Reset Green-Card Calendar: Nov 2025 PERM Line

Your green-card calendar needs one deadline first: as of Aug. 31, 2026, DOL’s Office of Foreign Labor Certification was still working through PERM filings from November 2025 or earlier. For PERM determinations completed in August 2026, the average Analyst Review time ran 336 calendar days, 36 days under July 2026’s 372-day figure. The planning question is which filing month the queue has not yet reached, not how fast last month’s cases closed.

The queue line drives the hire date

The average describes completed cases in a reporting month. The filing-month line shows where the active queue sits. For a sponsored hire, the second number moves the green-card date. If the line has not reached the hire’s PERM filing month, the case is still waiting for its turn, even when the average looks shorter. That distinction matters when you are setting expectations with a manager, a candidate, or an immigration team already juggling extensions and approvals.

Processing times behave like three moving lines. One tracks completed determinations. Another tracks the filing month still being worked. A third tracks the prevailing wage request that must clear before the labor certification can be filed. The calendar needs all three visible, because a hire can look safe on one line and exposed on another.

Build the checklist around the queue line

• Write the current filing-month line at the top of each sponsored-hire record, next to the hire’s PERM filing date. The record needs a visible field for the current line.
• Compare each hire’s PERM filing date to that line. If the filing date is after the line, mark the case as behind the active queue. The status can be in queue, behind queue, or cleared.
• Add the prevailing wage lead time before the PERM filing date. At the same Aug. 31, 2026 data point, the National Prevailing Wage Center was still working PWD requests from May 2026 or earlier, covering H-1B and PERM OEWS and Non-OEWS cases. That cohort carried an estimated 3-4 month wait in the same data set. The hire plan carries a PWD target date that lands before the PERM filing date, with the buffer written in.
• Remove premium-processing assumptions from the plan. DOL had no premium-processing lane for PERM labor certification or for PWD requests. The plan cannot depend on a faster lane that is not available.
• Track reconsideration appeals separately if a denial goes to reconsideration. The PERM reconsideration queue in the same data set still showed appeals filed in April 2026 or earlier under review. The appeal gets its own line item, with its own status date and no assumption that it will move on the main certification clock.

Give the calendar a monthly owner

Assign one owner to the green-card calendar, even if the team is small. That owner reviews the queue line, the wage target, and the labor-certification filing date on the same day each month. The review produces three outputs: a revised expected date, a risk note, and a next action. When a hire moves from behind the queue to inside the queue, the calendar shows the change without rewriting the whole plan. When a wage target slips, the labor-certification filing date moves first, not the candidate’s start date.

When a manager asks for a date, give the range and the reason for the range. Keep the calendar short enough to read in a meeting, but specific enough to survive an audit.

Keep proposed changes off the plan

H.R. 10051 proposed an optional, employer-paid 30-day PERM processing track, but it is not a planning tool until published rules exist. Do not count on speed from a bill that has not become an available service. If leadership asks whether a hire can be rushed, the answer should come from the current queue line and the current wage lead time, not from a future option. That keeps the plan defensible when the question moves from immigration to business operations.