USCIS Places Indefinite Adjudication Hold on Immigration Benefits for Nationals of Designated Countries (PM-602-0192), Expanded to 39 Countries on Jan 1

On December 2, 2025, USCIS issued Policy Memorandum PM-602-0192, placing an indefinite adjudicative hold on all pending immigration benefit requests filed by nationals of an initial set of 19 designated countries. On January 1, 2026, PM-602-0194 expanded the hold to 39 countries. Under both memos, USCIS continues to accept applications — and the associated filing fees, which are non-refundable under USCIS’s own Policy Manual — but neither approves nor denies them: the cases are held in an indefinite pending state with no adjudication timeline.

The hold compounds an already-collapsing throughput. USCIS ended FY2025 with roughly 11.6 million pending cases plus a “frontlog” of received-but-not-entered filings; completions declined through the first three quarters of the second Trump administration even as filings rose. For affected applicants, the practical effect of an indefinite hold is loss of status: employment authorization (EAD) renewals stall — the automatic 540-day renewal extension was terminated effective October 30, 2025 — and applicants who fall out of status become removable. Court-adjudicated abuse survivors, work-authorized long-term residents, and pending adjustment-of-status applicants are caught alike.

Federal courts in multiple districts found the country-based hold likely unlawful. In Doe v. Trump (D. Mass.), Judge Kobick issued preliminary injunctions on April 30 and May 7, 2026 covering 266 plaintiffs; Saghafi v. Edlow (D. Md.) produced a parallel injunction on April 24, 2026.

This is administrative delay weaponized as an enforcement tool: a government-created bottleneck used to push lawful immigrants out of status while the agency retains the fees. It is the same mechanism documented in the SIJS deferred-action rescission (2026-05-10–uscis-ends-sijs-deferred-action-child-immigrants-visa-backlog) and the voluntary-departure coercion reporting — procedural leverage substituting for, and evading the due-process constraints of, formal denial. The pattern was surfaced publicly in part by immigration-bar practitioners and whistleblower Jenn Budd, though the load-bearing evidence is the policy memos themselves and the injunctions against them.

Research Gaps

• Total fees collected on held applications across the 39 designated countries
• Whether a lawsuit or GAO/OIG inquiry specifically alleges fee collection without adjudication (unjust enrichment) as distinct from the due-process challenges already filed
• Final disposition of Doe v. Trump and Saghafi v. Edlow beyond the preliminary-injunction stage

Related Entries

• 2026-05-10–uscis-ends-sijs-deferred-action-child-immigrants-visa-backlog
• uscis
• administrative-delay-as-enforcement