By: Patricia Gannon, Esq. and Marcela Bermudez, Esq.
For the past several years, employers sponsoring H-1B petitions and PERM labor certifications have faced challenges when using the Computer Systems Analyst classification. In 2023, O*NET downgraded the Computer Systems Analyst occupation from Job Zone 4 to Job Zone 3, a designation that often failed to reflect the realities of the profession when employers sought to demonstrate that the position normally requires a specialized bachelor’s degree. The U.S. Department of Labor (DOL) has now reclassified the occupation and restored it to Job Zone 4, better aligning it with industry standards and reducing some of the hurdles employers face when establishing that the position requires, at minimum, a bachelor’s degree.
Effective July 2026, the O*NET occupational data for Computer Systems Analysts (SOC 15-1211.00) has been reclassified from Job Zone 3 to Job Zone 4. This welcome change represents a significant development for employers that rely on this occupation for H-1B petitions, PERM labor certification applications, and prevailing wage determinations.
The DOL uses Job Zones to categorize occupations into five groups based on the level of education, experience, and training typically required to perform the duties of the position. Job Zone 4 occupations generally require substantial preparation, including a bachelor’s degree in a related field and two to four years of relevant experience. In contrast, Job Zone 3 occupations typically require a vocational or associate degree and one to two years of experience. While the occupation remained in Job Zone 3, H-1B petitions for Computer Systems Analysts were frequently challenged by U.S. Citizenship and Immigration Services (USCIS), which often argued that the classification did not support the position’s qualification as a specialty occupation requiring a bachelor’s degree or higher.
The reclassification to Job Zone 4 more closely aligns with the educational and professional qualifications that employers have traditionally expected for Computer Systems Analyst positions. However, it is important to note that the reclassification alone does not determine the approvability of a case. While the change may strengthen future H-1B and PERM filings involving this occupation, employers should continue to evaluate specialty occupation issues, prevailing wage considerations, and case strategy on a case-by-case basis.
Greenspoon Marder’s immigration attorneys can help employers understand the implications of this change, evaluate available options, and develop strategies to address compliance and visa-related concerns.
This publication is provided by Greenspoon Marder LLP is issued for informational purposes only and is not intended to be construed or used as general legal advice nor a solicitation of any type. Please contact the author(s) or your Greenspoon Marder LLP contact if you have any questions regarding the currency of this information. The hiring of a lawyer is an important decision. Before you decide, ask for written information about the lawyer’s legal qualifications and experience.
