In both Global Mobility and U.S. politics, one thing is certain: change is constant. The recently approved changes to the H-1B lottery system are the latest example of this trend. While there is ongoing uncertainty around H-1B visas, such as the proposed $100,000 filing fee and Project Firewall, the shift to a wage-based lottery system is one of the more likely reforms to be implemented.
For Mobility leaders, this environment of shifting policy creates both compliance risk and advisory opportunity. By being aware of these changes and their implications, Mobility leaders can guide conversations with Legal, Immigration, Talent, and Compensation teams, ensuring that workforce planning remains aligned with both legal requirements and business needs.
To understand Mobility’s potential impact, it’s important to first understand how the H-1B system currently works. In the United States, H-1B visas allow employers to hire foreign workers in specialized occupations. Approximately 85,000 H-1B visas are granted annually by randomized lottery: 65,000 are available for any eligible applicant, with an additional 20,000 for those with a US master’s degree or higher.
However, recently proposed regulations have moved away from the previously randomized system: the revised approach instead uses a weighted selection process that prioritizes higher wage levels. The wage levels are tied to percentiles of wages earned by workers in that job category and geography.
Levels I–II generally represent entry-level or less experienced workers, while Levels III–IV represent more experienced or highly skilled professionals. Under the new system, all applicants still enter the same lottery pool, but their number of entries is determined by wage level.
For example, a Level IV applicant receives four entries, Level III receives three, Level II receives two, and Level I receives one. This weighting significantly increases the probability that higher-paid roles will be selected, while lower-paid roles still have a chance but at reduced odds. It’s important to note that most visa categories, such as the L-1 for intracompany transfers, remain unaffected.
Policy changes like this create uncertainty, but they also create opportunity: Mobility leaders are uniquely positioned to help their organizations anticipate risks, adapt hiring practices, and align talent planning with evolving U.S. immigration policies. Instead of treating this change as a compliance-only issue, Mobility can use it as a platform to act as a strategic advisor.
For example, with these changes, companies may face pressure to raise salaries for H-1B-sponsored roles to increase the odds in the weighted system, but this creates a risk of H-1B workers receiving a higher salary than a local peer. Before creating internal inequity, Mobility should work closely with compensation teams to review base salary structures and ensure alignment with both talent needs and pay equity.
In some cases, rebalancing compensation by shifting a greater portion into base salary from variable elements (like allowances or premiums) may help achieve the required wage level while safeguarding internal equity. Keep in mind: only base salary (not variable elements) counts towards wage levels.
These changes will also make it more difficult to bring in low-wage or entry-level foreign talent. For organizations that rely on specialized junior hires as part of their long-term pipeline, this presents a clear challenge. While Mobility leaders may not own talent strategy directly, by being aware of the policy shift they can help guide conversations with Talent teams about how early-career talent is sourced and developed.
Rather than relying heavily on the U.S. H-1B system for entry-level placements, companies may look to expand recruitment into other geographies. Adopting rotational programs that begin outside the United States, for example, provides a way to build a steady stream of talent while reducing pressure on U.S. visa slots.
Equally important is investing in early-career development programs in international markets. By creating structured training and career growth opportunities abroad, companies can prepare high-potential employees to step into more senior roles (with eventually higher wage levels) by the time they are considered for U.S. assignments.
This approach ensures that foreign talent continues to be part of the workforce strategy, even if their first touchpoint with the company is outside the United States. For Mobility, this means shifting the conversation from short-term visa fixes to long-term talent investment, helping the business avoid disruptions once the new rules take effect. Mobility’s role here is not to design these programs, but to surface the immigration perspective so leaders understand how today’s decisions impact tomorrow’s access to talent.
This immigration policy shift underscores the need for Mobility leaders to act as advisors rather than policy executors. While other H-1B reforms are still pending, it is especially important for Mobility to stay aware of all potential impacts in this ever-changing landscape.
By translating immigration changes into clear business risks and opportunities, Mobility can help build bridges between HR, Compensation, Talent Acquisition, and business leaders while advocating for aligning global talent strategy to ensure the business remains both competitive and resilient.
As immigration policy continues to evolve, Mobility leaders who stay proactive will be best positioned to guide their organizations with confidence. If you’d like to better understand how upcoming H-1B changes could impact your workforce strategy, reach out to AIRINC’s advisory team to explore data-driven insights tailored to your organization’s needs.
Special thanks to Miki Kawashima Matrician, Partner at WR Immigration, whose expertise and insights helped inform this article and frame the implications for Mobility leaders navigating H-1B lottery changes.