The U.S. Department of Labor (DOL) recently released a significant update to its O*NET (Occupational Information Network) database in April 2025. While these updates are part of routine maintenance to reflect evolving job markets, they have direct implications on employment-based immigration processes—including PERM labor certifications and H-1B petitions.
Given the reliance of both DOL and USCIS on O*NET data to evaluate job classifications, prevailing wages, and required qualifications, it is crucial for employers, attorneys, and foreign workers to understand how these changes could affect current and future filings.
What Has Changed in O*NET?
The April 2025 O*NET update includes:
- Revised job descriptions, tasks, and core responsibilities across various occupations.
- Updates to Specific Vocational Preparation (SVP) and Job Zones, altering the recognized level of education and experience required.
- Modifications to technology tools and software skills listed for many roles.
- Reclassification or merging of certain Standard Occupational Classification (SOC) codes.
These updates influence how the DOL interprets whether an employer’s job duties and requirements align with market norms.
Key Job Zone Shifts to Note
Here are a few prominent occupations affected by updated Job Zone levels:
|
Occupation Title |
SOC Code |
Previous Job Zone |
Updated Job Zone |
|
Data Scientists |
15-2051.00 |
4 |
5 |
|
Software Developers |
15-1252.00 |
4 |
5 |
|
Financial Analysts |
13-2051.00 |
4 |
5 |
|
Market Research Analysts |
13-1161.00 |
3 |
4 |
|
Computer Systems Analysts |
15-1211.00 |
4 |
5 |
Job Zone increases suggest that the DOL now views these roles as requiring more advanced preparation—typically more education, training, or experience. This can influence how prevailing wages are determined and whether a job’s stated qualifications are deemed excessive or appropriate.
Impact on PERM Labor Certifications
Employers filing PERM applications should carefully reassess how their roles are defined:
- Prevailing Wage Determinations (PWDs): Job Zone and SVP adjustments may result in higher wage requirements, particularly for roles now considered more complex.
- Job Description Alignment: If your job duties no longer match the revised O*NET definition, DOL may see the position as overly tailored, triggering an audit.
- Education & Experience Requirements: Employers must now justify higher education or experience thresholds in light of updated SVP levels.
Impact on H-1B Petitions
USCIS regularly refers to O*NET when evaluating whether a position qualifies as a specialty occupation. Updates to duties, job zones, or complexity may:
- Raise questions about whether a bachelor’s degree is “normally required.”
- Lead to Requests for Evidence (RFEs) or denials if job duties appear too general or inconsistent with the O*NET profile.
- Affect how wage levels (I–IV) are assigned in H-1B LCA filings, depending on the revised classification.
Employer Best Practices
To minimize compliance risk, we recommend:
- Review SOC Codes currently used in immigration filings.
- Revisit job descriptions and ensure alignment with the latest O*NET profiles.
- Adjust minimum qualifications in PERM and H-1B documentation as needed.
- Stay audit-ready by preparing rationales for job requirements and prevailing wage choices.
- Coordinate with immigration counsel to identify roles significantly impacted by the update.
Final Thoughts
These O*NET updates, though technical, carry meaningful implications for how roles are classified and evaluated in employment-based immigration. A proactive review can go a long way in avoiding processing delays or denials—particularly in this climate of increasing scrutiny.
If you’re unsure whether your roles are impacted, we recommend initiating a quick internal audit in collaboration with your immigration advisors.
Disclaimer
This article is for informational purposes only and does not constitute legal advice. Immigration regulations are subject to change, and the impact of O*NET updates can vary depending on the specific facts of a case. For case-specific guidance, please consult an immigration attorney or qualified professional.
Author: Ms. Harsha Venkatesh, Partner, NovoJuris Legal.
"For any of your immigration requirements, do write to us at relationships@novojuris.com"