USCIS intends to revoke your approved L-1?
An L-1 Notice of Intent to Revoke means USCIS is reconsidering an intracompany transferee petition it previously approved. The agency may now question the corporate relationship, continued business operations, the beneficiary's L-1A managerial or executive duties, L-1B specialized knowledge, prior qualifying employment, or the accuracy of facts contained in the petition.
Send Us Your L-1 NOIRWhat approved L-1 requirement does USCIS now believe is missing?
An L-1 NOIR usually asks whether the approved intracompany structure still exists—or ever existed as represented.
L classification depends on a qualifying relationship between the relevant U.S. and foreign organizations and on the beneficiary satisfying the requirements for intracompany transferee classification.
L-1A applies to qualifying managers and executives. L-1B applies to qualifying employees with specialized knowledge. The petition also depends on qualifying foreign employment and continued organizational requirements.
A NOIR should therefore be broken into the specific regulatory finding USCIS proposes to make rather than answered only with general evidence that the company and employee are legitimate.
Current regulations identify six grounds for revocation on notice.
The response should identify which ground or grounds USCIS invokes and answer each one separately.
Corporate Relationship No Longer Qualifies
USCIS may issue a NOIR if one or more entities are no longer qualifying organizations. Ownership, control, corporate restructuring, sale, dissolution, merger, or other changes may become central to the case.
Employee Allegedly No Longer Qualifies
USCIS may conclude that the beneficiary is no longer eligible under the L classification, including concerns relating to the approved capacity or other underlying eligibility requirements.
Qualifying Organization Violated L Requirements
USCIS may allege that a qualifying organization failed to comply with requirements governing L intracompany transferee classification.
Statement of Facts Was Not True and Correct
A NOIR may challenge ownership documents, staffing, duties, foreign employment, business operations, organizational charts, payroll, financial records, or another fact submitted with the approved petition.
Approval Allegedly Involved Gross Error
USCIS may seek to revoke the petition when it concludes that the original approval involved gross error under the applicable L classification requirements.
Blanket Procedure Has Not Been Used
For a blanket L petition, the regulations provide a separate revocation ground where none of the qualifying organizations has used the blanket petition procedure for three consecutive years.
The beneficiary's approved capacity determines much of the response.
Manager or Executive
A NOIR may question whether the beneficiary primarily performs managerial or executive functions rather than principally performing the day-to-day operational work of the company.
The response may need to document organizational structure, subordinate employees, professional staff, function management, decision-making authority, budget responsibility, reporting relationships, and the actual allocation of duties.
Specialized Knowledge
An L-1B NOIR may question whether the beneficiary possesses the required special or advanced knowledge and whether the U.S. position actually requires that qualifying knowledge.
Product knowledge, internal processes, proprietary systems, international applications, training history, projects, comparative employee evidence, and detailed explanations of the beneficiary's expertise may be relevant.
Does the required relationship between the U.S. and foreign entities still exist?
Ownership and control should be proven with the actual corporate record.
L classification requires qualifying organizations connected through an eligible parent, branch, affiliate, or subsidiary relationship. USCIS may examine both legal ownership and actual control.
A response may require formation documents, stock certificates, shareholder registers, capitalization records, tax returns, corporate resolutions, purchase agreements, financial statements, organizational records, government registrations, and evidence tracing ownership through multiple entities.
Where a corporate restructuring occurred after approval, establish exactly what changed, when it changed, and whether the qualifying relationship continued.
If the NOIR incorrectly reads a corporate chart or ownership record, identify the specific factual error rather than merely resubmitting the same documents.
A corporate entity on paper is not enough by itself.
The regulations define a qualifying organization in part through actual business operations.
A post-approval compliance visit can trigger an L-1 NOIR.
USCIS conducts unannounced administrative site visits as part of compliance review.
A site visit may examine whether the petitioning organization exists and operates as represented, whether the beneficiary works at the reported location, and whether the actual position corresponds to the approved petition.
For L-1A cases, organizational staffing and the beneficiary's actual managerial or executive duties may become important. For L-1B cases, USCIS may examine what work the beneficiary performs and how the claimed specialized knowledge is used.
Compare any NOIR summary of the visit with company records and the accounts of the people who actually spoke with the officer. Temporary absences, remote work, changed office locations, misunderstandings, or incomplete answers should be explained accurately where relevant.
What evidence may defend an approved L-1 petition?
Ownership & Control
Corporate registrations, capitalization records, stock certificates, share ledgers, tax records, resolutions, acquisition documents, and financial records can establish the qualifying relationship.
Evidence of Doing Business
Customers, contracts, invoices, bank activity, leases, payroll, employees, products, services, tax filings, licenses, and other records can document ongoing operations.
Organizational Evidence
Organizational charts, employee records, job descriptions, project records, budgets, delegation evidence, calendars, approvals, and management records may document managerial or executive capacity.
Specialized Knowledge Evidence
Training records, proprietary systems, project assignments, internal materials, comparative employee evidence, product documentation, and technical records may demonstrate specialized knowledge.
Prior Qualifying Work
Payroll, tax, HR, employment, organizational, project, travel, and other records may corroborate the beneficiary's qualifying employment abroad.
Correct Disputed Facts
Where USCIS questions a particular statement or document, obtain confirmation from the original company, government registry, accountant, bank, customer, employee, or other reliable source.
Did a change require an amended L petition?
Six principles for responding to an L-1 NOIR.
Identify the Regulatory Ground
Match the allegations to the specific L revocation provision USCIS is using.
Review the Approved Petition
Compare the NOIR with the original I-129, organizational charts, business documents, job descriptions, earlier RFE responses, and approval record.
Reconstruct Corporate Changes
Document ownership, control, mergers, restructuring, acquisitions, office changes, and business developments chronologically.
Prove the Actual L-1 Role
Use evidence of real managerial, executive, or specialized-knowledge work instead of relying only on a title or generalized job description.
Correct Site-Visit Errors
Where USCIS relies on incomplete observations or inaccurate summaries, identify exactly what occurred and support the correction with records.
Build the Appeal Record
A revocation-on-notice decision can be appealed. Submit the strongest factual and documentary rebuttal before the final decision.
The L regulation provides a 30-day rebuttal period.
Use the deadline stated on the actual L-1 NOIR.
The regulation requires the NOIR to provide a detailed statement of the revocation grounds and permits the petitioner to submit rebuttal evidence within 30 days.
A response may require corporate records from several countries, organizational documents, payroll, financial records, contracts, government registrations, declarations, site-visit evidence, and translations.
Begin gathering third-party records immediately and do not assume USCIS will issue another request before deciding whether to revoke.
A revocation on notice is appealable; an automatic revocation is not.
Review the final decision immediately.
The L regulation expressly permits appeal of an individual or blanket petition revoked on notice under the applicable USCIS appeal procedure. Automatic revocations are not appealable.
Current Form I-290B procedures generally provide only 15 calendar days after service of a revocation decision, or 18 calendar days when USCIS mailed the decision, to file the appeal.
The strategy may instead or additionally involve a motion, new L petition, another nonimmigrant classification, or an employment-based immigrant strategy depending on the facts and the beneficiary's status.
L-1 NOIR FAQs
Common questions after USCIS announces that it intends to revoke an approved L petition.