Tighten PERM and H-1B Controls After the Cognizant and Cloudera Freeze

The freeze is the trigger, not the headline.

If you sponsor PERM or H-1B cases, the Cognizant and Cloudera freeze is a signal to check your own filing lanes now. The Department of Labor suspended permanent labor certification filings by Cognizant and Cloudera. DOL Inspector General Anthony D'Esposito announced the suspension on September 8, 2026. A major Trump administration investigation into alleged H-1B and PERM employment visa fraud began in July. The investigation into the two companies was run in coordination with the White House Fraud Task Force and other officials.

Only Cognizant’s new PERM filings are affected, while its prior approvals and H-1B program remain unsuspended. Cognizant cannot file new PERM applications until DOL completes its investigation into alleged fraud involving its H-1B and PERM programs. For sponsors, the useful question is which filings are frozen and which are still moving. The answer changes the response: a paused PERM lane is not the same as a paused H-1B lane, and a prior approval is not a pass for the next filing.

During the first three quarters of FY26, 104,028 permanent labor certifications were issued, and the Professional, Scientific and Technical Services sector received 28,425, equal to 27.3 percent. If your business sits in that sector, a suspension becomes a pipeline problem. The practical risk is not only a stopped case; it is a backlog of weak evidence that becomes harder to fix after the agency starts asking questions.

Scope comes before evidence.

Separate the cases that are stopped from the cases that can continue. A suspension does not automatically erase a prior approval, and it does not automatically stop every related petition. The sponsor's job is to prove the boundary. Keep a simple table with the case type, filing date, entity, worker, and next action. The table should answer: if the agency pauses a new filing today, which cases are affected, and who owns the response?

Map the evidence that supports each case. The strongest file can be read by a stranger. It should show the role, business need, wage, recruitment, and employer ability to pay. If a document is missing, put the gap in the table and assign a fix date. A file that depends on a single person's memory is a gap, even if the case was approved before.

Build the evidence file before the agency asks for it.

• Inventory every PERM and H-1B case that touches the same roles, worksites, recruiters, or payroll entities. Maintain a register with the case number, worker, employer entity, filing date, status, and the person who owns the evidence. The register should be current enough that a new hire could find the file quickly.
• Freeze new PERM filings that depend on unverified job orders, wage data, or recruiter promises. Put a hold flag in your tracking system and a written reason for the hold. The common mistake is treating a prior approval as a shield for a new filing. A prior approval proves a case was approved; it does not prove the next case is clean.
• Rebuild the PERM evidence file as if the agency will request it tomorrow. Keep a folder per case with the job description, business need memo, recruitment record, wage source, and proof that the employer can pay the proffered wage. Organize it in the order a reviewer would ask for it, not the order the case team happened to save it.
• Tighten H-1B controls where PERM risk is highest. Use a written attestation that the worker will perform the duties listed in the petition, at the worksite listed, for the period listed. Put a checkpoint before any transfer, new worksite, or change in duties, signed by the mobility manager and the hiring manager.
• Document the business need in plain language. The memo should explain why the role exists, why it cannot be filled with a worker who is already eligible to work here, and why the wage is supported. Avoid boilerplate. Name the project, client or internal unit, skill set, and reason the employer needs the role now.
• Rehearse the suspension response. Keep a short plan that says who pauses filings, who notifies counsel, and which cases get a hold. Run the drill regularly. End it with a list of open gaps and a date for each fix.

Every filing should carry a short certification that the facts in the petition match the facts in the business. If the business changes, the file changes. If the file cannot keep up, pause the filing. That keeps the sponsor from adding a weak case to a growing audit trail.