For employers and foreign national employees navigating the employment-based green card process, PERM processing times have become one of the most important timeline variables. Over the last several years, PERM delays have stretched longer than many employers expected, creating uncertainty around work authorization, retention planning, priority dates, and overall green card strategy.
There is now a cautiously positive development: recent Department of Labor data suggests that some PERM-related queues are moving faster than they were earlier in 2026. But the improvement is uneven, and it may be too early to treat it as a durable trend.
As of May 31, 2026, the Department of Labor was conducting analyst review for PERM applications filed in April 2025 or earlier, audit review for applications filed in November 2025 or earlier, and reconsideration requests filed in January 2026 or earlier. The agency also reported that the average processing time for PERM analyst review determinations issued in March 2026 was 501 calendar days, while audit review averaged 343 calendar days.
Those numbers tell two different stories at once. On one hand, the queue appears to have advanced meaningfully compared with earlier 2026 reports. In January 2026, DOL was reviewing analyst cases filed in August 2024 or earlier and audit cases filed in December 2024 or earlier. By late May 2026, analyst review had advanced to April 2025, and audit review had advanced to November 2025. On the other hand, an average analyst review time of 501 days remains very long by historical expectations and continues to require careful planning.
So the question is not simply whether PERM processing times have improved. The more practical question is whether employers and employees can rely on that improvement going forward.
Why PERM Processing Times Matter So Much
PERM, formally known as Program Electronic Review Management, is the labor certification process administered by the Department of Labor for many employment-based green card cases, especially EB-2 and EB-3 cases that do not qualify for a PERM exemption. Before an employer can file the immigrant petition with U.S. Citizenship and Immigration Services, the employer generally must first obtain a certified PERM labor certification from DOL.
That labor certification is meant to show that there are not sufficient able, willing, qualified, and available U.S. workers for the offered position, and that employing the foreign worker will not adversely affect the wages and working conditions of similarly employed U.S. workers.
Because PERM comes before the I-140 immigrant petition, delays at the PERM stage can delay the entire green card case. For employees approaching the end of their H-1B time, PERM timing can also become critical for extension strategy. For employers, delayed PERM adjudications can affect workforce planning, promotion timing, relocation decisions, and long-term retention.
A PERM case also involves more than just the final ETA Form 9089 filing. In a typical case, the employer must first obtain a prevailing wage determination, complete a recruitment process, observe required waiting periods, prepare documentation, and then file the PERM application. If the case is audited, the timeline can expand substantially.
That is why even modest changes in DOL processing speed can have a major practical impact.
What the Latest Data Shows
The latest available DOL processing update shows several important data points.
First, DOL’s PERM analyst review queue has advanced to applications filed in April 2025 or earlier, as of May 31, 2026. This is significant because earlier in the year, DOL was still reporting analyst review for applications filed in August 2024 or earlier.
Second, the audit review queue has advanced to applications filed in November 2025 or earlier. This is also notable because audit review was at December 2024 or earlier in January 2026.
Third, reconsideration requests to the Certifying Officer are being reviewed for cases appealed in January 2026 or earlier.
Fourth, DOL’s reported average processing times remain substantial. For determinations issued in March 2026, analyst review averaged 501 calendar days, while audit review averaged 343 calendar days. DOL cautions that actual processing times may vary depending on the facts and circumstances of each case.
Finally, prevailing wage determinations appear to have improved compared with earlier 2026 reporting. Fragomen’s summary of the May/June 2026 DOL update states that, as of June 8, 2026, DOL was issuing PERM and H-1B prevailing wage determinations for requests filed in March 2026 for both OEWS-based and non-OEWS requests. By comparison, in January 2026, DOL was issuing prevailing wage determinations for OEWS requests filed in August 2025 and non-OEWS requests filed in June 2025.
Taken together, these updates suggest forward movement across multiple parts of the process. But they do not necessarily mean that PERM processing has returned to a predictable or short timeline.
The Improvement Is Real, But It Needs Context
The clearest improvement is in the movement of the queue dates. When a processing queue advances by several filing months over a shorter period, that can indicate that the agency is working through older inventory more efficiently. For employers with cases filed in late 2024 or early 2025, the recent movement may be encouraging.
However, processing queue dates and average calendar days are not the same thing. A queue date tells stakeholders which filing month DOL is currently adjudicating. Average processing days reflect how long recently completed cases took to reach determination. Both numbers matter, but they measure different things.
For example, if DOL is now reviewing April 2025 filings, that does not mean a case filed today will necessarily be decided in the same number of months that it took the queue to move from August 2024 to April 2025. Future processing depends on incoming case volume, staffing, audit rates, system changes, policy developments, federal funding conditions, and the complexity of pending cases.
The average analyst review figure of 501 calendar days also remains a warning sign. Even if the queue is moving, many employers and employees are still looking at a PERM stage that can exceed a year before accounting for prevailing wage, recruitment, I-140 processing, and adjustment of status or consular processing.
The better interpretation is this: the latest data shows progress, not normalcy.
Why Processing Times May Be Improving
There are several possible explanations for the recent improvement, though DOL’s public processing-time page does not provide a full operational explanation.
One possibility is that DOL has increased adjudicatory throughput after a period of slower processing. Agencies sometimes move through backlogs more quickly when staffing, workflow, technology, or prioritization improves.
Another possibility is that the distribution of pending cases has changed. If DOL resolves a cluster of older or more complex cases, the queue date can appear to move more quickly. But that does not always mean the entire system is permanently faster.
A third possibility is that prevailing wage processing improvements may be helping the front end of the PERM pipeline. If prevailing wage determinations are being issued more promptly, employers can move more efficiently into recruitment and PERM filing. Fragomen’s May/June 2026 update indicates that DOL was issuing PERM and H-1B prevailing wage determinations for March 2026 requests as of June 8, 2026, a notable improvement from the January 2026 reported PWD months.
However, improved PWD timing can also produce a future wave of PERM filings. If more employers receive prevailing wage determinations within a shorter period, more recruitment cycles may begin, and more PERM filings may enter the system in the following months. That could eventually increase pressure on the PERM adjudication queue.
In other words, faster processing at one stage may relieve immediate pain but could also shift volume downstream.
Why the Improvement May Not Last
The main reason to be cautious is that PERM processing times are highly sensitive to volume. Demand for employment-based green cards remains strong, and PERM is a required step for many employer-sponsored EB-2 and EB-3 cases. If filing volume stays high or increases, recent gains may slow.
Another concern is audits. A PERM audit can significantly change the timeline for a case. DOL’s latest data shows audit review averaging 343 calendar days for determinations issued in March 2026. While that figure is lower than the analyst review average reported for the same month, an audit still adds uncertainty, requires a complete and timely response, and can complicate planning.
Processing times may also fluctuate because DOL’s own reporting methodology excludes certain withdrawn, rejected, voided, or otherwise excluded matters depending on the category. DOL notes that excluded cases may cause numbers for previous months to fluctuate. That means stakeholders should be careful about over-reading any single monthly update.
Government operations can also affect timing. Budget issues, staffing changes, policy shifts, system outages, and administrative priorities can all influence adjudication speed. PERM is not a premium processing system; employers cannot pay DOL to expedite a standard PERM labor certification adjudication. That makes proactive planning even more important.
What Employers Should Do Now
Employers should treat the latest improvement as an opportunity to plan more strategically, not as a reason to relax.
The first step is to start PERM strategy early. For employees in H-1B status, timing is especially important because PERM filing and I-140 approval can affect long-term H-1B extension eligibility. Waiting until the employee is close to the end of the six-year H-1B period can create avoidable risk.
Second, employers should build conservative timelines. Even with signs of improvement, a PERM case can still take many months before filing and more than a year for adjudication. A realistic timeline should include prevailing wage processing, recruitment preparation, the recruitment period, the mandatory quiet period after recruitment, application preparation, DOL review, and possible audit response.
Third, employers should review job descriptions carefully before the prevailing wage request is filed. A vague, inconsistent, or poorly structured job description can create issues later in the process. The job requirements must be aligned with business necessity, minimum requirements, and the employee’s qualifications. Once the PERM process begins, changes to the position can require restarting or modifying the strategy.
Fourth, employers should maintain strong recruitment documentation. If a case is audited, the employer must be able to produce evidence that the required recruitment steps were completed properly and that U.S. applicants were evaluated in compliance with PERM rules. Documentation discipline is essential.
Fifth, employers should monitor visa bulletin issues separately from PERM timing. PERM certification is only one part of the green card process. Even after PERM approval and I-140 filing, the employee may still face immigrant visa backlogs depending on country of chargeability and preference category.
What Employees Should Understand
Foreign national employees should understand that PERM is an employer-driven process. The employer sponsors the position, controls the recruitment process, and files the labor certification. Employees can support the process by providing accurate background information, education documents, experience letters, and timely responses, but they do not file the PERM application themselves.
Employees should also understand that PERM timing can affect career planning. Promotions, role changes, worksite changes, and major job duty changes may affect a PERM case depending on where the case is in the process. A role that changes significantly after the process begins may no longer match the sponsored position.
This does not mean employees should avoid career growth. It means employers and employees should communicate before making major changes. Immigration counsel can help determine whether a change affects the existing PERM strategy or whether a new process is needed.
Employees approaching the end of H-1B time should also pay attention to the timing of PERM filing and I-140 approval. Depending on the circumstances, certain H-1B extensions beyond the normal six-year limit may be available, but those options are timing-sensitive and should be assessed early.
The Prevailing Wage Piece Is Especially Important
The prevailing wage determination is one of the most important early steps in the PERM process. DOL uses the prevailing wage determination to establish the minimum wage that must be offered for the sponsored position. Employers generally should not begin recruitment until the prevailing wage and job requirements have been carefully reviewed, because recruitment must align with the sponsored position and wage strategy.
The apparent improvement in prevailing wage processing is therefore significant. As noted above, by June 2026 DOL was reportedly issuing PERM and H-1B prevailing wage determinations for March 2026 requests, whereas in January 2026 the agency was working on much older PWD requests.
If that improvement continues, it may reduce the front-end delay in PERM cases. But employers should be cautious. Faster PWD issuance does not guarantee faster PERM adjudication after filing. It may simply move cases into the recruitment and filing pipeline more quickly.
For workforce planning, this means employers should not look at the PERM analyst review date alone. They should track PWD timing, recruitment timing, PERM filing timing, audit risk, I-140 strategy, and visa bulletin availability as part of one integrated plan.
Audits Remain a Major Timeline Risk
Even when analyst review improves, audits can disrupt expected timelines. A PERM audit may be random or may be triggered by case-specific factors. The employer must respond with required documentation, often including recruitment records, resumes received, lawful rejection reasons, business necessity documentation, and proof of compliance with posting and notice requirements.
The latest DOL data shows audit review for November 2025 or earlier as of May 31, 2026. That is a positive movement from the January 2026 report, when audit review was at December 2024 or earlier. Still, an audited case remains meaningfully less predictable than a case certified through standard analyst review.
Employers should prepare every PERM case as if it could be audited. That means keeping complete records from the beginning, not trying to reconstruct documents months later. It also means ensuring that recruitment steps are not only completed, but completed correctly.
Small mistakes can become large problems in PERM. Incorrect posting dates, inconsistent job requirements, inadequate recruitment documentation, or poorly explained applicant rejections can all create risk.
Practical Timeline Expectations for 2026
Based on the latest public information, employers should still assume PERM will be a long process. The improvement in queue movement is encouraging, but the reported average analyst review time of 501 calendar days remains significant.
A conservative PERM timeline in 2026 should often account for:
- Prevailing wage preparation and filing;
- Prevailing wage determination processing;
- Recruitment preparation;
- Mandatory recruitment steps;
- The required post-recruitment waiting period;
- PERM application preparation and filing;
- DOL analyst review;
- Possible audit and audit review;
- I-140 preparation and filing after PERM certification; and
- Adjustment of status or consular processing when the priority date is current.
For some cases, the overall process from PERM initiation to green card filing eligibility can be much longer than the PERM adjudication number alone suggests.
Employers should therefore avoid using a single processing-time figure as the entire timeline. The PERM filing date, priority date, employee status expiration date, and visa bulletin category all matter.
Will the Improvement Last?
The honest answer is: it is too early to know.
The latest DOL data shows real progress in the queue dates, especially compared with January 2026. Analyst review moved from August 2024 filings to April 2025 filings, and audit review moved from December 2024 filings to November 2025 filings. That is encouraging.
But the average analyst review time remains over 500 days, and DOL expressly cautions that actual case processing times may vary based on case-specific facts and circumstances. In addition, PERM demand, audit volume, agency resources, and downstream filing patterns could all affect whether this progress continues.
The best approach is cautious optimism. Employers should recognize the improvement, but they should not build immigration strategy around an assumption that processing times will continue to accelerate.
Key Takeaways
PERM processing times appear to be showing signs of improvement, particularly when comparing current queue dates to those reported earlier in 2026. DOL is now reviewing analyst cases filed in April 2025 or earlier and audit cases filed in November 2025 or earlier, as of May 31, 2026.
Prevailing wage processing also appears to have improved, with March 2026 PWD requests reportedly being issued as of early June 2026.
However, the PERM process remains lengthy. DOL’s reported average analyst review time for March 2026 determinations was 501 calendar days. That means employers and employees should continue to plan early, document carefully, and prepare for possible delays.
The recent improvement is good news. But whether it will last depends on whether DOL can sustain faster adjudication while managing new filing volume, audits, and operational demands.
For now, PERM planning should remain conservative, proactive, and closely monitored. In employment-based immigration, timing is often strategy. The employers and employees who start early and prepare thoroughly will be best positioned if processing times improve — and better protected if they do not.