Which Occupations Get Hit Hardest? A SOC Code Analysis of the Proposed Wage Thresholds
An occupation-level analysis of DOL's proposed prevailing wage threshold increases, examining how the impact varies across top H-1B job classifications and metro areas.
By Kevin Cole •
Updated March 27, 2026: This post has been revised to reflect the DOL’s published proposed rulemaking, which sets wage level thresholds at the 34th/52nd/70th/88th percentiles. The original version used the 2021 Final Rule thresholds (35th/53rd/72nd/90th) as a reference point.
In our previous analysis, we modeled the aggregate impact of the proposed DOL wage threshold increases across all FY2025 LCA filings: $16.5 billion in total compliance costs, 92% of filings affected. Those numbers capture the macro scale, but they obscure significant variation at the occupation level.
The wage distribution of a Software Developer filing differs fundamentally from that of a Computer Systems Analyst or an Industrial Engineer: the concentration across wage levels, geographic spread, and sensitivity to threshold shifts vary substantially by occupation. This analysis digs into the occupation-level data to answer a more targeted question: which job classifications face the most disruptive threshold increases, and where?
The H-1B Filing Landscape by Occupation
H-1B filings are heavily concentrated in a handful of SOC codes. Software Developers (15-1252) alone account for roughly 170,000 certified FY2025 filings, about a third of all non-academic H-1B volume. The next eleven largest occupations collectively make up most of the remainder.
This concentration matters because the proposed wage thresholds don’t increase uniformly across occupations. The dollar impact depends on the spread between existing wage levels for each SOC code, which varies substantially by occupation and geography.
Wage Level Mix: Where the Exposure Lives
Under the weighted lottery system taking effect for FY2027, wage level directly determines lottery entries: Level 1 gets one entry, Level 4 gets four. The distribution of filings across wage levels therefore measures two compounding risks at once: reduced lottery odds under the weighted system and larger compliance gaps under the proposed thresholds.
Wage level analysis is based on filings with reported wage level data in the DOL disclosure file. Coverage is approximately 90% for FY2025 (e.g., 161,459 of 179,964 Software Developer filings). The remaining ~10% carry null wage level values despite the field being mandatory on the LCA, likely a disclosure file formatting artifact.
Several patterns stand out:
Computer Programmers (15-1251) have the most bottom-heavy distribution: 85.6% of filings are at Level 1 or Level 2, with 70.6% at Level 2 alone. Only 4.4% reach Level 4. This is the occupation most exposed to both the lottery weighting and the proposed threshold increases.
Accountants & Auditors (13-2011) have the highest Level 1 share at 31.1%, nearly a third of filings at the entry-level tier. Combined with Level 2 (40.1%), over 71% of accounting H-1B filings sit in the bottom two tiers.
Software Developers (15-1252), the dominant occupation by volume, show a moderately bottom-heavy distribution: 60.4% at Level 1 or 2. At 170,000 filings per year, even modest per-position cost increases generate enormous aggregate exposure.
Electronics Engineers (17-2072) sit at the opposite extreme: 30% of filings are at Level 4, the highest share of any major SOC code. With 4x selection weight in the lottery and the smallest threshold gaps among major occupations, these positions face the least disruption from either policy change.
What the Proposed Thresholds Mean, Occupation by Occupation
The proposed rule would shift wage level percentiles from 17th/34th/50th/67th to 34th/52nd/70th/88th. Applied to current OEWS wage data, this produces meaningfully different dollar impacts depending on the occupation.
Wage distributions are right-skewed: the dollar gap between successive percentiles grows as you move up the distribution. The distance between the 50th and 67th percentile is roughly $28,000 for Software Developers. BLS OES publishes actual 75th and 90th percentile wages, allowing us to anchor the proposed thresholds to empirical data rather than relying solely on extrapolation. The proposed Level 3 (70th percentile) is interpolated between the OFLC 67th percentile and BLS 75th percentile. The proposed Level 4 (88th percentile) is interpolated between the BLS 75th and 90th percentiles. In high-wage metros, however, BLS censors the 90th percentile (reported as ”>$115/hr”) in 8 of 382 MSAs for Software Developers, including San Jose, Seattle, and San Francisco. In those metros, Level 4 must be extrapolated and should be treated as a floor. This is staff-level engineer territory at a major tech company, not a senior developer at a mid-market employer. For many high-wage SOC codes in top-filing metros, Level 4 could effectively collapse to a flat ceiling at or near the BLS estimation cap of $239,200.
For Software Developers, the single most important SOC code in H-1B, the threshold shift is substantial across all four levels:
Under proposed thresholds, a Software Developer Level 1 position would require an estimated $116,376 nationally, a $28,000 increase over the current $88,483 threshold. Notably, the proposed Level 1 (34th percentile) is exactly the current Level 2 threshold. Our prior analysis found that 100% of FY2025 Level 1 filings fall below the proposed thresholds across all occupations analyzed. At $116k, the proposed Software Developer Level 1 exceeds what most IT consulting firms currently offer for junior positions.
The L1 gap ($28k, +32%) is the current Level 2 threshold exactly, and the L2 gap ($31k, +27%) is a high-confidence estimate interpolated between adjacent OFLC percentile points. The L3 gap ($27k, +19%) reflects interpolation between the OFLC 67th percentile and BLS OES 75th percentile: because the BLS empirical 75th percentile is slightly below the OFLC’s derived 67th percentile at the national level, the interpolated L3 is modestly lower than a pure extrapolation would suggest. The L4 gap ($34k, +20%) is interpolated between the BLS 75th and 90th percentiles; in censored metros, it is a conservative floor.2 The percentage increase is steepest at Level 1 (32%) and shallowest at Level 3 (19%), with the L3-to-L4 gap widening to $35k as the right tail of the distribution accelerates.
Cross-Occupation Comparison
Comparing across the top SOC codes, the dollar gaps vary considerably:
| Occupation | Current L1 | Proposed L1 | L1 Gap | L1 % Increase |
|---|---|---|---|---|
| Computer & IS Managers (11-3021) | $116,002 | $151,819 | $35,817 | 30.9% |
| Software Developers (15-1252) | $88,483 | $116,376 | $27,893 | 31.5% |
| Computer Occ., All Other (15-1299) | $61,693 | $89,066 | $27,373 | 44.4% |
| Data Scientists (15-2051) | $71,386 | $97,864 | $26,478 | 37.1% |
| Software QA Analysts (15-1253) | $66,789 | $88,421 | $21,632 | 32.4% |
| Computer Systems Analysts (15-1211) | $70,034 | $90,896 | $20,862 | 29.8% |
| Industrial Engineers (17-2112) | $73,424 | $90,584 | $17,160 | 23.4% |
Computer & IS Managers face the largest absolute gap at $35,817 per Level 1 position, though at a $116k starting threshold, these are already senior-compensated roles. The proposed Level 1 of $151,819 would push entry-level IT management positions firmly into senior individual contributor territory.
Computer Occupations, All Other (15-1299) face the steepest percentage increase: 44.4% at Level 1. This catch-all code, which covers cloud architects, DevOps engineers, and other roles that don’t map to a standard classification, would see its entry threshold jump from $61,693 to $89,066.
Industrial Engineers face the smallest gap in both absolute and percentage terms, consistent with the narrower wage dispersion in traditional engineering disciplines relative to software occupations.
Geography Amplifies the Impact
For Software Developers, the current Level 1 threshold ranges from $85,467 in Chicago to $149,365 in San Jose, a $63,900 spread. Under proposed thresholds, that range widens to $108,077 to $187,741, a $79,664 gap that makes metro selection a first-order compliance decision.
Filing Hotspot Analysis
The geographic variation becomes especially significant when you consider where H-1B filings are actually concentrated. Filing counts below reflect cumulative certified LCA filings (FY2022-2026) to show structural metro-level patterns:
| Metro | SW Dev Filings | Current L1 | Proposed L1 | Gap |
|---|---|---|---|---|
| Dallas-Fort Worth | 94,234 | $90,896 | $112,923 | $22,027 |
| San Jose (Silicon Valley) | 77,598 | $149,365 | $187,741 | $38,376 |
| Seattle | 66,664 | $117,749 | $149,240 | $31,491 |
| New York | 57,299 | $103,210 | $131,997 | $28,787 |
| San Francisco | 47,464 | $135,699 | $161,637 | $25,938 |
| Atlanta | 34,514 | $87,859 | $109,283 | $21,424 |
| Austin | 27,984 | $90,355 | $114,754 | $24,399 |
| Chicago | 26,641 | $85,467 | $108,077 | $22,610 |
| Washington DC | 25,916 | $101,421 | $126,090 | $24,669 |
San Jose (Silicon Valley) has the largest per-position gap at $38,376, driven by exceptionally high local wage data that pushes the proposed Level 1 to $187,741. The proposed San Jose entry-level threshold exceeds the current Level 3 threshold in most of the metros shown above.
Dallas-Fort Worth leads in filing volume (94,234) with a proposed Level 1 of $112,923. This is where the IT consulting model has concentrated, and it’s the metro that will see the most filings affected numerically.
San Francisco shows the smallest gap among major tech hubs ($25,938), partly because its already-high wages compress the percentage increase. Seattle’s proposed Level 1 of $149,240 represents a 27% increase over its current $117,749 threshold.
The Compounding Effect: Wage Levels, Lottery, and Geography
The occupational lens reveals how the proposed thresholds interact differently with the weighted lottery depending on the SOC code:
High-risk occupations (Computer Programmers, Accountants, Data Scientists) combine Level 1+2 filing concentrations of 63-86% with threshold gaps of $18-30k per position. Under the proposed rule, these classifications face the most pressure: either wage increases to meet the new thresholds or downward reclassification that reduces lottery entries.
Lower-risk occupations (Electronics Engineers, Computer & IS Managers) have more top-heavy wage distributions and can more easily absorb threshold increases. Managers, despite facing the largest absolute gaps, already file disproportionately at Level 3 and 4.
The geographic dimension adds another layer. An employer filing a Software Developer position in Dallas at Level 1 currently needs to pay $90,896. Under proposed thresholds, that same position requires $112,923, a 24% increase. The same employer filing in San Jose faces a jump from $149,365 to $187,741 (26%), with a far larger absolute gap of $38,376.
This means the proposed rule hits hardest in absolute terms where wages are already highest: San Jose’s $38k gap dwarfs Dallas’s $22k, while percentage increases are comparable across metros (24-27%). For IT consulting firms concentrated in Dallas, Atlanta, and Austin, the dollar gaps are $21-24k per position.
What This Means for Practitioners
For immigration attorneys and HR teams preparing for the FY2027 filing season and beyond, this occupation-level analysis suggests several practical considerations:
SOC code selection matters more than ever. A role that could reasonably be classified as either 15-1252 (Software Developers, $116k proposed L1) or 15-1211 (Computer Systems Analysts, $91k proposed L1) faces a $25,000 difference in the entry-level threshold. Under proposed thresholds, that gap is the difference between a manageable compliance cost and a budget-breaking one.
Geographic strategy becomes a wage strategy. Under the weighted lottery, geographic optimization is already a tool for improving lottery odds. The proposed thresholds add another dimension: the same salary qualifies for different wage levels in different metros. Employers with multi-site operations have more levers to pull.
The IT consulting model faces occupation-specific pressure. The three SOC codes most associated with IT consulting (15-1252, 15-1299, and 15-1211) collectively account for over 1 million filings and face proposed Level 1 thresholds of $89-116k nationally. These are the occupations where the gap between current employer practice and proposed thresholds is widest.
Conclusion
The aggregate $16.5 billion compliance cost from our previous analysis captures scale. This occupation-level analysis reveals where that cost concentrates: overwhelmingly in software and computer occupations, disproportionately at Level 1 and 2, and with geographic variation that can swing a single position’s compliance gap by tens of thousands of dollars.
The proposed wage thresholds do not treat all occupations equally. Employers who model the impact at the SOC code and metro level, rather than relying on national averages, will be better positioned to make strategic filing decisions. Those who don’t will be making six-figure compliance decisions with five-figure visibility.
Footnotes
Footnotes
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This analysis uses the 2026 NPRM percentiles of 34th/52nd/70th/88th. The 2021 Final Rule used 35th/53rd/72nd/90th; the October 2020 Interim Final Rule (IFR) used 45th/62nd/78th/95th, which were vacated by federal courts. The 2026 NPRM thresholds closely mirror the 2021 Final Rule, differing by only 1-2 percentile points at each level. Our prior analysis also uses the 34th/52nd/70th/88th percentiles. ↩
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Proposed Level 1 (34th percentile) corresponds to the current Level 2 threshold exactly. Proposed Level 2 (52nd percentile) is interpolated between adjacent OFLC wage levels (50th and 67th percentiles). Proposed Level 3 (70th percentile) is interpolated between the OFLC 67th percentile (Level 4) and the BLS OES 75th percentile:
L3 = OFLC_67th + (70-67)/(75-67) * (BLS_75th - OFLC_67th). At the national level for Software Developers, the BLS 75th ($81.25/hr) is slightly below the OFLC 67th ($82.78/hr), reflecting methodological differences between OFLC’s derived wage levels (mean-based) and BLS’s empirical percentiles. This produces a more conservative L3 than pure extrapolation from OFLC data alone. Proposed Level 4 (88th percentile) is interpolated between the BLS OES 75th and 90th percentiles. In 8 of 382 MSAs, including San Jose, Seattle, and San Francisco, the BLS 90th percentile is censored (”>$115/hr” or >$239,200 annualized); in those metros, L4 falls back to OFLC-based extrapolation and should be treated as a floor. ↩
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