Blanket L Petition and Intracompany Transfer Process

The procedure allows USCIS to approve the qualifying organizational group in advance.

Individual beneficiaries are not named in the blanket petition itself.

A blanket L petition allows a qualifying corporate group to obtain continuing USCIS approval of listed parent, branch, subsidiary, and affiliate entities for use in later L-1 transfers. The blanket petition is an organizational approval rather than an individual worker petition. Its principal benefit is procedural efficiency for qualifying multinational groups that regularly transfer managers, executives, and certain specialized knowledge professionals. Approval does not eliminate the substantive L-1 requirements. The corporate group must continue to satisfy the blanket criteria, and each later beneficiary must still qualify for the requested L classification and be transferred between qualifying organizations covered by the blanket approval.

The consular or other adjudicating officer still determines whether the beneficiary satisfies the managerial, executive, or specialized knowledge professional standard and the qualifying foreign employment requirement.

Blanket approval does not preapprove a particular employee's eligibility. The individual case must still establish the beneficiary's qualifying employment abroad, the qualifying relationship to the proposed US employer, and the required managerial, executive, or specialized knowledge professional role. A company should therefore maintain two distinct evidentiary layers: the blanket approval and entity list, and the beneficiary-specific evidence. If the worker or employing entity falls outside the approved blanket framework, or if the individual does not meet the blanket beneficiary requirements, the organization may need to use the ordinary individual L petition process instead.

Managers and executives can use the blanket process.

An L-1B blanket beneficiary must be a specialized knowledge professional, not merely an employee who possesses specialized knowledge.

The blanket process can be used for qualifying managers and executives and for specialized knowledge employees who meet the professional requirement applicable to blanket L-1B classification. The company should identify the requested category precisely and document the worker's education, experience, foreign employment, and proposed US duties accordingly. A broad statement that the worker is important to the company is not enough. L-1A cases should establish managerial or executive capacity, while blanket L-1B cases should establish the claimed specialized knowledge and the beneficiary's professional qualifications under the rules that apply to the blanket process.

The State Department's current guidance expressly limits blanket beneficiaries to established U.S. offices.

New office transfers require individual petition procedures.

A company cannot obtain blanket approval merely because it belongs to a multinational group. USCIS requires the petitioner to have a US office that has been doing business for at least one year, at least three domestic and foreign branches, subsidiaries, or affiliates, and qualifying commercial activity among the listed entities. In addition, the petitioner and other qualifying organizations must satisfy at least one scale threshold: the required number of recent L approvals, qualifying combined US sales, or the required US workforce. Ownership, control, commercial operations, and the selected numerical or financial threshold should be documented with objective records.

The beneficiary uses Form I-129S together with the Blanket L approval record and required visa or admission documentation.

The adjudicating officer examines the beneficiary's individual eligibility.

Once USCIS approves the blanket petition, the beneficiary-specific procedure depends on where the worker is applying. Current Form I-129S instructions provide the individual blanket classification process for qualifying beneficiaries abroad and require Form I-129S with Form I-129 when a petitioner requests a change of status or extension of stay for a beneficiary in the United States. Consular or port procedures still require the worker to establish individual eligibility. The employer should use the current approved blanket notice and current forms and should confirm that both the foreign and US employing entities are included in the approved blanket framework before proceeding.

• Blanket approval notice
• Form I-129S
• Qualifying entity evidence
• Foreign employment evidence
• Job duties
• Managerial or executive evidence
• Professional evidence for L-1B
• Specialized knowledge evidence

A strong blanket filing should make the corporate group easy to verify. Evidence can include organization charts, formation records, ownership and control documents, lists of qualifying entities, proof of commercial trade or services, US operating records, and documentation showing that the petitioner satisfies the applicable recent L approval, annual sales, or US workforce threshold. Later beneficiary filings should add the worker-specific foreign employment, position, duties, qualifications, and employing entity evidence. Changes in approved relationships or additional qualifying organizations may require an amended blanket filing, so the company should maintain current corporate records after approval.