Global mobility policy - what belongs in it and who owns each part

A global mobility policy is the internal document that decides, in advance, what your company pays for when an employee moves across borders. It also names who approves an exception and who owns each step. Most policies get the first half right and skip the second. They describe the benefits in detail and leave the decisions unassigned, so who signs off on a six month housing extension gets answered differently each time. The cause is rarely a gap in immigration knowledge. It is the absence of a process: every move gets handled from scratch by whoever picks it up. What follows is the list of decisions the document has to settle, section by section, with the function that owns each answer.

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What a global mobility policy is and what it has to settle

A global mobility policy covers every piece of moving someone from one country to another. That means the offer, the work authorization, the shipment, the housing, the tax filings, the family, and the trip home. It settles three things before the first case opens: what the company pays for, who can approve a departure from the stated rule, and which function owns each step. No U.S. law requires an employer to keep a written global mobility policy. The obligations such a document organizes are required, and they sit in the Code of Federal Regulations rather than in your handbook. One narrow exception runs the other way. Under 2 CFR 200.464(a)(2), relocation costs charged to a federal award are allowable only if reimbursement follows an established written policy the employer applies consistently. Outside federal awards the document is optional and the duties inside it are not.

The sections a global mobility policy needs and who owns each one

Eight sections cover most programs. The table gives the shape, and the prose underneath says what goes inside each one. Any row where you cannot name an owner today is the row that will cost you later.

Eligibility is the section people write last and need first. Set it by role, level and business need rather than by request, so a hiring manager is not negotiating the package in the middle of an offer. A long posting is an international assignment, the person moving is the assignee, and an expatriate package of that kind usually needs a tier of its own. Relocation, shipping and housing are where the total cost of a move is decided, so each one needs a cap and a named approver rather than a range. Say what the company ships, what it reimburses on receipts, and how many nights of temporary accommodation it covers. Write the number down even if it is modest, because an unstated cap becomes whatever the last person approved. Tax is the section HR should not own alone. Decide whether you offer tax equalization, where the employee pays roughly the tax they would have paid at home and the company covers the difference. Then name the preparer who files in the host country. Dependants belong next to it, since a spouse and children change both the filings and the budget. Duration and repatriation close the loop. State how long the posting runs, whether it can extend, who pays the return trip, and what role the employee comes back to. A policy that stops at arrival leaves the most expensive question open.

Which visa categories should your policy cover?Compare requirements, timing and eligibility across U.S. work visas before you name the ones you will file.

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Writing the immigration and sponsorship section

This is the section most often left vague, and vagueness here moves start dates. Name the categories you will file, name the ones you will not, and name the person who decides when a case sits outside the list. If you came here only for the sponsorship rules themselves, our guide to building a company immigration policy owns that decision in full. Four items belong in this section and nowhere else.

1. A service level. What the company commits to on timing, from signed offer to filing, so nobody promises a candidate a date the process cannot hold.
2. The budget split. The breakdowns in work visa sponsorship cost and employer-sponsored green card let you set this against real figures.
3. Attorney of record. Form G-28, the Notice of Entry of Appearance as Attorney or Accredited Representative, is filed to establish eligibility to represent a client before USCIS. Under 8 CFR 292.4(a), it has to be signed by the petitioner, applicant or respondent for the appearance to be recognized. Say which party counsel appears for on an employer-filed petition.
4. What happens on a denial. Whether the company refiles, switches category, or ends the posting, and who tells the employee.

Immigration compliance duties the policy has to assign an owner to

These are the lines where a vague document turns into an employer's problem, so each one needs a name next to it rather than a department.

1. I-9 reverification. Reverify when an employee's employment authorization or its documentation expires, and do it no later than the expiration date. USCIS states that reverification is never required for U.S. citizens and noncitizen nationals, for lawful permanent residents who presented a Form I-551 Permanent Resident Card, or for List B identity documents. Document expiry tracking and the right to work file belong to one owner, not two.
2. Telling USCIS when a sponsored worker leaves. Under 8 CFR 214.2(h)(11)(i)(A), the petitioner must immediately notify USCIS of changes in a beneficiary's terms and conditions of employment. Where the petitioner no longer employs the beneficiary, it sends a letter explaining the changes to the director who approved the petition. HR triggers it on the termination date and counsel drafts it.
3. Return transportation on an H-1B dismissal. Under 8 CFR 214.2(h)(4)(iii)(E), the employer is liable for the reasonable costs of return transportation abroad. The trigger is dismissal before the end of the period of authorized admission. A voluntary resignation is not a dismissal, and finance should know this exists before it happens.
4. LCA notice and the public access file. Two duties sit here. Under 20 CFR 655.734, hard copy notice of a Labor Condition Application goes up in at least two conspicuous locations at each place of employment. The notice goes up on or within 30 days before filing and stays posted for a total of 10 days. Under 20 CFR 655.760, the certified application and its supporting documentation are open to public examination within one working day of filing. The records are kept one year beyond the last date any H-1B worker was employed under that application.
5. Amended petitions after a material change. In policy memorandum PM-602-0120 of July 21, 2015, USCIS set out when a material change needs a new filing. Following Matter of Simeio Solutions, H-1B petitioners must file an amended or new petition before placing an employee at a worksite the approved petition does not cover. A move inside the same area of intended employment needs no new application, though the original one still gets posted at the new site. The policy does not need to explain any of this at length. It needs to say whose calendar each date lives on and who signs each filing.

Who approves an exception to the employee relocation policy

Every policy gets exceptions, and the ones with no named approver quietly become the new rule. An employee relocation policy should carry an approval workflow short enough that people follow it under time pressure.

1. The request goes in writing and names the section it departs from and what it asks for.
2. HR checks two things: the cost, and whether the change touches an immigration filing. A new city or a changed title can do both.
3. The named approver signs off against a threshold your finance team already uses. Name the role rather than the person, so a vacancy does not stall a move.
4. The decision is recorded in the same place as the case file, with the date and the reason. That last step is the one teams skip. A policy exception that lives in a direct message cannot be cited the next time someone asks for the same thing. The company then grants it by default or refuses it for no stated reason.

How often to review a relocation policy, and what triggers an off-cycle review

Review the document once a year on a fixed date, and put that date and its owner inside the document itself. Four events should open it off-cycle.

• A government fee change, since the USCIS fee schedule moves on its own schedule and your budget lines are written against it.
• A rule change that alters a filing requirement or a posting duty.
• A first move into a country you have not sent anyone to before.
• A headcount shift that changes your volume enough to change who should own the work. A mobility document with no stated review date is one that ages until someone gets surprised by it.

Running a global mobility program without a policy

A global mobility program without a written policy still works, in the sense that people do move. What it costs shows up in four places. Offers differ between candidates for reasons nobody can reconstruct, because each one was negotiated by a different manager on a different week. Costs arrive after the fact, since no cap was set and the shipment, the housing and the dependant filings were each approved in isolation. Deadlines live in individual inboxes, so a reverification date or an extension window leaves with the person who was tracking it. And nothing records who agreed to what. When an employee asks why a colleague got three months of housing, there is no document to point at, and HR or people ops absorbs it.

Put your mobility policy in front of an immigration attorneyBring your draft sections and owners to a call with the Tukki legal team.

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Where Tukki fits in your global mobility strategy

Our immigration attorneys handle the legal strategy and the filings, and they answer the employee's questions directly rather than routing them back through HR. The software keeps documents, deadlines and case status in one place, so the policy has something concrete to point at when it names an owner for a date. That gives the immigration section of your global mobility strategy a stated service level instead of an intention. If the tooling question is the one you are on, our evaluation framework for immigration case management software covers it. Tukki is an immigration provider that helps employers and their employees with work visas and green cards. The range runs from H-1B specialty occupation and L-1 transfers to EB-2 and EB-3 cases through labor certification. HR teams get case visibility across the sponsored population, and the people you move get an attorney who answers them.

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