows continued work for the same employer in the same role while the extension is pending. However, if the hold lasts longer than 240 days beyond the expiration date, work authorization could lapse. Filing up to six months before expiration maximizes the protected period. Employers may find it beneficial to document all filing dates and maintain copies of receipt notices.
Dual nationals traveling on their non-Iranian passport are exempt from the visa ban under Section 6(b)(ii) of Proclamation 10998. An Iranian-Canadian traveling on a Canadian passport would not be subject to the travel restriction. However, the USCIS adjudication hold applies more broadly to anyone born in or a citizen of a listed country. This means even dual nationals with pending USCIS applications may face frozen benefit adjudications. The distinction between the visa ban (nationality-based) and the USCIS hold (birthplace-and-citizenship-based) is important and can be reviewed with experienced immigration counsel.
Filing an EB-2 NIW petition remains strategically important despite the current restrictions. While final adjudication is frozen, filing locks in a priority date and positions applicants ahead of those who delay. Iran had 364 EB-2 NIW I-140 approvals in Q1 FY2025 alone (7.7% of all approvals), demonstrating that Iranians are a significant beneficiary group in this category. When restrictions eventually change, whether through policy review, court order, or a new administration, applicants with early priority dates and strong petitions on file will be first in line. Alma's attorneys prepare petitions in approximately 2 weeks and can help build the strongest possible case while the opportunity to file remains open.
