Who should care: This update primarily affects Chinese executives and investors applying under H-1B, L-1, EB-1C, and EB-5 categories, as well as their U.S. employers who file petitions on their behalf. Given the complexity of these filings and the increased scrutiny on signatures, understanding the changes is critical to avoid delays.

What changed: USCIS has tightened its signature rules, emphasizing that all petitions must contain original, wet ink signatures by either the petitioner or the applicant, depending on the form. Electronic or stamped signatures that were previously accepted are now subject to stricter review and may trigger Requests for Evidence (RFE) or outright denials. This change stems from updated guidance in the USCIS Policy Manual (Volume 2, Part B, Chapter 3) and 8 CFR §103.2(a)(3), which governs signature requirements.

Attorney Insight
From our experience, this change has already caused several H-1B petitions to be returned or delayed. For example, last month, a fintech client’s L-1B extension was delayed because the petition contained a scanned signature instead of an original signature by the employer’s authorized signatory. This delay impacted the employee’s ability to maintain continuous status and required expedited correction.

Step-by-step action plan:

  1. 1Immediately audit all ongoing and upcoming petition filings (I-129 for H-1B/L-1, I-140 for EB-1C, I-526 for EB-5) to confirm that all required signatures are original and wet ink. Digital signatures should be avoided unless explicitly permitted by USCIS.
  2. 2Coordinate with HR and legal teams to update internal procedures ensuring that the authorized signatory physically signs all petitions before submission. For remote or international filings, plan for courier or in-person signing well in advance.
  3. 3For petitions already filed with questionable signatures, proactively prepare to respond to RFEs by obtaining corrected signatures or affidavits explaining the signature method.

For Chinese corporate executives applying for L-1 or EB-1C, this means you should confirm that your U.S. subsidiary’s authorized signatory signs all petitions in original ink. Similarly, EB-5 investors need to verify that their project developers and attorneys comply with these requirements to avoid processing delays.

We also recommend that petitioners maintain a clear signature log and retain copies of the signed documents with dates and names, as USCIS may request evidence of authenticity.

Attorney Insight
In conclusion, while this change adds a procedural hurdle, it is manageable with proper preparation. We suggest clients treat signature compliance as a critical checkpoint in petition preparation to minimize risk. Our firm is updating all client intake protocols accordingly and offering signature compliance audits to help you stay ahead.

What this means for you: Review your current filings immediately, ensure original signatures on all USCIS forms, and adjust your internal processes to prevent avoidable delays or denials under the new USCIS signature policy.