Blanket L: approved once, then straight to the consulate

With a blanket petition, a corporate group has USCIS confirm once that its companies belong together. After that, managers and specialists go straight to the consulate with a single form, no individual petition needed. That saves time, but it shifts the review to the consular officer, and the officer's no is final.

For a group that sends engineers, sales managers and project managers to its American companies every year, the individual L-1 petition is a recurring chore. For every employee, the US company has to prove to the immigration agency USCIS all over again that parent and subsidiary belong together, that both are doing business and that the position meets the requirements. The blanket petition takes this part out of the individual case.

This article from our guide to the L-1 visa explains what the blanket petition approves, which companies can file one, who can be transferred under it, how the Form I-129S process works and when the individual petition remains the better route for a mid-sized company.

1What the blanket petition approves, and what it doesn't

A blanket petition is not a visa for a group of people. It is an ongoing approval for companies. Under 8 CFR 214.2(l)(1), USCIS checks whether the petitioner and the listed parent, subsidiary and affiliate companies and branches are qualifying organizations for L-1 purposes. The I-797 approval notice lists the companies that were recognized.

The employees themselves are not named in the petition. Whether a particular manager or specialist qualifies is decided later by the State Department, usually the consular officer where the employee applies for the visa. INA 214(c)(2)(A) expressly requires that this procedure allow visas to be processed faster. This is exactly where the speed comes from: the USCIS step disappears for each individual employee.

For the employee, the outcome is the same. They get an L-1A or L-1B, with the same maximum stays of seven and five years, with dual intent and with the L-2 for spouses and children. The visa reads "Blanket L-1", and for the family "Blanket L-2".

2Which companies can file one

The requirements are set out in 8 CFR 214.2(l)(4). Three always apply: all included companies are engaged in trade or services, the group has a US office that has been doing business for at least one year, and it has at least three domestic and foreign branches, subsidiaries or affiliates. On top of that comes one of three size thresholds: ten approved L petitions in the past twelve months, combined annual US sales of at least $25 million, or at least 1,000 employees in the USA.

The State Department's Foreign Affairs Manual says openly who this is meant for: relatively large, established companies with multilayered structures and numerous related entities that usually have a set program for rotating staff. The criteria are designed to exclude small businesses and nonprofits. They continue to file individual petitions.

The blanket petition must include every company that wants to transfer employees under it. If a company is added later or an ownership stake changes, you need an amended petition, with a fee. Important for family businesses with a holding company: the relationship between the companies must meet the legal rules for each included company. What counts as a parent, subsidiary or affiliate is explained in the article on L-1 requirements.

3Who can be transferred under it

Only three groups can come to the USA under a blanket petition: managers, executives and so-called specialized knowledge professionals. The third group is narrower than the regular L-1B. It requires specialized knowledge and, in addition, that the employee is a member of a profession as defined in INA 101(a)(32). The law gives architects, engineers, lawyers, physicians, surgeons and teachers as examples. An experienced service technician with deep product knowledge who doesn't belong to one of these professions therefore needs an individual petition, even if the group holds a blanket approval.

The Foreign Affairs Manual also excludes anyone who is to open or work at a new office. Blanket L serves the established office. If you are setting up your first US company, you go the individual petition route.

The familiar one-year rule applies to everyone: within the three years before the visa application, the employee must have worked full time, without interruption, for at least one year at a company listed in the approval notice, as a manager, executive or specialist. There is no shorter period anymore. Until 2004, the law allowed six months for blanket cases; Congress removed this shortcut with Pub. L. 108-447.

4The process with Form I-129S

When one of the listed companies wants to transfer an employee to a US company in the group, it completes Form I-129S, the certificate for the individual employee. Under 8 CFR 214.2(l)(5), it is prepared as an original and three copies. The company keeps one copy; the original and two copies go to the employee, each with a copy of the I-797 blanket approval. USCIS also requires a letter with employment dates, duties, qualifications and salary that documents the year abroad.

With these documents, the employee applies for the visa within six months of the date on the I-129S. At the consulate, they pay the $205 visa fee and, because it is a new I-129S, the $500 fraud prevention fee. Only the principal applicant pays this, not the family. If the employer meets the threshold in Pub. L. 114-113, meaning at least 50 employees in the USA, more than half of them on H-1B or L status, another $4,500 is added. According to the Foreign Affairs Manual, these fees are credited against any reciprocity fee that may be due.

If the employee is already in the USA and is changing to L-1 status, the employer files the I-129S with USCIS together with a Form I-129. The general consulate process, from the DS-160 to the interview, is covered in the article Applying for the L-1.

5What the consular officer checks, and why a no is final

With Blanket L, the real review happens at the consulate. The officer determines whether the US position is with a company listed in the approval notice, whether it is a position for a manager, an executive or a specialized knowledge professional, and whether the year abroad was spent at a listed company in such a role. 8 CFR 214.2(l)(5)(ii)(E) allows the officer to grant the L only in clearly approvable cases.

If a question can't be resolved in the interview, the officer refuses under INA 221(g) and notes "not clearly approvable" on the I-129S. Before that, the Foreign Affairs Manual requires the officer to consider whether the employee qualifies as a manager or as a specialized knowledge professional. The decision is final. The employee may not apply again under the same blanket petition, not even in the other category.

That isn't the end of the road. The employer can file an individual petition for the employee with USCIS. It must state why the consulate refused, which consulate it was and when. Conversely, both procedures may not run at the same time for the same employee unless a consular officer has refused. What to do after a refusal is covered in the article L-1 denied or RFE.

6Validity, extension and revocation of the petition

Under 8 CFR 214.2(l)(7), a blanket petition is initially valid for three years. After that, it can be extended indefinitely if the companies have complied with the rules. To do so, the group files a new Form I-129 with a copy of the previous approval and a report on every employee who entered under it during the three years: position, company, date of first entry and date of final departure. The group also states whether it still meets the requirements.

Miss this extension and the approval lapses automatically, with no appeal. If indefinite validity is denied or not requested, the group must file individual petitions for three years before it can apply for a new blanket petition. USCIS can also revoke the approval if a company no longer qualifies, the rules were violated, or none of the companies used the procedure for three consecutive years.

USCIS figures show that the bar is low for established groups. From 1 October 2025 to 30 June 2026, USCIS received 998 Blanket L petitions. It decided 990 of them and approved 971, which is 98.1 percent. 22.6 percent received an RFE first.

7Blanket or individual petition: what suits mid-sized companies

For many European companies, the question never even comes up. If you have a US subsidiary with twenty employees and send someone over every two years, you won't reach any of the three size thresholds. For you, the individual petition remains the way to go, and it's no disadvantage: with Premium Processing, USCIS decides within 15 business days, and the review sits with the agency, whose decision can be challenged.

For groups with several US entities, their own plants and regular rotation, the math is different. Every individual petition costs the base fee, the Asylum Program Fee and preparation. With blanket approval, that part falls away, and employees take their I-129S straight to the consulate. The price is that the review shifts: the consular officer decides alone, and a refusal can only be cushioned with an individual petition.

Even a group with blanket approval can file an individual petition at any time. That makes sense when an employee's case isn't clear-cut, for example a specialist whose profession doesn't fit neatly into a category. The employer then has to confirm that the employee will not file a blanket application at the consulate. What a posting means beyond the visa, from social security to payroll, is covered in our article on sending employees to the USA.

8The individual employee: stay, transfers, extensions

On entry, CBP notes a stay of up to three years on the I-129S. The employee may stay those three years even if the blanket petition itself expires earlier; in that case the employer must apply for indefinite validity in good time or file an individual petition. Under the Foreign Affairs Manual, on the first application the consular officer sets the I-129S validity at three years from the decision or at the requested end date, whichever comes first.

Within the group, the employee is mobile. They can move to any entity listed in the approval notice without a new review, as long as they do substantially the same work there. If the duties change, a new I-129S is needed, filed with USCIS.

To extend the stay, the employer files a new I-129S with a copy of the previous one, together with the petition extension. The employee must be in the US at the time. Each extension runs for up to two years, up to a total of seven years for managers and executives and five years for specialists. If the employee later only renews the visa with a still valid I-129S, the consular officer doesn't have to review their qualifications again. Details on the maximum duration are in our article L-1 validity and extension.

In short

• The blanket petition approves a group's entities, not individual employees. The consular officer decides how each employee is classified.
• It can be filed by a group with a US office that has been operating for at least one year, at least three affiliated entities and one of the three size thresholds.
• Blanket L only covers managers, executives and specialists who belong to a profession as defined by law, such as engineers, not employees of a new office.
• If the consular officer refuses, that is final. The employer can then file an individual petition with USCIS.
• The petition is initially valid for three years and can then be extended indefinitely if the group has followed the rules.

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