Major TN Visa Changes: What the June 2025 USCIS Policy Updates Mean for Canadian and Mexican Professionals

June 30, 2025, By Sarah Pelud, Immigration Attorney | Pelud Immigration

Bottom Line: USCIS has significantly tightened TN visa eligibility requirements across multiple professions, particularly for Engineers, Economists, Computer Systems Analysts, Scientific Technicians, and Medical Laboratory Technologists. These changes aim to unify adjudication practices between USCIS and CBP while ensuring TN classifications are used only for their intended purposes.

What Changed and Why It Matters

On June 4, 2025, U.S. Citizenship and Immigration Services (USCIS) issued policy guidance in its Policy Manual regarding TN nonimmigrant visa classification under the United States-Mexico-Canada Agreement (USMCA). The guidance took effect immediately, applying to all petitions and applications filed on or after June 4, 2025. These updates represent the most significant changes to TN visa requirements in years, affecting thousands of Canadian and Mexican professionals working in the United States.

The changes were driven by a need to create consistency between USCIS adjudications (for those applying from within the U.S.) and Customs and Border Protection (CBP) decisions at ports of entry. Previously, applicants could sometimes receive different outcomes depending on whether they applied through USCIS or CBP.

Key Professions Most Affected

Engineers: Degree Requirements Now Strictly Enforced

USCIS now applies a strict four-part test for Engineers: (1) The applicant must hold a bachelor's or licenciatura degree in the engineering field related to the position; (2) Duties must align with engineering tasks per the Occupational Outlook Handbook; (3) The title and actual job duties must reflect true engineering work; and (4) Computer or IT roles are generally excluded unless the degree and tasks are engineering-specific.

What This Means: The days of using generic business or computer science degrees to qualify for TN Engineer status are over. Software engineers must now demonstrate both an engineering degree and engineering-specific duties, not just programming or software development.

Economists: Market Research No Longer Qualifies

The updated guidance makes clear that only roles involving traditional economic analysis, such as forecasting economic trends or conducting supply-and-demand research, qualify. Positions like market research analysts, marketing specialists, and financial analysts do not qualify, even if the job title includes the word "economist."

This change will significantly impact business professionals who previously qualified under the Economist category despite performing market research or financial analysis rather than true economic research.

Scientific Technician/Technologist: Healthcare Roles Excluded

USCIS has clarified that Scientific Technicians must work in direct support of a supervisory professional in one of 10 specified disciplines, and importantly, any role involving patient care is now disqualified. This includes radiologic technologists, sonographers, and any technician assisting physicians in patient-facing settings.

Critical Impact: Healthcare employers who previously used ST/T classification for various medical technician roles must now explore alternative visa options, as only laboratory-based research and engineering support roles remain eligible.

Computer Systems Analyst: Programming Focus Disqualifies

Applicants must have a bachelor's degree or diploma/certificate plus three years' relevant experience, and job duties must focus on systems analysis, not software development or programming. Roles with a primary focus on coding, general IT support, or software development without system analysis duties are no longer covered.

Medical Laboratory Technologist: Patient Care Restrictions

To qualify, applicants must perform scientific lab testing (not direct patient care), have a valid Health Care Worker Certification, and be engaged in diagnostic or treatment-related lab analysis. Only laboratory-based work qualifies under this TN category.

Broader Procedural Changes

Self-Employment Prohibited

The new guidance specifies that self-employment no longer qualifies for TN classification. If a foreign national will be employed by a corporation or entity for which they are the sole or controlling shareholder or owner, that is considered self-employment and not allowed under TN classification.

Education Requirements Stricter

If the professional occupation requires a bachelor's degree, the foreign national must hold the appropriate degree, and experience cannot be substituted for any part of the educational requirement. In the past, employers could combine academic and professional experience to demonstrate equivalent qualifications - this is no longer accepted.

Enhanced Documentation Standards

For degrees earned outside the U.S., Canada, or Mexico, an academic equivalency evaluation is strictly required. The applicant must also document that they meet any licensing requirements that apply to their profession in the state where they will work if they will engage in activities that legally require a license.

What Employers Need to Know

The updated requirements create new compliance challenges for employers:

• Job Description Alignment: Employers must ensure TN professionals work strictly within the scope of approved employment parameters and that job descriptions precisely match USMCA professional categories.

• Support Letter Requirements: Employer support letters must be more detailed and specific, clearly demonstrating how the role fits within the designated professional category.

• Healthcare Industry Impact: Employers in the healthcare industry may need to consider other visas for certain roles previously filled through TN status.

  
  

Strategic Implications for Applicants

For Current TN Holders: Review your current role and qualifications against the new standards. If your position no longer aligns with the updated requirements, consider speaking with an immigration attorney about alternative options before your next renewal.

For New Applicants: Ensure your educational background directly matches your intended role. Generic degrees paired with unrelated job duties are likely to face denial under the new standards.

Documentation Strategy: Emphasize the temporary nature of employment, ensure academic evaluations for foreign degrees, and provide original or certified transcripts.

Looking Forward

These updates aim to unify USCIS and CBP adjudication practices and minimize inconsistent decisions. However, many professionals- especially in IT, healthcare, and general business roles - may now find it harder to qualify under traditional TN categories. While this may create initial challenges, it should ultimately lead to more predictable and consistent adjudications.

Action Steps

1. Review Current Status: If you currently hold TN status, evaluate whether your role still qualifies under the new standards.

2. Document Preparation: Gather enhanced documentation, including academic evaluations for non-North American degrees and detailed job descriptions that clearly match USMCA categories.

3. Legal Consultation: Given the complexity of these changes, consider consulting with an immigration attorney to assess your specific situation and explore alternative visa options if needed.

4. Employer Training: Employers should train HR personnel on the new requirements and update their TN visa procedures accordingly.

   
   

Get Expert Guidance for Your TN Visa

The June 2025 updates have significantly tightened TN visa eligibility across multiple professions. With stricter requirements and enhanced scrutiny, professional guidance is now essential for success. Even minor missteps in documentation or job alignment can lead to costly denials.

Sarah Pelud has been helping Canadian and Mexican professionals secure US work authorization since 2006. Based in Montreal, she specializes in employment-based visas and understands the unique challenges of cross-border immigration.

Contact Pelud Immigration:

• Email: info@peludimmigration.com

• Phone: 450-497-1644

• Website: www.peludimmigration.com

This article provides general information about recent TN visa changes and should not be considered legal advice. Individual circumstances vary, and consultation with a qualified immigration attorney is recommended for specific situations.