FY2026 Q1 LCA Data: Shutdown Cuts Certifications 25%, While Wages and AI/ML Roles Signal Structural Shift
The October 2025 government shutdown zeroed out a month of DOL processing, pulling FY2026 Q1 certified H-1B filings down ~25% to 71,782. Beneath the decline, structural trends accelerated: median wages reached $131K, AI/ML roles nearly doubled, and $200K+ filings hit 12.6% of certifications. Threshold's five-year analysis of DOL OFLC disclosure data.
By Kevin Cole •
The Department of Labor has released FY2026 Q1 LCA disclosure data covering decisions made between October and December 2025, the first quarterly release following the 2025 government shutdown that closed DOL’s FLAG system through most of October. This analysis covers H-1B LCA filings (excluding H-1B1 and E-3 categories), with four years of historical comparisons across the full FY2022–FY2026 Q1 series.
The headline number: FY2026 Q1 certifications fell roughly 25% to 71,782, down from 95,775 in FY2025 Q1. The decline is entirely attributable to DOL’s processing gap: the October shutdown zeroed out a full month of certifications, with DOL producing just 103 October decisions versus approximately 35,700 in FY2025’s October.
To enable a multi-year trend analysis, this report uses the November–December window to compare compositional shifts across five fiscal years. Beneath the volume disruption, structural trends continued: the median offered wage rose to $130,707, AI/ML roles nearly doubled, $200K+ filings reached 12.6% of certifications, and the top-10 employer list diversified across tech, consulting, and outsourcing companies.
1. Volume: Q1 certifications down ~25% after October shutdown
FY2026 Q1 produced 79,852 total filings and 71,782 certifications, down from 95,775 certifications in FY2025 Q1. The cause is straightforward: the government shutdown beginning October 1, 2025 shuttered DOL’s FLAG system for the entire month (restored October 31), producing just 103 October decisions and zero certifications (78 Certified-Withdrawn, 25 Withdrawn) versus approximately 35,700 October certifications in FY2025.
For compositional trend analysis across the five-year window, November–December provides a more consistent basis. However, as the weekly data below demonstrates, even this comparison overstates FY2026 demand due to backlog processing in November.
| Fiscal Year (Q1) | Nov–Dec Total | Nov–Dec Certified | YoY Change (Certified) |
|---|---|---|---|
| FY2022 | 77,156 | 69,947 | — |
| FY2023 | 62,341 | 55,803 | −20% |
| FY2024 | 55,786 | 49,953 | −10% |
| FY2025 | 65,034 | 60,038 | +20% |
| FY2026 | 79,745 | 71,782 | +20% |
Within the Nov–Dec window, FY2026’s 71,782 certifications are the highest in the five-year series, surpassing FY2022’s previous peak of 69,947. However, as a measure of full-quarter volume, FY2026’s 71,782 certifications place it well below every other year, reflecting the complete loss of October processing.
Weekly data sharpens the picture.
When FLAG reopened on October 31, DOL faced a month of pent-up applications. The effect on November was immediate: certified filings in the week of November 10 hit 13,867, more than double the corresponding FY2025 week (5,453) and the single highest weekly total in either year’s Q1 window. By the final week of November, the year-over-year gap had narrowed to 20%. By December, it had closed entirely. Across five December weeks, FY2026 produced 30,305 certified filings versus FY2025’s 32,484, a 7% year-over-year decline.
This pattern is consistent with backlog clearing, not a demand surge. Employers and attorneys who would have filed in October were forced to wait, and DOL processed a compressed queue once FLAG came back online. The November surplus of approximately 13,900 additional certifications over FY2025 accounts for roughly 39% of a normal October’s output, a plausible fraction given that some displaced applications were likely deferred beyond Q1 or abandoned due to the shutdown and lack of access to FLAG. Once the backlog cleared, the weekly run rate settled back to FY2025 levels.
Part of the longer-term pattern is structural. USCIS’s January 2025 shift to beneficiary-centric lottery selection eliminated mass duplicate registrations: average registrations per beneficiary fell from 1.70 in FY2024 to 1.06 in FY2025. Total cap registrations dropped roughly 38%, and first-round selection rates improved from approximately 15% to 26%. Nov–Dec certified filings declined from FY2022’s 69,947 through FY2024’s trough of 49,953, reflecting both the registration cleanup and broader market conditions. The FY2025-to-FY2026 recovery confirms that underlying demand has rebounded above the trough.
2. Wages have climbed 17% in four years, reaching $130,707
The median offered wage for Nov–Dec certified H-1B filings has risen every year in the five-year series:
| Fiscal Year (Q1) | Median Offered Wage | P25 | P75 | P90 | Count* |
|---|---|---|---|---|---|
| FY2022 | $111,301 | $88,608 | $143,042 | $175,000 | 69,623 |
| FY2023 | $117,915 | $94,402 | $152,100 | $189,140 | 110,481 |
| FY2024 | $122,009 | $96,239 | $158,581 | $194,986 | 49,716 |
| FY2025 | $130,000 | $102,000 | $165,000 | $201,100 | 58,340 |
| FY2026 | $130,707 | $102,000 | $166,800 | $209,957 | 71,345 |
*Count reflects certified filings with annual wage data between $15K and $1M; differs slightly from total certified counts in the volume table above.
All wage figures in this analysis are nominal. Adjusted for inflation (CPI-U rose 16.4% over the same period), real median wage growth is approximately 1%. In practical terms, H-1B wages have kept pace with inflation but have not meaningfully outrun it.
The full FY2026 Q1 wage distribution (all certified, $15K–$1M):
| Percentile | Wage |
|---|---|
| P10 | $80,704 |
| P25 | $102,000 |
| Median | $130,707 |
| P75 | $166,800 |
| P90 | $209,957 |
The P25 has held at $102,000 for two consecutive years. The P90 has expanded from $175,000 in FY2022 to $209,957 in FY2026, a roughly $35,000 widening concentrated at the top of the distribution. Top-of-distribution wages are growing faster than bottom-of-distribution wages.
3. 12.6% of filings now offer $200K+
One in eight certified H-1B filings this quarter offered a base salary of $200,000 or more. The share has nearly tripled since FY2022:
| Fiscal Year (Q1) | Filings $200K+ | Share of Certified |
|---|---|---|
| FY2022 | 3,202 | 4.6% |
| FY2023 | 8,133 | 7.4% |
| FY2024 | 4,456 | 9.0% |
| FY2025 | 6,282 | 10.8% |
| FY2026 | 8,966 | 12.6% |
The share has risen in every year, including FY2024 when overall volume declined. The $200K+ segment is structurally growing as a proportion of the program, not tracking total volume.
In absolute terms, $200K+ filings grew 43% year-over-year (6,282 to 8,966) while total certifications grew 20%. The high-wage segment is expanding faster than the overall market.
The weighted H-1B lottery assigns Level IV positions 4x lottery entries and Level III positions 3x. It was published as a final rule December 23, 2025, effective for the FY2027 cap season. Although employers were likely aware of the proposed rule (published September 24, 2025) during the filing period, LCA data does not enable us to distinguish between anticipatory behavior and the multi-year structural shift toward higher-wage positions.
4. AI/ML roles: four years of accelerating share, now at 991 filings
Job titles containing “Machine Learning,” “AI,” “Deep Learning,” “LLM,” or “Generative” now account for 1.38% of all certified filings: 991 filings, nearly double the 506 recorded in FY2025 Q1. There’s a clear longer trend visible across the full five-year window: AI/ML’s share of H-1B LCA filings has grown in four of five years since FY2022, rising from 0.40% to 1.38% even as overall volume fluctuated.
| Fiscal Year (Q1) | AI/ML Filings | Share of Certified | Total Certified |
|---|---|---|---|
| FY2022 | 277 | 0.40% | 69,947 |
| FY2023 | 581 | 1.04% | 55,803 |
| FY2024 | 324 | 0.65% | 49,953 |
| FY2025 | 506 | 0.84% | 60,038 |
| FY2026 | 991 | 1.38% | 71,782 |
The share dipped in FY2024 (from 1.04% to 0.65%) when both AI/ML counts and total certifications fell, but resumed climbing in FY2025 and FY2026. AI/ML filings grew 96% year-over-year while total certifications grew 20%. This mirrors the $200K+ pattern: a structural shift independent of overall filing volume.
The employers driving this: Apple (86 AI/ML filings, median $184,974), LinkedIn (63, median $187,741), Adobe (18, median $235,000), Meta (16, median $214,732), Qualcomm (13, median $158,400), Snap (12, median $180,710), ServiceNow (12, median $175,276), Pinterest (11, median $196,914), Reddit (10, median $300,000), TikTok (10, median $281,000), PayPal (10, median $227,500), and Atlassian (10, median $215,000).
AI/ML roles have a median wage of $184,974, compared to $144,400 for Software Developers (SOC 15-1252), the dominant H-1B occupation at 25,781 certified filings. AI/ML roles carry a 28% wage premium over general software development.
5. Amazon reclaims the top spot
Amazon led Q1 with 2,227 filings (all certified), reclaiming its position as the largest H-1B filer. Apple is second with 1,627 filings, followed by Ernst & Young, Cognizant, and Microsoft. The top of the table is a mix of tech majors, consulting firms, and outsourcing companies:
| Employer | Filings | Avg. Wage | Certified | Notable |
|---|---|---|---|---|
| Amazon | 2,227 | $158,445 | 2,227 | 100% certification rate |
| Apple | 1,627 | $179,134 | 1,165 | 28.4% Certified-Withdrawn |
| Ernst & Young | 1,566 | $172,715 | 1,509 | Consulting |
| Cognizant | 1,384 | $116,554 | 1,383 | Outsourcing |
| Microsoft | 1,317 | $183,807 | 1,317 | 100% certification rate |
| Deloitte | 817 | $153,053 | 815 | Consulting |
| Meta | 812 | $224,104 | 811 | Highest average wage, top 10 |
| TCS | 783 | $92,225 | 778 | Outsourcing |
| 773 | $203,897 | 770 | High average wage | |
| Infosys | 737 | $102,031 | 732 | Outsourcing |
Three patterns stand out:
Apple’s anomalous withdraw rate spike. Of Apple’s 1,627 filings, 462 (28.4%) were Certified-Withdrawn: Apple obtained LCA certification and then withdrew before filing the underlying I-129 petition. This stands out from the company’s previous filing patterns, where certified-withdrawn rates predominately hovered around 2-7%.
Consulting firms at scale. Ernst & Young (1,566 filings) and Deloitte (817) rank in the top 10 at average wages of $153K–$173K, well above the outsourcing firms in the same table.
Meta’s wage premium. Meta’s 812 filings carry the highest average wage in the top 10 at $224,104, reflecting the company’s concentration in senior engineering roles.
6. Amazon, Microsoft, Google, and Meta dip 8% as others gain share
Combined Q1 Nov–Dec certified filings for Amazon, Microsoft, Google, and Meta have declined from a FY2022 peak of 7,190, with a notable divergence in FY2026: these four companies declined 8.2% while the rest of the filing base expanded.
| Fiscal Year | Combined Q1 Nov–Dec Certified | YoY Change |
|---|---|---|
| FY2022 | 7,190 | — |
| FY2023 | 5,731 | −20% |
| FY2024 | 5,787 | +1% |
| FY2025 | 6,711 | +16% |
| FY2026 | 6,160 | −8.2% |
The FY2026 Q1 figure of 6,160 certified is 8.2% below FY2025’s 6,711. Over the full FY2025 year, these four companies produced a combined 47,016 certified LCAs.
Meanwhile, Apple’s certified filings grew from 974 (FY2025 Q1 Nov–Dec) to 1,173 (+20%) and NVIDIA grew from 207 to 434 (+110%). Consulting firms (Ernst & Young, Deloitte) scaled significantly. The outsourcing firms (TCS, Infosys, Cognizant) maintained substantial presence.
The top-10 filing list tells the story: concentration among a handful of large tech filers has given way to a broader distribution. As of FY26 Q1, tech majors, consulting firms, financial services companies, and outsourcing firms hold roughly equal shares. One variable to watch: the $100,000 proclamation fee on H-1B petitions for beneficiaries applying from outside the United States disproportionately affects outsourcing firms, whose candidates are more frequently processed through consular channels. We can expect major compositional changes to begin taking place starting with the FY27 cap lottery season.
7. The $56K Silicon Valley premium
H-1B wage offers vary sharply by metro area:
| Metro | Filings | Median Wage | P90 Wage |
|---|---|---|---|
| San Francisco | 1,602 | $190,000 | $275,000 |
| Silicon Valley* | 5,965 | $186,491 | $250,000 |
| Seattle Metro | 4,605 | $165,000 | $218,700 |
| New York City | 3,568 | $160,000 | $240,000 |
| Austin | 1,864 | $139,152 | $190,700 |
*Santa Clara, Sunnyvale, Cupertino, San Jose, Mountain View, Palo Alto, and surrounding cities.
The gap holds when controlling for occupation. For Software Developers (SOC 15-1252) specifically, the single largest H-1B occupation (25,781 certified filings), the Silicon Valley median is $198,000 versus $141,718 in Austin: a $56,282 gap for the same job classification (n=2,461 and n=691 respectively).
This gap directly affects wage level classification. A Software Developer wage appropriate for Austin may land at Level II; the same role in Silicon Valley may qualify for Level IV. Under the weighted lottery, that gap means 2x versus 4x selection entries.
California accounts for 19% of all certified filings (13,675) at a median of $172K. Texas is second with 11,207 filings at a median of $118K. Washington ranks third (5,235 filings, median $163K), followed by New York (4,956, median $142K) and New Jersey (3,412, median $132K).
8. Who pays above prevailing wage, and by how much?
Employers must pay at least the prevailing wage for the wage level at which their LCA was certified. Among cap-subject employers with 50+ certified filings this quarter, the premium above that floor ranges from 29% to 91%:
| Employer | Certified Filings | Avg. Offered | Avg. Prevailing | Premium %* |
|---|---|---|---|---|
| OpenAI | 57 | $296,718 | $160,883 | 90.7% |
| Boston Consulting Group | 62 | $210,235 | $145,105 | 45.8% |
| Ernst & Young | 1,509 | $173,962 | $123,082 | 45.2% |
| Mphasis | 301 | $117,830 | $84,802 | 42.3% |
| J.B. Hunt Transport | 53 | $131,254 | $93,230 | 41.7% |
| PwC Advisory | 116 | $194,051 | $147,436 | 35.5% |
| Goldman Sachs | 53 | $167,790 | $128,688 | 31.7% |
| Bank of America | 67 | $170,004 | $135,570 | 30.3% |
| Salesforce | 317 | $211,224 | $163,909 | 29.9% |
| TikTok | 71 | $206,464 | $162,631 | 29.1% |
*Premium % is the average of each filing’s individual (offered − prevailing) / prevailing ratio, which can differ from the ratio of the average columns.
OpenAI leads at 90.7%: 57 filings averaged $296,718, against a prevailing wage of $160,883. Consulting firms (BCG, Ernst & Young, PwC) cluster in the 35–46% range, reflecting advisory roles priced well above prevailing floors. Financial institutions (Goldman Sachs, Bank of America) and tech companies (Salesforce, TikTok) land in the 29–32% range, with offered wages above $160K offset by higher prevailing wages in major metros.
The bigger picture
Three forces are reshaping the H-1B filing landscape.
Regulatory reform is the backdrop. Beneficiary-centric selection eliminated most duplicate registrations and improved first-round selection rates from approximately 15% to 26%. The weighted lottery rule, effective FY2027, adds a new dimension: wage level now directly affects selection odds. The $200K+ share climbed from 4.6% in FY2022 to 12.6% before the rule took effect; the rule may accelerate that trend further.
Q1 volume fell ~25%, but the drop is a processing gap, not a demand signal. The October shutdown eliminated a full month of certifications, pulling Q1 totals well below FY2025. The subsequent Nov–Dec 20% gain reflects backlog clearing, not demand growth as December filings ran at FY2025 levels. Underlying demand appears to have consolidated above the FY2024 trough without accelerating, though future quarterly disclosures will provide a stronger signal.
Compositional shift is pulling wages upward. AI/ML roles command a 28% premium over general software development. Their share of H-1B filings has risen from 0.40% to 1.38% since FY2022, growing in four of five years regardless of overall volume. The $200K+ share at 12.6%, the median at $130K+, and the P90 approaching $210K reflect a program increasingly oriented toward senior, specialized roles.
For practitioners, the implications are concrete:
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Wage levels are now selection strategy. With the weighted lottery in effect for FY2027, Level III and Level IV filings carry different selection odds: 3x and 4x entries, respectively. The $200K+ share has nearly tripled since FY2022.
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The employer landscape is diversifying. The top 10 now spans tech majors, consulting firms, and outsourcing companies in roughly equal measure. Ernst & Young and Deloitte are filing at volume and at wages well above the outsourcing firms sharing the table with them. With the $100k consular notification fee and the new weighed lottery in effect, we can expect the outsourcing model to take a fundamental blow and for multiple firms to heavily reduce their H-1B program participation.
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AI talent competition is intensifying on H-1B. AI/ML filings have grown from 277 (FY2022) to 991 (FY2026), with the share rising from 0.40% to 1.38%. At a 28% wage premium over Software Developers, more employers are competing for the same talent pool at wages from $158K to above $300K.
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Geography is strategy. With wage level now playing a direct role in cap-subject lottery selection odds, immigration firms and H-1B employers alike are scrambling to develop H-1B filing strategies that include comparative analysis of wage levels across both SOC code classification and worksite prevailing wages.
Threshold is built to run that analysis across SOC codes, wage levels, and worksite geographies simultaneously. The API covers prevailing wage lookups, SOC classification analysis, geographic optimization, and employer intelligence, sourced from DOL OFLC disclosure data, OEWS prevailing wages, and O*NET. Evidence PDFs for LCA support packages generate from the same dataset.
For attorneys and HR teams working inside AI tools, Threshold publishes an MCP Server with 14 tools spanning all five modules. It runs natively inside Claude, ChatGPT, Cursor, and custom AI agents. Query prevailing wages, run SOC classification, or pull employer filing patterns without leaving the tool you’re already in.
Threshold is in early access. Request access here.
Data source: DOL OFLC LCA Disclosure Data, FY2022–FY2026 Q1. Analysis by Threshold. All wage figures represent annualized offered wages for certified H-1B filings. Detailed analyses use a cleaned and filtered data set excluding outliers below $15,000 and above $1,000,000 and filings with obviously erroneous data.
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