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A rapidly shifting landscape of humanitarian protections presents ongoing compliance challenges for employers. As the latest example, the Department of Homeland Security (DHS) recently announced the termination of Temporary Protected Status (TPS) for nationals of Haiti, Burma (Myanmar), and South Sudan while a federal court has temporarily blocked the termination of TPS for Syria.
TPS Terminations: Haiti, Burma (Myanmar), South Sudan
Haiti
Back in July, we covered litigation developments from a US District Court decision that extended TPS for Haiti until February 2026.
On November 26, 2025, DHS published a notice ending TPS for Haiti. At the time of writing, the official Federal Register has not been published yet, but the termination is set to take effect on February 3, 2026. The termination will affect around 330,000 nationals from Haiti.
Burma (Myanmar)
On November 25, 2025, DHS published a notice ending TPS for Burma. The termination will take effect on January 26, 2026, and will affect nearly 4,000 nationals from Burma who were granted TPS after the military coup in 2021.
South Sudan
On November 5, 2025, DHS published a notice ending TPS for South Sudan. The termination will take effect on January 5, 2026.
Possible Termination of Somalia
On November 21, 2025, President Trump announced that he intends to end TPS for Somalia. At the time of writing, no official notice from DHS has been released. We will continue to monitor for official updates from DHS.
Please reference the table below to track the upcoming work authorization expiration dates for each TPS-designated country:
| Country | Date Work Authorization Expires |
| South Sudan | January 5, 2026 |
| Burma (Myanmar) | January 26, 2026 |
| Haiti | February 3, 2026 |
Litigation Halts Termination: Syria
Back in October, we covered the announcement of the termination of TPS for nationals from Syria. The Federal Register notice scheduled the termination to take effect on November 21, 2025, citing national security concerns as the basis for the decision. The decision would have affected nearly 4,000 Syrian nationals. However, on November 19, 2025, a judge in the Southern District of New York issued an order staying the termination of Syria TPS. We will update as the litigation develops.
Employer Considerations
Employers should be aware that affected TPS holders will lose both protected status and their work authorization unless they have transitioned to another lawful immigration status. This could result in the loss of employees who rely on TPS-based work authorization.
Employer Next Steps
Continued Form I-9 Compliance: Employees with TPS may have Employment Authorization Documents (EADs) that expire when their TPS ends. Employers should review and track card expiration dates for the TPS (A12 or C19) designations, follow reverification procedures, and closely monitor updates from DHS.
ICE I-9 Inspections: Employers may face increased scrutiny from Immigration and Customs Enforcement during I-9 inspections if their records are not updated timely, or if individuals without valid work authorization maintain employment.
Ongoing Communication: Employers should be prepared to address questions from affected employees and provide resources for legal counsel.
Stay Informed: Monitor updates from DHS and follow our blog for updates.
We'll continue to monitor these developments and provide updates as they become available. If you have questions about how these updates may affect your workforce or what steps you should take, please don't hesitate to reach out.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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