Keep an L-1A new-office record from approval to extension

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Create a working record that separates the initial expansion plan from the operation that develops, with responsibility for business activity, staffing, duties and financial evidence.

Save the initial plan as a dated baseline

Initial L-1A new-office evidence addresses secured premises and an operation capable of supporting a managerial or executive position within one year of approval. Save the submitted plan and supporting records as a dated baseline. Alongside it, make a separate working table of the milestones your company chose: opening steps, spending decisions and assignment of responsibilities. Give each milestone an owner and a place for actual results. Keep revisions in the working table without overwriting the submitted version. This creates a usable history when the team later needs to explain how the expansion unfolded.

USCIS Policy Manual: L-1A new-office initial evidence

Capture completed activity while it is easy to explain

At extension, USCIS asks for evidence that the U.S. entity has been doing business. As a practical monthly routine, select completed transactions and connect the order, delivery or service record, invoice and payment where available. Note the reporting period and the person who can explain the transaction. For longer projects, keep dated progress records so a later reviewer can understand what happened between signing and payment. These are organizational examples, not a prescribed monthly filing package. The useful question is whether someone outside the business can follow the activity from the records you retain.

USCIS Policy Manual: evidence of doing business at new-office extension

Track who takes over operating work

The extension evidence includes staffing information, wages paid and the beneficiary’s past and proposed duties. Keep a quarterly responsibility map showing who actually handles customer delivery, scheduling, purchasing and other recurring work. Add the date a responsibility changes hands, and distinguish employees from outside providers. Keep short contemporaneous notes about the beneficiary’s decisions and time allocation, using concrete examples rather than a leadership label. The map can reveal unresolved operating responsibilities while there is still time to discuss them. It is a planning aid, not a headcount formula or proof that any particular structure qualifies.

USCIS Policy Manual: new-office extension staffing and duties evidence

Keep corporate and financial records connected

The extension also requires evidence of continuing qualifying organizations and the U.S. operation’s financial status. Maintain one index of dated corporate changes and another of financial reporting periods, with named record holders. When a funding transfer appears, make a note of the corresponding agreement and the person who can reconcile the accounting treatment. If ownership changes, record the effective date and send the underlying documents for review. Avoid leaving these questions to a last-minute search through founder inboxes. A clear index helps the company retrieve the actual evidence without confusing a new forecast with an historical result.

USCIS Policy Manual: continuing organizations and financial evidence

Review the gap between the plan and the operation

Initial new-office approval is limited to one year; the extension review calls for evidence about the developed operation. Well before the relevant filing deadline, compare each baseline milestone with the actual record and identify missing explanations. A delayed hire, changed customer mix or revised product can be recorded honestly with dates and supporting facts. Have the company and counsel assess what those changes mean for the proposed role. Use the review to assign retrieval tasks and resolve factual gaps. Do not treat the original business plan, or a newly optimistic replacement, as an automatic substitute for operating evidence.

USCIS Policy Manual: extension of L-1 new-office petitions

YOUR CONVERSATION WORKSHEET

Turn reading into preparation.

Mark the topics you have prepared to discuss. This is a planning aid, not an eligibility assessment. Nothing entered here is sent or saved.

0 of 5 topics prepared

Baseline and datesWhere is the submitted initial plan stored? Record the approval and status dates for review with counsel, plus the person responsible for the extension calendar.Transaction trailChoose one completed transaction from the latest reporting period. Where are its order, performance record, invoice and payment, and who can explain any missing link?Responsibility changesWhich recurring operating tasks still sit with the beneficiary? For each reassigned task, record the responsible employee or provider, the change date and the supporting record.Corporate and financial ownersWho holds current ownership records, financial reports and funding agreements? List any change since the initial filing that needs review.Plan versus resultsIdentify three material differences between the initial plan and current operations. What happened, when, what evidence explains it, and who will assess its effect on the role?

General planning information. Individual immigration and licensing questions need assessment by appropriately qualified professionals.