IN THIS GUIDE · Review a move to another group entity against the actual blanket approval
Start with the L-1A eligibility and application overview
Identify the destination entity and approved coverage
Compare the actual legal entity with the organizations named in the blanket approval. Document its qualifying relationship and operating facts. Do not rely solely on a group logo or an informal statement that the whole group is covered. Use formation, ownership, and transaction records to test the listed organization at the actual reassignment date. A group logo or an old chart cannot establish what a merger or reorganization changed. If the legal name changed, obtain the resolution or transaction record connecting the listed entity to its current name before relying on informal explanations.
Compare the duties before and after reassignment
The regulation permits reassignment during authorized stay to an organization listed in the approved blanket when the employee performs virtually the same duties. Different duties or changes affecting eligibility require review under the applicable process. Do not treat this specific provision as blanket permission to move to any company or any job. Compare functions, decision power, and reporting level rather than job titles. The employer must decide whether the employee will perform virtually the same work or whether a different immigration step requires review. Retain both job descriptions and ask the business to identify every material difference. A revised reporting chart can expose a change even where a title remains identical.
Retain the individual qualifying basis
The proposed role must primarily involve qualifying managerial or executive work. Generally establish a continuous year of qualifying full-time foreign employment in the relevant preceding three years, with the applicable blanket conditions assessed, and continuing qualifying business in the United States and abroad. A corporate reassignment does not replace individual eligibility or extend the authorized stay. The foreign employee must have one qualifying continuous year with the related organization during the three years immediately before the transfer. L-1A has a cumulative seven-year limit, so previous L time belongs in the staffing plan. Count prior L periods carefully, including earlier assignments, before a new end date is represented to the employee or receiving company.
Explain authority and support in the proposed operation
Identify the applicant’s decisions, responsibility for staff or a function and the support performing execution work. Identify authority over priorities, resources or the relevant function, together with any approvals retained elsewhere. The record should separate the owner’s personal authority from the transferee’s future authority, identify people who will perform ordinary operational tasks, and explain how the U.S. organization will function on a normal week. Identify real employees or service arrangements supporting the function instead of assigning all daily delivery to the transferee. For a new office, sufficient premises and support for a managerial or executive role within one year are required; initial new-office approval is limited to one year.
Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.
