Research

Can AI Get Immigration Right?

This report presents an independent evaluation of how leading AI models perform on U.S. immigration law questions, and what it means for the international students, entrepreneurs, employers, and other people who rely on AI to navigate the U.S. immigration system.

Talent Mobility FundVals AI
Talent Mobility Fund & Vals AI 10/28/2026
Can AI Get Immigration Right?

Live results are on the Immigration Bench page.

Key Takeaways

  • No AI model performs well enough to be trusted with immigration guidance. The top-performing model, Claude Fable 5.1, met 75.4% of each question’s rubric items on average, and gave a fully correct answer (defined as meeting every item on the rubric) on only 26.3% of questions. For the most vulnerable users, including those with Deferred Action for Childhood Arrivals (DACA) or Temporary Protected Status (TPS), even the best model met only 63.9% of rubric items on average.
  • Models explain the law better than they apply it. Immigration advice depends on the specific person’s facts. Every model was better at explaining general rules than at working out what those rules mean for the person asking. Models that asked the person more questions did not score higher overall: asking questions earned credit on fact-finding items but did not improve the legal guidance itself.
  • No single model has the full picture. Together, the 25 models met about 93% of what the experts asked for — but the best individual model met only 75.4%, meaning a significant share of what the benchmark requires sits outside any one model’s reach. Recent policy is the starkest exception: on rules from 2025 and 2026, even all 25 models combined met only about 29% of rubric items. The knowledge gap on recent immigration law is not a model-selection problem — it is a structural one.
  • Recent policy changes are an invisible gap. Models met only 7.3% of rubric items involving policy rules from 2025 and 2026, compared to 64.0% for established law. Web search helps, but does not reliably close this gap: even the best model with web search met only 43.1% of recent-rule items.
  • Employer questions gain the most from web search. Web search raised the average score on Employer questions by 10.4 points, well ahead of its effect on any other persona (6.0 points for University Advisor questions, the next largest). For example, without search, no model knew about a March 2026 change in how ICE enforces I-9 violations.
  • Fixing the gaps requires more than better models. The knowledge AI needs to reliably answer immigration questions, such as agency policy memos and adjudication trends, is fragmented across the Department of Homeland Security, the Department of State, immigration courts, and legal practice. Closing the gap will require AI developers to collaborate with immigration attorneys, legal service organizations, and federal government experts to build narrowly scoped, retrieval-grounded tools rigorously tested against real immigration questions.
  • Models perform far better on student work permits than on long-term visas for STEM workers. Rubric items on student work authorization (OPT and STEM OPT) were met 76% of the time. Items on the employment-based green card and talent pathways that scientists and engineers use to stay long-term, such as the National Interest Waiver, PERM labor certification, O-1, and EB-5, were met 57% to 60% of the time.
Immigration Bench leaderboard: average answer accuracy, cost, and duration for all 25 models without web search

Partners in Evaluation

Immigration Bench is a joint effort by the Talent Mobility Fund, a program of Renaissance Philanthropy, and Vals AI.


Background

About half of U.S. adults now use AI chatbots, according to the Pew Research Center. Immigration questions – about visa eligibility, filing deadlines, work authorization, and what to do when a status is at risk – are among the most consequential. This benchmark tests whether AI gets these answers right.

The consequences of a wrong answer are serious: a missed deadline can mean losing work authorization, incorrect advice about immigration status can trigger removal proceedings, and misinformation about a visa category can cost an employer a key hire.

Vals AI and the Talent Mobility Fund partnered to build an expert-validated benchmark for AI performance on U.S. immigration law. We tested 25 leading AI models against hundreds of questions written by immigration experts. This work is intended as a guide to improvement for AI labs, and to give the public, practitioners, and policymakers a clear, evidence-based picture of where AI stands on U.S. immigration knowledge.

Note: This benchmark focuses on common immigration pathways used by scientists, engineers, and other professionals, such as student visas, work visas, and those transitioning from an uncertain situation, such as Deferred Action for Childhood Arrivals (DACA), to a more durable immigration status. There are many other immigration domains that are out of scope for this study, such as the asylum system and the immigration court system, where the consequences of incorrect information could be even more consequential.


About the Benchmark

Every question has an expert-written rubric: a list of items a complete answer must include. A rubric item counts as met when the model’s answers include it anywhere in the conversation, as judged by an AI grader (see Methodology). A model’s average answer accuracy is the share of each question’s rubric items it met, averaged over all questions.

Immigration experts drafted a benchmark of 519 questions designed to reflect the complexity and stakes of real immigration questions; not textbook scenarios, but the kinds of issues that actually appear on an attorney’s desk or in an immigrant’s search bar. Each question was written from the perspective of a specific persona, such as an international student, an employer, a DACA recipient, or a university advisor, reflecting the range of individuals who actually turn to AI for immigration support. Questions were designed around ambiguous facts, multi-step legal analysis, and situations where the wrong answer carries serious consequences. The goal was not to catch models out on technicalities, but to test whether the models can handle the kind of complexity that people actually encounter.

This page reports results on the 262-question test set, which is kept private to allow ongoing, tamper-resistant evaluation. The other 257 questions are not part of these results and are reserved for the labs to license for their own benchmarking and evaluation work.

PersonasEach test question is written from one persona's point of view
  • International StudentF-1 visa holders navigating work authorization and maintenance of immigration status64Questions
  • International Scholar / FacultyResearchers and academics on J-1 or H-1B visas33Questions
  • University AdvisorUniversity staff advising international students33Questions
  • EmployerHR professionals and counsel for companies sponsoring noncitizen employees34Questions
  • EntrepreneurFounders and business owners navigating their own immigration options34Questions
  • Self-PetitionerIndividuals pursuing O-1, EB-1, or similar pathways that are independent of an employer34Questions
  • Fragile / Temporary StatusIndividuals on DACA, Temporary Protected Status (TPS), or with uncertain immigration status30Questions
  • 7Personas262Test questions

To give a sense of what the benchmark looks like in practice, the table below demonstrates one representative question from each persona.

One representative question per persona
PersonaQuestion
International StudentI got an email saying my SEVIS record was terminated. Do I have to leave the U.S. immediately?
International Scholar / FacultyI am a J-1 research scholar. Can I technically obtain an EB-1 while I am on J-1?
University AdvisorCan a student with TPS and a pending F-1 change of status still attend full-time until approved? Should they?
EmployerOur company just changed its legal name and tax ID. Do I have to re-file immigration paperwork for every single visa holder we employ?
EntrepreneurI would like to apply for an E-2 treaty investor visa upon purchasing partial shares of a restaurant. Is that possible and what counts as a “substantial” investment?
Self-PetitionerAre publications mandatory for a National Interest Waiver or only helpful for academic/research profiles?
Fragile / Temporary StatusIf I am in the United States under a current TPS designation, can I continue to work with an expired EAD while my EAD extension application is pending?

Results

Overall performance

The top-scoring model, Claude Fable 5.1, met an average of 75.4% of each question’s rubric items. This means that even the best AI model left out roughly one in four pieces of information an immigration expert would consider essential to a complete answer. Fully correct answers, where a model met every rubric item, were rare: the best rate was 26.3% (Claude Fable 5.1), and rates ranged from 12.6% to 26.3%.

Claude Fable 5.1 leads at 75.4%, 3.3 points ahead of Claude Opus 5.5 (72.1%), a clear lead: on the same questions it scores 1.2 to 5.4 points higher (95% interval). Behind it, 10 models scored within 4.4 points of each other (67.7% to 72.1%).

Without web search, Claude Fable 5.1 had the top score on all seven personas, from 60.9% on University Advisor questions to 90.2% on International Student questions. It did not lead on every single question, though: on 134 out of the 262 questions, at least one other model scored higher.

The models know more together than any one of them shows. A complete answer that drew on the best response to each rubric item across all 25 models would score about 92%, against 75.4% for Claude Fable 5.1, and would be fully correct on about 62% of questions, against 26.3% for Claude Fable 5.1. Even if you could always pick the best model’s answer to each question — knowing in advance which model would do best — you would only score 87%. About 90% of rubric items were met by at least one model — the remaining 10% were beyond every model tested. The gap is less about missing knowledge than about applying it reliably to each specific question: most of what the best model misses, some other model gets right. Recent policy is the exception: even taken together, the models met only about 29% of rubric items on 2025 and 2026 rules.

The combined model score is lowest for Fragile/Temporary Status (84%) and University Advisor (85%) questions, against 93% to 97% for the other personas — a sign that these two personas are more challenging, not just for one model but for all of them. The best single model on each was 63.9% (Fragile/Temporary Status) and 60.9% (University Advisor). These combined figures are best read as an upper bound: because an item counts as met if any one of the 25 models met it, they also include cases where the grader incorrectly marked an item as met.

Significant challenges

Performance varied significantly across personas, from 85.6% average answer accuracy for International Students down to 48.5% for University Advisors. International Students, whose questions tend to be more standardized, such as questions related to Optional Practical Training (OPT) timelines, Curricular Practical Training (CPT) authorization, and maintaining status, received the most reliable answers. University Advisors scored lowest; their questions carry the longest rubrics in the benchmark with 19.5 items on average. Individuals with Fragile or Temporary Status scored second-lowest, at 51.1% average answer accuracy, and for these users the cost of a wrong answer is potentially the most severe. For every model, these two personas were consistently the two lowest.

PersonaRubric items per questionAverage score (all models, without web search)Best single model (without web search)Worst single model (without web search)
International Student8.685.6%90.2% (Fable 5.1)80.2% (Gemini 3.5 Flash Lite)
International Scholar / Faculty15.766.7%74.8% (Fable 5.1)47.4% (Gemini 3.5 Flash Lite)
University Advisor19.548.5%60.9% (Fable 5.1)34.3% (Gemini 3.5 Flash Lite)
Employer4.864.6%76.1% (Fable 5.1)51.7% (MiniMax-M3)
Entrepreneur4.964.2%72.9% (Fable 5.1)52.4% (MiniMax-M3)
Self-Petitioner4.463.6%74.5% (Fable 5.1)52.4% (MiniMax-M3)
Fragile / Temporary Status9.351.1%63.9% (Fable 5.1)38.9% (Gemini 3.5 Flash Lite)

The people in the most vulnerable immigration situations, likely with the least access to legal counsel, get the weakest answers

For individuals with fragile or temporary status, including DACA recipients and those on TPS, even the best model scored only 63.9% average answer accuracy. Some of the lowest-cost models tested scored as low as 38.9% for this persona.

For example, when asked how soon to renew DACA, Claude Opus 5.5 met every rubric item, while Gemini 3.5 Flash Lite and GPT-6 Luna scored 40% and 20% respectively; they gave the government-recommended renewal window, but neither checked whether the individual was still eligible to renew or flagged the pending Texas v. United States litigation. Every model scored lower on Fragile/Temporary Status than on any other persona except University Advisor. The three lowest scores on the Fragile/Temporary Status persona all came from low-cost models: Gemini 3.5 Flash Lite (38.9%), MiniMax-M3 (42.9%) and DeepSeek V4 Pro (43.1%). Cost does not always determine quality, though: MiMo V2.6 Pro, at under 2 cents a question, scored 56.6%, fourth-best of the 25 models.

AI knows the rules better than it knows how to apply them

The questions that the models found most challenging share a common thread: they turn on recent policy changes, operational details, or the individual’s specific circumstances. Whether premium processing has become the default for National Interest Waiver (NIW) petitions (16% average score across models) or whether an NIW can cover work in multiple roles or industries (33% average score across models, see Example 4) both require either up-to-date policy knowledge or multi-step reasoning applied to a specific situation. At the other end, 4 questions were answered fully correctly by every model, and others came close, such as whether a student whose F-1 visa has expired is “undocumented,” where 24 of 25 models met every item (see Example 5). All of them turn on well-established, foundational legal distinctions that have not changed recently.

This pattern holds at the rubric item level too. Rubric items requiring the model to confirm something about the person’s circumstances — their visa stage, their eligibility, their filing history — were met only 43% of the time, compared to 63% for items asking AI to explain the law or recommend a next step, and 86% for items warning it away from a specific mistake. AI is better suited as a research and explanation tool than as a diagnostic one. It can tell you what the law says — but it struggles to tell you what the law means for you. Asking the user more questions was not the fix: when a model asked questions in its first reply, it met about 4 points more of the fact-finding items on that question, but its overall score barely moved (under 1 point) and its legal guidance did not improve.

Persona Strengths Relative to the FieldEach model's score by persona, against the field mean on the same questions
Immigration Bench•Oct 28, 2026
Vs. field mean:
BelowAbove
Persona Strengths Relative to the Field
ModelsInternational StudentInternational Scholar / FacultyEmployerEntrepreneurSelf-PetitionerFragile / Temporary StatusUniversity Advisor
Field mean85.666.764.664.263.651.148.5
Claude Fable 5.190.2+4.674.8+8.176.1+11.572.9+8.774.5+11.063.9+12.860.9+12.4
Claude Opus 5.588.9+3.374.6+7.974.5+10.068.0+3.865.2+1.759.8+8.757.2+8.7
Wonder Full88.2+2.773.4+6.774.9+10.468.9+4.766.9+3.355.3+4.253.6+5.1
Qwen 3.8 Max86.7+1.171.8+5.164.9+0.371.5+7.271.2+7.655.1+4.053.0+4.5
Wonder86.3+0.772.8+6.169.0+4.466.1+1.970.0+6.451.7+0.654.1+5.6
Claude Sonnet 5.586.5+1.065.6-1.270.9+6.369.6+5.463.60.057.7+6.651.3+2.8
Kimi K385.2-0.471.3+4.672.8+8.264.3+0.166.4+2.851.4+0.349.0+0.5
Gemini 4 Argon86.6+1.067.6+0.963.9-0.661.3-2.971.3+7.755.5+4.451.9+3.4
Grok 4.787.2+1.771.7+5.064.0-0.664.0-0.265.3+1.753.3+2.251.8+3.3
GPT-6.1 Sol88.3+2.870.4+3.666.0+1.466.7+2.563.9+0.350.1-1.048.60.0
GPT-6 Astra88.6+3.069.9+3.268.2+3.768.6+4.458.4-5.249.4-1.749.6+1.1
MiMo V2.6 Pro86.1+0.568.5+1.863.6-1.064.5+0.365.4+1.856.6+5.449.7+1.1
GLM 5.385.5-0.166.9+0.267.4+2.860.8-3.467.1+3.548.3-2.851.9+3.4
Muse Spark 1.286.3+0.866.5-0.362.5-2.167.5+3.365.5+1.948.9-2.248.50.0
Grok 4.684.0-1.569.4+2.761.7-2.963.9-0.366.2+2.652.9+1.845.7-2.8
DeepSeek V4.1 Flash86.8+1.269.0+2.359.4-5.262.1-2.265.0+1.447.6-3.548.4-0.2
Muse Spark 1.383.4-2.265.5-1.262.5-2.164.8+0.661.8-1.750.3-0.848.2-0.3
Muse Spark 1.3 Max86.6+1.063.1-3.764.2-0.463.7-0.558.3-5.350.6-0.646.6-2.0
Mistral Large 482.4-3.262.9-3.867.0+2.465.1+0.962.2-1.447.0-4.140.3-8.2
Gemini 3.8 Flash84.3-1.363.2-3.561.0-3.660.5-3.858.4-5.249.8-1.446.1-2.4
GPT-6 Luna83.8-1.765.3-1.455.3-9.363.4-0.858.4-5.243.3-7.946.7-1.8
Claude Haiku 5.583.9-1.758.8-8.060.8-3.857.3-6.957.8-5.854.5+3.438.4-10.1
DeepSeek V4 Pro 081382.2-3.359.5-7.255.0-9.663.7-0.561.1-2.543.1-8.046.2-2.3
MiniMax-M381.0-4.658.2-8.551.7-12.852.4-11.852.4-11.242.9-8.241.2-7.3
Gemini 3.5 Flash Lite80.2-5.447.4-19.357.3-7.353.8-10.453.3-10.338.9-12.234.3-14.2
Personas run from easiest to hardest; models are ranked by overall score.Each cell shows the score and its difference from the 25-model mean, shaded fully at ±19 points.

The heatmap above removes question difficulty: each cell is a model’s score on that persona minus the 25-model mean on the same questions. Every model scores 29 to 46 points lower on University Advisor questions than on International Student questions.

With 30 to 64 questions per persona, the standard error on a persona score is about 2 to 6 points. Thus, these scores should be read as indicative rather than definitive.

Where the Field AgreesCriteria every model passes or fails, by persona
Immigration Bench•Oct 28, 2026
Share of criteria
Criteria:
International Student64 questions553 criteria
57%38%
International Scholar / Faculty33 questions519 criteria
21%74%
Employer34 questions164 criteria
16%79%
Entrepreneur34 questions166 criteria
20%73%
Self-Petitioner34 questions150 criteria
16%76%8%
Fragile / Temporary Status30 questions279 criteria
18%63%19%
University Advisor33 questions643 criteria
10%74%16%
262 questions across 25 models, an unfinished conversation failing every criterion: 2,474 criteria, 245 of them failed by every model.Best-of-field is the mean score if the best model were picked for each question.

AI is flying blind on recent immigration law

Immigration policy has changed significantly in 2025 and 2026, with new rules affecting OPT, H-1B, and other key pathways. 65 rubric items cite a rule from 2025 or 2026. Without web search, pooled across all 25 models, these rubric items were met 7.3% of the time, against 64.0% for every other item. The best model on these items, Claude Fable 5.1, met these rubric items 18.5% of the time. Even with web search, these rubric items were met only 29% of the time.

For example, when an international student asked how the end of “duration of status” affects them, no model distinguished, without web search, between students admitted before and after the July 2026 DHS Duration of Status final rule was scheduled to take effect. With web search, only 3 of 25 did (see Example 1).

The takeaway: users should verify anything touching on recent policy against primary sources such as USCIS.gov, the Federal Register, or current agency guidance, whether or not the tool searches the web.

2025–2026 Policy CriteriaPass rate on criteria citing a 2025 or 2026 rule, against all other criteria
Immigration Bench•Oct 28, 2026
Pass rate
Criteria:
Claude Fable 5.1
73.4%
18.5%
Claude Opus 5.5
70.4%
18.5%
Wonder Full
69.1%
9.2%
Qwen 3.8 Max
68.4%
4.6%
Wonder
67.8%
4.6%
Grok 4.7
66.7%
6.2%
Claude Sonnet 5.5
66.5%
12.3%
MiMo V2.6 Pro
66.1%
6.2%
Gemini 4 Argon
66.0%
4.6%
Kimi K3
65.8%
6.2%
GLM 5.3
65.1%
3.1%
GPT-6.1 Sol
65.0%
12.3%
GPT-6 Astra
64.8%
13.8%
DeepSeek V4.1 Flash
64.3%
3.1%
Muse Spark 1.2
64.3%
6.2%
Grok 4.6
63.5%
4.6%
Muse Spark 1.3
62.6%
4.6%
Muse Spark 1.3 Max
62.4%
4.6%
Gemini 3.8 Flash
61.6%
3.1%
GPT-6 Luna
60.8%
10.8%
Mistral Large 4
60.3%
7.7%
DeepSeek V4 Pro 0813
59.5%
3.1%
Claude Haiku 5.5
58.2%
10.8%
MiniMax-M3
56.5%
1.5%
Gemini 3.5 Flash Lite
51.8%
3.1%
Rows are ranked by pass rate on other criteria.Rates cover 1,625 dated and 60,225 other scored checks across 25 models.

Does turning on web search help?

We also tested every model with web search enabled, on the exact same questions and with the same simulated person and grader. Web search helped some models substantially: MiniMax-M3 (an increase of 9.1 points), Claude Haiku 5.5 (an increase of 9.0 points) and DeepSeek V4.1 Flash (an increase of 8.3 points). For 7 of the 25 models run with search, it added less than two points, including Claude Fable 5.1 (1.2 points).

No Search vs. Web SearchSame model, same questions: average answer accuracy on every question
Immigration Bench•Oct 28, 2026
Answer accuracy
Run:
Qwen 3.8 Max
70.1%
77.5%
Claude Fable 5.1
75.4%
76.6%
Wonder Full
71.2%
76.3%
Claude Opus 5.5
72.1%
75.1%
Claude Sonnet 5.5
69.0%
74.3%
Grok 4.7
68.0%
74.1%
DeepSeek V4.1 Flash
65.6%
73.9%
Wonder
69.6%
73.8%
GLM 5.3
66.7%
73.7%
MiMo V2.6 Pro
67.5%
72.3%
Grok 4.6
66.0%
72.1%
Mistral Large 4
63.7%
71.5%
Claude Haiku 5.5
61.8%
70.8%
Muse Spark 1.3 Max
64.9%
70.8%
Muse Spark 1.3
65.0%
70.4%
Muse Spark 1.2
66.5%
70.2%
Gemini 4 Argon
68.1%
70.0%
GPT-6.1 Sol
67.8%
69.2%
Kimi K3
68.3%
69.1%
GPT-6 Astra
67.7%
68.8%
DeepSeek V4 Pro 0813
61.7%
68.2%
MiniMax-M3
57.5%
66.6%
Gemini 3.8 Flash
63.4%
65.0%
GPT-6 Luna
62.5%
64.3%
Gemini 3.5 Flash Lite
55.7%
58.5%
Search scores are not on the leaderboard. As on the leaderboard, a conversation that did not finish scores 0.

By persona, web search helped most on Employer questions, adding 10.4 points on average, adding 6.0 points for University Advisor questions, the next largest, and 1.6 points for International Student questions. Models searched in nearly every conversation (98.9%), but how much they searched did not predict how much they gained: GPT-6 Luna averaged over 100 searches per conversation and gained only 1.8 points, while DeepSeek V4 Pro averaged about 10 searches and gained 6.5 points.

Web Search Gains by PersonaAverage answer accuracy across 25 models
Immigration Bench•Oct 28, 2026
Answer accuracy
Run:
Employer
64.6%
74.9%
University Advisor
48.5%
54.6%
Self-Petitioner
63.6%
69.0%
Entrepreneur
64.2%
69.1%
International Scholar / Faculty
66.7%
70.4%
Fragile / Temporary Status
51.1%
54.6%
International Student
85.6%
87.1%
Each model is compared with itself on every question, an unfinished conversation scoring 0, then averaged across the 25 models.Rows are sorted by gain.
Web Search Gains by Model and PersonaPoints each model gained or lost with web search, by persona
Immigration Bench•Oct 28, 2026
With search:
LostGained
Web Search Gains by Model and Persona
ModelsInternational StudentInternational Scholar / FacultyEmployerEntrepreneurSelf-PetitionerFragile / Temporary StatusUniversity AdvisorAll questions
Mean gain+1.6+3.7+10.4+4.9+5.4+3.4+6.0+4.7
Claude Fable 5.1-1.00.0+4.8+0.1+4.1+2.4-0.1+1.2
Claude Opus 5.50.0-2.1+2.3+9.4+5.1+3.9+4.6+3.0
Wonder Full+1.2+1.2+8.2+4.2+10.7+5.9+7.6+5.1
Qwen 3.8 Max+3.5+4.0+16.8+2.7+7.5+10.1+10.7+7.4
Wonder-0.1+0.5+12.1+5.1+7.7+5.6+2.4+4.2
Claude Sonnet 5.5+2.0+6.7+7.7+4.5+10.3+5.2+3.9+5.3
Kimi K3+1.8-5.8+2.1+5.5-1.40.0+2.8+0.8
Gemini 4 Argon+0.4-1.5+10.8+6.5-1.7-0.9+1.0+1.9
Grok 4.7+2.3+4.2+12.1+8.2+7.9+5.9+4.8+6.1
GPT-6.1 Sol-0.5-0.4+6.4-2.6+4.2-1.2+5.3+1.4
GPT-6 Astra-1.9+1.4+2.6-3.8+4.4+2.1+5.9+1.1
MiMo V2.6 Pro+2.1+5.5+9.7+5.5+5.7-0.6+7.6+4.8
GLM 5.3+2.7+4.4+12.4+15.9+4.9+6.0+6.4+7.0
Muse Spark 1.2+2.4+3.7+13.5+0.5+1.0+1.2+4.3+3.7
Grok 4.6+2.1+2.6+14.1+9.7+6.3+1.0+9.9+6.1
DeepSeek V4.1 Flash+0.8+5.1+21.7+9.6+8.4+7.1+11.7+8.3
Muse Spark 1.3+4.8+5.7+9.0+6.1+4.8+1.7+5.6+5.4
Muse Spark 1.3 Max+1.8+12.1+11.6+0.2+5.5+5.5+8.3+5.9
Mistral Large 4+4.2+9.8+10.3+6.5+1.2+7.3+18.9+7.8
Gemini 3.8 Flash-1.5+3.6+2.8+2.0+4.4-1.3+3.2+1.6
GPT-6 Luna+1.0+0.4+10.5-4.9+5.3+1.7-0.8+1.8
Claude Haiku 5.5+4.0+10.7+15.5+9.7+14.6+1.9+10.0+9.0
DeepSeek V4 Pro 0813+1.8+4.4+22.1+6.5-1.0+7.7+8.7+6.5
MiniMax-M3+5.2+7.4+19.8+10.9+10.1+8.0+5.2+9.1
Gemini 3.5 Flash Lite+0.4+8.9+0.1+5.1+4.4-0.3+3.1+2.8
Rows are ranked by score without search.Each model is compared with itself on every question, an unfinished conversation scoring 0, shaded fully at ±22 points.

Two examples illustrate the difference with web search. In March 2026, ICE reclassified a failure to check the alternative procedure box when using remote I-9 verification as a substantive violation subject to immediate fines. Asked by an employer in exactly that situation, no model mentioned the March 2026 change without web search, and 9 of 25 met the rubric item with web search.

In August 2026, the Board of Immigration Appeals ruled that travel on advance parole can trigger the 3- and 10-year unlawful presence bars. Asked about the risks of traveling abroad on TPS, no model mentioned the decision without search, and 19 of 25 did with search (see Example 3).

The tradeoff is time. Web search makes conversations significantly longer as models search and retrieve pages before responding. The difference is vast: Claude Opus 5.5 and Claude Sonnet 5.5 took a median of about an hour per conversation with web search (70 minutes and 63 minutes respectively), compared to 13 minutes and 11 minutes without. Qwen 3.8 Max took 40 minutes, Claude Fable 5.1 took 22 minutes, and Grok 4.7 took 12 minutes. At the fast end, Kimi K3 and Gemini 3.5 Flash Lite finished in under two minutes. For a person waiting on an answer, an hour-long conversation may not be practical, regardless of how accurate the answers turn out to be.

Search helped most on recent policy: every model met more of the 2025 and 2026 rubric items with web search, but even the best model reached only 43.1% on those items. The takeaway: web search is not a reliable fix for the knowledge gaps these models have on immigration law.

2025–2026 Policy Criteria With Web SearchPass rate on dated and all other criteria, with and without web search
Immigration Bench•Oct 28, 2026
Pass rate
Criteria:
Run:
Qwen 3.8 Max
74.3%
68.4%
43.1%
4.6%
Claude Opus 5.5
71.6%
70.4%
43.1%
18.5%
Claude Haiku 5.5
66.5%
58.2%
41.5%
10.8%
Claude Sonnet 5.5
70.4%
66.5%
40.0%
12.3%
Claude Fable 5.1
73.3%
73.4%
38.5%
18.5%
Mistral Large 4
69.3%
60.3%
35.4%
7.7%
MiMo V2.6 Pro
69.8%
66.1%
35.4%
6.2%
DeepSeek V4.1 Flash
70.6%
64.3%
33.8%
3.1%
GLM 5.3
70.1%
65.1%
32.3%
3.1%
Muse Spark 1.3 Max
68.6%
62.4%
30.8%
4.6%
Gemini 4 Argon
66.4%
66.0%
26.2%
4.6%
Kimi K3
65.6%
65.8%
26.2%
6.2%
GPT-6 Luna
61.0%
60.8%
26.2%
10.8%
DeepSeek V4 Pro 0813
64.7%
59.5%
24.6%
3.1%
Grok 4.6
68.7%
63.5%
24.6%
4.6%
Wonder
70.2%
67.8%
24.6%
4.6%
Muse Spark 1.3
67.5%
62.6%
24.6%
4.6%
GPT-6 Astra
66.5%
64.8%
24.6%
13.8%
GPT-6.1 Sol
66.2%
65.0%
24.6%
12.3%
Grok 4.7
71.5%
66.7%
23.1%
6.2%
Wonder Full
72.8%
69.1%
23.1%
9.2%
Muse Spark 1.2
67.6%
64.3%
23.1%
6.2%
MiniMax-M3
63.1%
56.5%
23.1%
1.5%
Gemini 3.5 Flash Lite
54.7%
51.8%
13.8%
3.1%
Gemini 3.8 Flash
63.0%
61.6%
7.7%
3.1%
Rows are ranked by pass rate on 2025–26 rules with search.Search scores are not on the leaderboard; each model is paired with itself on the test set.

Longer answers explain part of the web search ranking. The rubric credits every item a model covers, so an answer that says more has more chances to meet items. Comparing each conversation with what the same model usually writes on the same question, an answer twice as long scored about 2.6 points higher without web search and 4.2 points higher with it.

Without search, adjusting for this barely changes the leaderboard: no model moves by more than 2 points, and Claude Fable 5.1 stays first. With search it matters more. As scored, Qwen 3.8 Max leads with search (77.5%), ahead of Claude Fable 5.1 (76.6%) and Wonder Full (76.3%). Qwen’s answers with search run about half again as long as other models’ on the same questions and Fable’s about a third longer, while Wonder Full’s are average length, so after adjusting for length Wonder Full leads: 1.3 points ahead of Qwen and 1.4 ahead of Fable. The most verbose models with search, Qwen 3.8 Max, Mistral Large 4 and MiniMax-M3, lose 2 to 3 points each. Some of that extra length is legitimately covering more of what an expert expects, so this is not a corrected ranking, but differences of a point or two between scores with web search partly reflect how much each model writes.

Longer answers score higher, more so with web search: score versus expected plotted against answer length relative to what the same model usually writes on the same question

What models looked up. With web search on, models searched autonomously — choosing which websites to visit without any specific direction. Most models read at least one web page, drawn mostly from official sources: government agencies and the regulations themselves made up about two-thirds of what they read. Content from USCIS appeared in nearly half of all conversations. Models gravitated toward different sources depending on the question type — on International Student questions, models most often turned to the Department of Homeland Security’s (DHS) Study in the States website, and on University Advisor questions they most often consulted the regulations directly.

Did it matter which website? Mostly not. No website was associated with reliably higher scores across the benchmark. The only persona-level exceptions were small: answers that drew on DHS’ Study in the States scored about 2 points higher on International Student questions, and answers that drew on the Code of Federal Regulations scored about 4 points higher on Fragile or Temporary Status questions. With this many comparisons, isolated differences should be interpreted cautiously.

The charts below show which websites models read most often and whether reading each site was associated with higher or lower scores — across all questions.

Websites models read most often with web search, across all questions, with the score difference when each site was read

The next chart shows the same breakdown for International Student questions only, where Study in the States was read in 42% of conversations — far more often than any other site (the next, the Code of Federal Regulations, was read in 26%). A full breakdown of sources read by persona is available in the Appendix.

Websites models read most often on International Student questions, with the score difference when each site was read

Cost and speed matter too

Cost does not have to mean a large drop in quality for some models.

The top-ranked model, Claude Fable 5.1, costs roughly $2.11 per question. Lower-cost models from U.S. developers come within 7.4 to 8.9 points of it for a fraction of the price: Grok 4.7 and GPT-6.1 Sol score 68.0% and 67.8% for about 24 cents a question, nearly nine times cheaper, and Muse Spark 1.2 scores 66.5% for under 4 cents, more than 50 times cheaper. That makes them practical options for legal aid organizations, nonprofits, and others operating on limited budgets. The steep drop comes at the very cheapest tier: on Fragile/Temporary Status questions, Gemini 3.5 Flash Lite scored 38.9%, against 63.9% for Claude Fable 5.1 — a 26-point gap for the population that can least afford bad advice.

Tokens & Accuracy
Pinch or Ctrl/Cmd + scroll to zoom. Once zoomed, scroll or swipe with two fingers to pan, or drag to pan. Shift + drag draws a box to zoom into; turn on box zoom to draw one without Shift. Plus and minus keys zoom, arrow keys pan, 0 resets.

Speed is also a practical concern. Latency, the time to complete a whole conversation of up to five exchanges, is shown in the chart below. Claude Fable 5.1 takes about 7 minutes per conversation, and a person seeking help may give up before they receive a complete answer. Muse Spark 1.2, 8.9 points below the top score, finished in about 40 seconds.

Accuracy & Duration
Pinch or Ctrl/Cmd + scroll to zoom. Once zoomed, scroll or swipe with two fingers to pan, or drag to pan. Shift + drag draws a box to zoom into; turn on box zoom to draw one without Shift. Plus and minus keys zoom, arrow keys pan, 0 resets.

A note on cost and token use. AI models charge per token — roughly per word or word fragment — but the number of tokens each model uses to answer the same question varies enormously. This means the sticker price per token can be misleading: what matters for anyone building an immigration tool is the total cost per question, which is price per token multiplied by tokens used. Output tokens per question, including reasoning, vary more than tenfold, from about 6,800 for Muse Spark 1.2 to about 95,000 for Claude Sonnet 5.5 and Claude Haiku 5.5. Claude Opus 5.5 charges less than half as much per token as Claude Fable 5.1, yet it costs nearly the same per question ($2.16 for Opus 5.5 vs. $2.11 for Fable 5.1), because it uses about two and a half times as many output tokens. Opus also scores 3.3 points lower than Fable. More tokens, it turns out, do not buy a better answer.

The free and low-cost models most people reach first

Most people who ask an AI about immigration will not pay $2 a question; they use free models. About half of U.S. adults now use AI chatbots, and 60% say they read the AI summaries at the top of search results, according to the Pew Research Center. The chatbots they use most are ChatGPT (44% of U.S. adults), Gemini (24%), Copilot (17%) and Meta AI (14%). Worldwide, Google reports that AI Overviews in Search reaches more than 2.5 billion people a month. We could not test these products directly: they add their own instructions and search, and the companies do not disclose which model serves each answer. We did test the low-cost models these companies sell through their APIs.

Their results are a step below the top of the board. Of the nine models from U.S. and European developers that cost under 20 cents a question, the best without web search scored 66.5% (Muse Spark 1.2), 8.9 points behind Claude Fable 5.1, and the weakest scored 55.7% (Gemini 3.5 Flash Lite), last of all 25 models. On questions from people with Fragile or Temporary status, they scored 38.9% to 54.5%, against 63.9% for Fable.

Web search did little for Google’s low-cost models. Gemini 3.5 Flash Lite, the weakest of this group, and Gemini 3.8 Flash scored 55.7% and 63.4% without search and gained only 2.8 and 1.6 points with it. With search, they met just 13.8% and 7.7% of rubric items on 2025 and 2026 rules, the lowest of the 25 models. Meta’s Muse Spark models, which answer in under two minutes, scored 64.9% to 66.5% without search and about 70% with it. With search, the best of the group was Grok 4.6 (72.1%), and Claude Haiku 5.5 gained the most from search (9.0 points).


What This Means for the Immigration Community

  • For immigration attorneys: AI can assist with general research and drafting, but should not be relied on to independently advise clients on their specific situation. The gaps in applying the law to a client’s facts are particularly concerning.
  • For universities’ international offices: AI performed the worst on the University Advisor persona – questions from school officials advising students – which carry the longest rubrics in the benchmark. Before relying on AI for compliance guidance, Designated School Officials (DSOs) should test it against their most common scenarios and verify its answers against government guidance and the institution’s legal counsel.
  • For employers and HR teams: AI performed in the mid-range on Employer questions, and web search helped more on these than on any other persona. It may be useful for general orientation to a visa category, but should not substitute for counsel on specific sponsorship decisions or compliance requirements.
  • For legal aid organizations: Of the seven personas, individuals with Fragile or Temporary Status ranked second lowest, just above University Advisors. This benchmark gives concrete evidence of the risks when clients rely on AI for immigration guidance, and a basis for educating them about those risks.

What This Means for AI Labs

This benchmark gives every lab whose model was tested a concrete, evidence-based picture of where it stands. These findings demonstrate the need for progress on at least three fronts:

  • Prioritize keeping models current in fast-moving regulatory domains. Immigration law changes constantly, through executive orders, agency policy memos, court decisions, and rulemaking. Models met only 7.3% of rubric items involving rules from 2025 and 2026, and web search only partly closed that gap. Improvements could include more retrieval-augmented tools, real-time policy feeds, and clear disclosures when a model’s knowledge may be out of date.
  • Improve how models apply the law to a person’s situation, not just explain it. Knowing the law is not enough; the gap that matters is between explaining a general rule and working out what it means for the specific individual asking. That is where AI falls short most often, and where improvement would have the greatest impact. As in other domains, there is a need for improving how models identify what they need to know about a person’s situation before giving advice, and how they apply general rules to specific circumstances.
  • Engage with experts to expand training data access. Much of the knowledge reliable immigration advice depends on is not publicly available in formats AI systems can use. Closing this gap requires proactive collaboration between labs and the immigration legal community on data-sharing arrangements and retrieval-grounded tools.

Methodology

This benchmark was designed to reflect how real people interact with AI on immigration questions, not how researchers in a lab might test a model.

Scoring rubrics

For each question, experts wrote a rubric, which consisted of a checklist of everything a complete and accurate answer must cover: the key legal thresholds, factual elements, recommended next steps, and statements a model should explicitly avoid saying (such as guaranteeing an outcome). All rubrics were cross-reviewed by a second expert before being used. Rubric items were grouped by type into actions a model should confirm about the individual’s situation, points it should explain or recommend, and statements it should avoid — categorized automatically based on each item’s leading verb. Items that only list legal authorities are recorded but not scored.

MetricDefinition
Average Answer AccuracyShare of each question’s rubric items met, averaged over questions
All-PassShare of questions where every rubric item was met

Evaluation pipeline

Rather than asking each model a single question, we simulated a realistic conversation of up to five exchanges. The benchmark uses three models in different roles:

  1. Tested model: receives the question and tries to help.
  2. Simulated person: GPT-6 Luna plays the person asking, given the persona’s facts and background, and answers the tested model’s follow-up questions from those facts only. GPT-6 Luna is also one of the tested models — a limitation that is discussed below. It was chosen from three finalists: Claude Haiku 4.5, GPT-6.1 Sol and GPT-6 Luna. When two AI judges checked individual replies against each persona’s facts, Claude Haiku 4.5 invented facts about its own case in 42–48% of replies, against 1–3% for GPT-6.1 Sol and 4–10% for GPT-6 Luna, making Claude Haiku 4.5 unsuitable. Blind comparisons of full conversations, rated by two panels of AI judges and by a member of our team, rated GPT-6.1 Sol more realistic than GPT-6 Luna (the team member rated it 11 to 4, with 3 ties). We chose GPT-6 Luna because it was nearly as faithful to the persona’s facts, did not artificially inflate scores by asking leading questions, and cost about a twentieth as much per conversation.
  3. Grader: Claude Sonnet 5 evaluates every rubric item as met or not met against the full transcript, with a reason. It was selected through alignment testing with human experts: two immigration experts independently graded the same conversations, and on the rubric items where they agreed, Claude Sonnet 5 matched their verdict 88.6% of the time, the highest of the graders tested.

An item counts as met if the model covers it anywhere in the conversation, not just in its first response. Every model was run twice: once on its own, and once with web search, which could access pages published up to September 21, 2026, the date the question set was finalized. Each conversation had a 30-minute time limit, or three hours with web search; a conversation that exceeded its limit scored zero, and comparisons with and without web search use the questions a model finished in both conditions. Conversations that failed for infrastructure reasons, including grading failures, were re-run. Models were accessed through their providers’ APIs at default settings.

Uncertainty

Average answer accuracy carries a standard error of 1.4 to 1.7 points, so small differences between closely ranked models should be interpreted cautiously. Per-persona scores carry more uncertainty, roughly 2 to 6 points, and should be read as indicative rather than definitive.

Limitations

  • The simulated person is an AI model. How it answers and follows up affects what the tested model can draw out. In testing, swapping the simulated person shifted scores by a few points and reordered some closely ranked models.
  • The simulated person is also a tested model. GPT-6 Luna plays the simulated person in every conversation and is also one of the 25 tested models, so in its own conversations it is talking to itself, which may affect its score.
  • The grader is an AI model. Claude Sonnet 5 agreed most closely with human expert graders, but it is from the same developer as four tested models.
  • The rubric measures completeness, not harm. A response is credited for each item it meets. It is not penalized for additional incorrect statements unless the rubric includes an explicit “avoid” criteria. Longer answers also have more chances to meet items; with web search this explains part of the ranking (see “Does turning on web search help?”).
  • Some groupings are automatic. Recent-rule items were identified by whether the item cites 2025 or 2026, and item types were grouped by the item’s first word.
  • Results are a snapshot. Models, their default settings, and immigration law all change. Each model was run once per condition through its API; consumer-facing products were not tested, and may produce different results by adding their own system instructions or search capabilities.

Example Questions and Scoring

The following nine questions from the test set illustrate how models performed across different scenarios — each shown with an excerpt of the expert rubric and how many of the 25 models met each item, with and without web search. Scores are on the full rubric, so item counts in the text can exceed the rows shown.

Example 1Models missed a recent policy change
International Student

Q: Everyone keeps talking about D/S [Duration of Status] ending. How does that affect me?

A complete answer needed to give the historical meaning of D/S, explain that based on the July 2026 Duration of Status rule, the answer depends on when the student was last admitted to the United States, and distinguish students admitted before September 15, 2026 from those admitted under the new fixed-period framework. Every model explained what D/S used to mean, but without web search none distinguished students admitted before and after the rule was scheduled to take effect; with search, 3 of 25 did. No model met every item. The best scores were 78% without search (Claude Fable 5.1, Claude Haiku 5.5, Grok 4.7) and 89% with search (Claude Haiku 5.5, GPT-6 Astra), while the average was 55% both without and with web search.

Run:
No searchWeb search
Expert rubric item
Recognize that the answer depends primarily on when the student was most recently admitted to the United States, because the applicable admission framework differs before and after implementation of the DHS Final Rule published on July 17, 2026, effective September 15, 2026.
1 of 25 without search, 2 of 25 with search
Explain the historical meaning of Duration of Status (D/S) and how it governed F-1 admissions before implementation of the Final Rule.
25 of 25 without search, 25 of 25 with search
Distinguish between students admitted before September 15, 2026 under the D/S framework and students admitted on or after September 15, 2026 under the new fixed-period admission framework.
0 of 25 without search, 3 of 25 with search
Explain that students admitted under the new framework generally receive an Admit Until Date on the Form I-94 rather than D/S.
18 of 25 without search, 23 of 25 with search
Clarify that the Form I-94 establishes the student's authorized period of admission, while the Form I-20 documents the academic program and supports admission and, where applicable, future extension-of-stay requests.
17 of 25 without search, 14 of 25 with search
Explain that maintaining F-1 status continues to require compliance with all regulatory requirements regardless of whether admission occurred under D/S or the fixed-period framework.
9 of 25 without search, 9 of 25 with search
Warn against relying on pre-September 15, 2026 guidance without determining which admission framework applies
9 of 25 without search, 2 of 25 with search
Recommend reviewing the Form I-94 and Form I-20 after arrival and consulting the DSO promptly if there are questions regarding the authorized admission period.
23 of 25 without search, 24 of 25 with search
Recognize that additional facts, including the student's admission date, Form I-94, and travel history, may materially affect the analysis.
21 of 25 without search, 21 of 25 with search
Example 2One model significantly outperformed the rest
University Advisor

Q: Do you sign the I-20 for a student who is not yet enrolled in the next available term?

A complete answer needed to explain that not yet being registered doesn’t by itself bar a DSO from signing, and then lay out what the DSO must check and document before signing. Every model got the first point, but fewer covered what the DSO must check and document: items on checking the student’s SEVIS status, handling holds, and documenting the decision were met by only 3 to 9 models without web search. Claude Fable 5.1 met 14 of the 15 items (93%), missing only one tied to the September 2026 admission rules that no model met; the next best model, Claude Opus 5.5, scored 67%, and the average was 49%. With web search the lead disappeared: Fable scored 53%, and DeepSeek V4 Pro led at 87%, just ahead of Opus at 80%.

Run:
No searchWeb search
Expert rubric item
Explain that a DSO is not categorically prohibited from signing a continuing student's Form I-20 merely because the student has not yet registered for the next term.
25 of 25 without search, 24 of 25 with search
Confirm the student's current SEVIS status, program end date, academic standing, expected return date, next required term, eligibility to register, and intent to resume a full course of study.
9 of 25 without search, 8 of 25 with search
Clarify that an institutional academic or financial hold does not automatically make a travel endorsement improper, but the DSO should determine whether the hold makes the student unable or unlikely to resume the program.
3 of 25 without search, 5 of 25 with search
Confirm that substantive changes involving the student's program, school, degree level, funding, or personal information are properly reported and reflected on an updated Form I-20 before travel.
3 of 25 without search, 9 of 25 with search
Explain that the travel endorsement confirms the DSO's recommendation that the student is eligible to return to continue the program; it does not guarantee visa issuance, admission by CBP, registration, or restoration of status.
4 of 25 without search, 1 of 25 with search
Example 3Web search caught a new court decision
Fragile / Temporary Status

Q: I am in the United States on TPS and want to accept a promotion that would require me to travel internationally. What risks are there to traveling internationally on TPS?

In August 2026, the Board of Immigration Appeals ruled in Matter of Delcarmen-Lara that travel on advance parole can trigger the 3- and 10-year unlawful presence bars, overruling a 2012 decision. The rubric expected a complete answer to flag that the ruling adds uncertainty for travel on a TPS travel document. Without web search, no model mentioned the decision, and two models, Qwen 3.8 Max and Gemini 4 Argon, cited the overruled 2012 decision as current law. With web search, 19 of 25 mentioned the decision, and 17 met the full rubric item, which also required the model to stress that readmission is never guaranteed. The average score with web search rose from 56% to 72%.

Run:
No searchWeb search
Expert rubric item
Confirm the country of birth and citizenship/nationality or if stateless, country of last habitual residence
3 of 25 without search, 7 of 25 with search
Clarify when and how the individual entered the U.S. (with or without inspection)
11 of 25 without search, 16 of 25 with search
Determine whether the individual appears eligible for continued TPS based on current Federal Register notices and any applicable litigation
10 of 25 without search, 12 of 25 with search
Provide information about Form I-131 to apply for a TPS travel document
25 of 25 without search, 25 of 25 with search
Emphasize the importance of working with an attorney through the process
25 of 25 without search, 25 of 25 with search
Advise that travel and return is only permitted with an I-512T (TPS travel document)
23 of 25 without search, 25 of 25 with search
Caution that if the individual's TPS designation is terminated or a court vacates or stays a related TPS decision while the individual is abroad — whether by Federal Register notice or ongoing litigation — the individual may be found ineligible for TPS admission upon return even with a valid, unexpired I-512T
14 of 25 without search, 16 of 25 with search
Stress that admission to the United States is never guaranteed. Every returning individual is subject to inspection and the discretionary determination of a Customs and Border Protection officer at the port of entry, who may deny admission, refer the individual to secondary inspection, or initiate removal proceedings. A recent BIA decision adds further uncertainty as to whether travel after August 13, 2026 on a TPS travel authorization will trigger unlawful presence bars.
0 of 25 without search, 17 of 25 with search
Example 4Every model struggled
Self-Petitioner

Q: Does an NIW allow me to work in multiple roles or industries?

A complete answer needed to ask what the person means by multiple roles, explain that an NIW rests on a single proposed endeavor of national importance, warn that combining several roles or industries into one endeavor can be hard, and note that a unique combination of skills can strengthen the case. No model met every item, with or without web search, and none made the point about a unique combination of skills. The best models scored 75%: Claude Sonnet 5.5, DeepSeek V4.1 Flash, Grok 4.6 and Wonder without search, and nine models with search. The average was 33% without search and 44% with, among the lowest of any question in the benchmark.

Run:
No searchWeb search
Expert rubric item
Confirm whether (a) the self-petitioner intends to base the NIW filing on multiple roles or industries or (b) that this question relates to what the beneficiary can do after the NIW is approved
10 of 25 without search, 13 of 25 with search
Explain that an NIW requires a proposed endeavor that describes the type of work the self-petitioner intends to undertake within an occupation and the proposed endeavor must have national importance.
16 of 25 without search, 18 of 25 with search
Stress that integrating multiple roles or industries into one proposed endeavor that has national importance could be a challenge.
7 of 25 without search, 13 of 25 with search
Clarify that, with a well-defined endeavor, a unique combination of skills or knowledge might support a finding that the self-petitioner is well-positioned to advance a proposed endeavor and that the labor certification process would not produce someone with those skills and knowledge.
0 of 25 without search, 0 of 25 with search
Example 5Nearly every model answered fully correctly
International Student

Q: Am I considered "undocumented" if I stay in the U.S. after my visa expires if my I-20 and I-94 are still valid?

A correct response needed to distinguish an F-1 visa from the period of admission on Form I-94 and from ongoing maintenance of status, and to avoid calling the student undocumented. Every model but one (Grok 4.6) met every item without web search.

Run:
No searchWeb search
Expert rubric item
Recognize that expiration of an F-1 visa does not, by itself, mean the student is undocumented or unlawfully present in the United States.
25 of 25 without search, 25 of 25 with search
Distinguish between the validity of an F-1 visa, the student's authorized period of admission reflected on the Form I-94, and the student's ongoing maintenance of F-1 status.
25 of 25 without search, 25 of 25 with search
Explain that an F-1 visa is generally required only to seek admission to the United States and may expire while the student lawfully remains in the country.
25 of 25 without search, 25 of 25 with search
Explain that a student who continues to maintain valid F-1 status during an authorized period of admission generally may remain in the United States even after the visa expires.
25 of 25 without search, 25 of 25 with search
Recognize that an expired visa generally becomes significant only when the student departs the United States and later seeks readmission, unless another immigration issue exists.
25 of 25 without search, 25 of 25 with search
Recommend reviewing the student's Form I-94, maintenance of status, and future travel plans before determining whether any additional immigration action is required.
24 of 25 without search, 24 of 25 with search
Avoid equating visa expiration with loss of immigration status or characterizing the student as undocumented solely because the visa has expired.
25 of 25 without search, 25 of 25 with search
Recognize that additional facts, including the student's admission framework (D/S or fixed-period admission), Form I-94, maintenance of status, and planned international travel, would materially affect the analysis.
25 of 25 without search, 25 of 25 with search
Example 6Most models got a technical rule right
International Scholar / Faculty

Q: Research Assistant positions are only covered by the TN Visa if they are in a post-secondary educational institution. What if an employer affiliated with a university, is there a possibility that it might still be accepted at the border?

Most models handled this question well: without web search the average was 79% and six models met every item; with search the average was 88% and eight models met every item. Nearly all explained that an affiliation with a university is not enough by itself, and that the actual employer and its ties to the university decide whether the position qualifies.

Run:
No searchWeb search
Expert rubric item
Confirm that the USMCA TN profession of Research Assistant is expressly limited to a research assistant working in a postsecondary educational institution.
21 of 25 without search, 25 of 25 with search
Confirm that the applicant must be a Canadian or Mexican citizen and ordinarily must possess a Baccalaureate or Licenciatura degree.
13 of 25 without search, 14 of 25 with search
Distinguish a university or qualifying institutional component from a legally separate company, hospital, laboratory, or research organization that merely has an affiliation agreement with a university.
23 of 25 without search, 25 of 25 with search
Explain that affiliation alone does not establish eligibility, but the complete institutional relationship should be evaluated rather than relying solely on the employer’s name.
23 of 25 without search, 25 of 25 with search
Identify the legal employer, payroll entity, governance, ownership or control, university appointment, institutional agreements, supervision, worksite, funding, and integration into the university’s educational or research functions as potentially relevant evidence.
21 of 25 without search, 25 of 25 with search
Explain that Canadian citizens generally may request TN admission from CBP at a port of entry, while Mexican citizens generally require a TN visa before seeking admission; either process requires proof that the position and applicant satisfy the listed profession.
18 of 25 without search, 17 of 25 with search
Consider whether another USMCA-listed profession accurately matches the actual duties and credentials, but warn against relabeling the position solely to obtain TN classification.
14 of 25 without search, 16 of 25 with search
Explain that an application may be refused if the evidence does not establish that the employment is in a postsecondary educational institution, and that a port-of-entry determination should not be described as guaranteed or merely discretionary.
22 of 25 without search, 25 of 25 with search
Recommend obtaining institutional documentation, a detailed employer support letter, and qualified immigration review before applying.
23 of 25 without search, 25 of 25 with search
Example 7Web search filled in state law
Employer

Q: I'm wondering if it is acceptable to have our international faculty sign retention/claw-back agreements when the university sponsors them for permanent residency? The agreement would require the faculty member to repay any legal and filing fees we paid if they resigned from their position before the expiration date of the agreement. The length of the agreement is based upon the costs we are paying.

Most models said state law could limit an agreement like this, but without web search, only 7 met the rubric item, which also asked them to check where the employer is located and flag that certain states have enacted bans; with search, 18 did. Claude Opus 5.5 and Claude Fable 5.1 scored best (80%), and the average rose from 35% to 50% with search.

Run:
No searchWeb search
Expert rubric item
Distinguish between various types of permanent residence, including PERM-based categories (EB-2 and 3) and EB-1A, EB-1B, and EB-2 NIW.
1 of 25 without search, 3 of 25 with search
Explain that the employer is prohibited from seeking payment "of any kind" from the employee for costs related to the labor certification process, which is part of the EB-2 and EB-3 application (with the exception of a National Interest Waiver petition)
20 of 25 without search, 23 of 25 with search
Confirm that the same federal rules do not apply to fees associated with EB-1 or NIW cases, which the employee may fully fund
10 of 25 without search, 13 of 25 with search
Caution that an agreement of this type may be challenged under the Trafficking Victims Protection Act (TVPA) or violate certain state laws that prohibit the requiring of employee reimbursement payments if they leave their job
6 of 25 without search, 6 of 25 with search
Verify what state the employer is located and check that state's laws, since several states (California and New York) have already enacted bans and others (Pennsylvania) have legislation pending
7 of 25 without search, 18 of 25 with search
Example 8Models knew the options but missed the details
Entrepreneur

Q: Is there a specific “startup visa” for entrepreneurs?

All but one model (Claude Haiku 5.5) correctly said there is no visa designed for startups and named the main alternatives, and all 25 mentioned international entrepreneur parole. Scores then turned on the details the rubric asked for, such as who files each petition and the EB-5 investment threshold: only Claude Opus 5.5 met every item, and the average was 49%.

Run:
No searchWeb search
Expert rubric item
Confirm whether the person is a national of a treaty country listed by the Department of State: https://travel.state.gov/content/travel/en/us-visas/visa-information-resources/fees/treaty.html.
9 of 25 without search, 9 of 25 with search
Confirm how much money the person is actively investing in his company and the source.
7 of 25 without search, 11 of 25 with search
Advise that there is not a visa designed specifically for startup entrepreneurs, but there are options, such as E-2, H-1B, O-1, and international entrepreneur parole.
24 of 25 without search, 25 of 25 with search
Emphasize that the business as a separate legal entity must file the petition for an O-1, and H-1B, but an individual can apply for an E-2.
4 of 25 without search, 5 of 25 with search
Advise that while not a visa, international entrepreneur parole is an option for individuals who have secured the requisite amount of outside funding.
22 of 25 without search, 25 of 25 with search
Caution that international entrepreneur parole can only be renewed once, for a total of 5 years.
20 of 25 without search, 23 of 25 with search
Explain that if the person is actively investing at least $800,000 and will create at least 10 jobs in 2 years, an EB-5 immigrant visa might be an option.
6 of 25 without search, 4 of 25 with search
Explain that all other types allow a person to come to the U.S. temporarily, but the EB-5 is an option that can lead to permanent residence
6 of 25 without search, 10 of 25 with search
Example 9Models missed the practical catch
Self-Petitioner

Q: Can I qualify for EB-1A as a postdoc?

Nearly every model explained the sustained-acclaim standard and that accomplishments matter more than a job title. Few models warned that USCIS has treated postdoc positions as entry-level, which cuts against being at the top of the field, and only Qwen 3.8 Max and Wonder pointed out that a postdoc does not need the leading-role criterion if three others are met. Qwen 3.8 Max met every item; the average amongst the models was 53% without web search, and web search barely changed it (55%).

Run:
No searchWeb search
Expert rubric item
Explain that the statute requires “sustained acclaim” and being at the top of the field.
23 of 25 without search, 23 of 25 with search
Caution that USCIS has generally viewed a postdoc position as entry-level, which is inconsistent with being at the top of the field.
3 of 25 without search, 2 of 25 with search
Clarify that while it may be challenging to meet the leading or critical role criterion with a postdoc position, USCIS cannot require that a person meet a specific criterion provided the person meets at least three other criteria.
2 of 25 without search, 5 of 25 with search
Emphasize that whatever position the person holds, at issue is what the person has accomplished and their recognition in the field as demonstrated by meeting at least three of the regulatory criteria and through a showing of acclaim when considering the evidence in its totality.
25 of 25 without search, 25 of 25 with search

Conclusion

This benchmark is a first step, not a final word. Our goal is not to discourage the use of AI in immigration; it is to ensure that AI is used responsibly, with a clear understanding of where it falls short and what is at stake when it does. AI has real potential to expand access to immigration information, but only if it is accurate. Right now, the gaps are too significant to rely on AI alone for anything but general orientation.

AI is most reliable on settled, foundational law. It is least reliable on recent policy changes, on questions that require applying the law to a specific person’s facts, and for people with fragile or temporary status. Closing those gaps will take AI labs, legal practitioners, policymakers, and other stakeholders working together to build tools tested against the questions real people actually ask.

This benchmark exists because a team of immigration experts wrote 519 questions and cross-reviewed every rubric. We are grateful for their work.

Citation

Talent Mobility Fund and Vals AI, Can AI Get Immigration Right? An Independent Evaluation of AI Performance on U.S. Immigration Law Questions, October 2026. https://vals.ai/benchmarks/immigration

Citation (BibTeX)

@misc{immigration2026,
title        = {Can AI Get Immigration Right? An Independent Evaluation
                of AI Performance on U.S. Immigration Law Questions},
author       = {{Talent Mobility Fund} and {Vals AI}},
year         = {2026},
month        = oct,
howpublished = {Vals AI},
url          = {https://vals.ai/benchmarks/immigration},
}

Appendix

For each of the seven personas, the charts below show the websites models read most frequently during web search conversations and the score impact associated with each site.

Chart 1: Employer — Sites Read and Score Impact

Employer: websites read most often with web search and the score difference when each was read

Chart 2: Entrepreneur — Sites Read and Score Impact

Entrepreneur: websites read most often with web search and the score difference when each was read

Chart 3: Self-Petitioner — Sites Read and Score Impact

Self-Petitioner: websites read most often with web search and the score difference when each was read

Chart 4: University Advisor — Sites Read and Score Impact

University Advisor: websites read most often with web search and the score difference when each was read

Chart 5: International Student — Sites Read and Score Impact

International Student: websites read most often with web search and the score difference when each was read

Chart 6: International Scholar/Faculty — Sites Read and Score Impact

International Scholar / Faculty: websites read most often with web search and the score difference when each was read

Chart 7: Fragile/Temporary Status — Sites Read and Score Impact

Fragile / Temporary Status: websites read most often with web search and the score difference when each was read