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Pinho Law

H-1B 2026: the $100K fee, wage-weighted lottery, and what it means for Brazilians

The H-1B you remember — random lottery, $780 fee, 85K cap — is gone. The 2026 H-1B is a high-wage product. And the alternative — EB-2 NIW — has never been more attractive for Brazilians.

Reviewed by Dra. Izi Pinho — Florida Bar #126610··7 min read

A September 2025 presidential proclamation plus the USCIS wage-weighted selection rule have fundamentally changed the H-1B economics. For many Brazilians eyeing H-1B as their US entry path, it's time to reassess.

The Sep 2025 proclamation

  • $100K supplemental fee per NEW H-1B worker admitted from abroad or requesting a new visa abroad. Paid by the employer.
  • Applies to new I-129 H-1B petitions filed after Sep 21, 2025 for workers OUTSIDE the US.
  • Does NOT apply to: renewals with same employer, workers already in the US doing change-of-status to H-1B without departing, H-1B1 (Chile/Singapore).
  • Legal challenges in progress; no permanent injunction as of April 2026.

Wage-weighted lottery

Wage LevelRelative wageLottery entries
Level IV (expert)Top 33%4 entries
Level IIINext 33%3
Level IINext 33%2
Level I (entry)Bottom 33%1 entry

Employer cost in 2026

Total for a worker already in the US: $8,700–15,200. Total for a worker IN BRAZIL: $108,700–115,200. The difference is the new $100K proclamation fee.

Why EB-2 NIW became the obvious alternative

DimensionH-1B (2026)EB-2 NIW
Employer requiredYesNo — self-petition
Gov cost~$3.6K emp + $100K if abroad$4,245 (applicant)
Attorney fees$5.5K–9K (emp)$8.5K–14K (applicant)
LotteryYes — wage-weightedNo
Final resultTemp visa 3+3 yrsPermanent green card
Brazil queueNo specific queueCURRENT Apr 2026

When H-1B still works in 2026

  1. Already in US in another status (F-1 OPT, L-1) → change-of-status avoids the $100K.
  2. Senior role paying $200K+ where employer absorbs cost.
  3. No merit-based alternative (no publications/patents for NIW).
  4. Urgent employer need (3–6 months) — H-1B premium + COS faster than NIW I-140.

Frequently asked questions

Is the $100K fee in force?
Yes, since Sep 21, 2025. Litigation ongoing but no permanent injunction as of April 2026.
If I'm in the US on F-1, does the $100K affect me?
No. Internal change-of-status from F-1 OPT to H-1B avoids the fee. This is now the dominant path for US-educated Brazilians.
Does EB-2 NIW work for a recent OPT grad?
It can if the profile justifies it — publications, patents, national-reach work. Dhanasar (2016) has been applied with more flexibility for emerging-field profiles (AI, clean energy, biotech).

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