CIO playbook for treating work visas as enterprise risk

Why formalize immigration risk?

There are many reasons why CIOs should consider formalizing immigration as an enterprise risk category.

Formalizing immigration as an enterprise risk transforms an invisible vulnerability into a managed one with proper governance, monitoring and mitigation plans.

Without formalization, organizations face the following:

• Delayed project launches. Teams grounded by visa processing delays can derail critical initiatives.
• Abandoned projects. Inability to fill key positions forces companies to scale back or cancel strategic work.
• Compliance penalties. Violations that never appear in risk reports until it's too late.
• Crisis management. Reactive scrambling instead of proactive planning when policy changes hit.

Consider a financial services company launching a cloud migration with four H-1B developers. Six months in, visa renewals face unexpected delays. Two team members must stop working while applications are pending. The project slips by a quarter. The company misses a regulatory deadline. A visa processing delay becomes an SEC compliance issue.

6-step framework: Making immigration policy an enterprise risk category

For CIOs ready to formalize immigration as an enterprise risk, the following framework provides a systematic approach to integration with existing risk management structures.

Step 1: Define the risk

Start by explaining the immigration risk in business terms that resonate beyond the IT organization. This isn't about visa categories or immigration law; it's about workforce availability, project delivery capability and operational continuity. The global talent risk extends beyond individual visa holders to encompass the organization's ability to access skilled workers worldwide.

"CIOs and IT leaders should look to the dependency of their organization on labor that is composed of individuals needing temporary work visas," said John Connolly, senior managing director at Guidepost Solutions.

Connolly said calculating the amount of time it takes to identify the need for those individuals, completing the application process and onboarding them is a good base metric to follow. Combining this data with project delays caused by insufficiently trained staff reveals the enterprise-wide impact of this dependency.

Step 2: Quantify the exposure

Once the risk is defined, organizations need concrete metrics to measure their vulnerability.

"The simplest and most important metric for quantifying risk exposure is the number of employees and key suppliers who are dependent on a visa," Sarangan said.

Without quantification, immigration remains a theoretical concern rather than a measurable business risk. Manish Jain, principal research director at Info-Tech Research Group, said for many organizations, a key part of quantifying the risk can be done via the following metrics:

• VDR (visa dependency ratio): the percentage of IT workforce on H-1B, L-1B or other visas.
• VDR-C (visa dependency ratio for critical resources).
• VRS (visa renewal success rates).
• TTH (time-to-hire for visa-ready candidates versus local candidates).

"These metrics will help highlight operational exposure and frame immigration policy as a strategic risk impacting talent continuity," Jain said.

Step 3: Assign ownership

Clear ownership is essential for effective risk management. Immigration risk touches multiple departments, making it crucial to establish who has ultimate accountability.

"The greatest implementation challenge is the impact immigration has across the organization because it involves many different areas of the organization in a variety of ways," Connolly said. "To avoid finger-pointing and ensure a coordinated effort, it should be housed under a compliance officer who can engage across these departments and ensure the needs of the organization are met."

However, governance models may vary. Jain said that given this relates to worker mobility, governance should still be led by HR with a cross-functional risk committee, where IT contributes with specific actions around workforce planning for IT-specific resource areas.

Regardless of who owns the risk formally, the CIO must own IT's contribution. This means designating a leadership-level individual to serve as the primary liaison, maintaining current data on visa dependency, and participating in policy development and mitigation planning.

Step 4: Integrate into enterprise risk management framework

Immigration risk policy should be presented in the same locations and processes as other enterprise risks -- including the corporate risk register, regular board briefings, strategic planning sessions and business continuity plans.

"Leaders should also ensure the availability, currency and robustness of business continuity plans for critical functions or processes that are highly dependent on employees or provider staff on visas," Sarangan said.

Work with your enterprise risk management team to determine where immigration risk fits in the existing taxonomy. In many cases, it will be categorized under workforce risk or geopolitical risk. The important thing is that it becomes a permanent, recognized element of the risk landscape.

Step 5: Set governance and monitoring

Establish regular reporting cadences and accountability structures. At a minimum, this should include quarterly updates on key metrics, tracking policy changes, status reports on visa processing for critical roles and assessing emerging risks.

"A key mitigation strategy is planning by knowing when visa authorizations are expiring and when the next wave of visa-approved workers will be arriving," Connolly said. "This helps avoid gaps in your workforce as you move forward."

Step 6: Develop mitigation plans

Once the risk is quantified and governance is established, organizations need concrete strategies to reduce their vulnerability.

"Mitigation strategies can come in all shapes and sizes," Connolly said. "However, visa portfolio diversification, while seeming to be straightforward, is not always that way. Every visa category has different statutory requirements, and they are not always interchangeable."

Jain recommends organizations look at diversification of visa types, nearshoring or friendshoring talent and building contingency plans with contract staffing partners locally and in geographies that have relatively stable trade relations with their HQ country. He cautions that these diversification strategies are easier said than done, especially if you are in the United States, as there are very few countries with which the U.S. has stable trade relations.

Robust business continuity plans would be the primary approach to mitigate or manage any risk, Sarangan said. The cost of specific mitigation strategies should be compared with the cost of a readily deployable business continuity plan, which includes the provider ecosystem.

Role of CIOs and IT leaders

CIOs are well-positioned to drive the formalization of immigration risk. The challenge is building the business case, orchestrating cross-functional collaboration and positioning IT as a proactive risk mitigator.

Building the business case

Getting immigration risk onto the board's agenda requires demonstrating its potential business impact.

"The most effective approach is demonstrating to the board how much of the labor force is composed of temporary visa categories," Connolly said. "This will give them a clear picture of how any change to the immigration policy could ultimately affect the organization."

Going a step further, he advised not to stop at the workforce percentage. Be sure to also provide specific information about one project and demonstrate how a shift in immigration policy will affect this project directly -- whether through implementation delays or not completing the project on time.

"The risk should be a board agenda if the exposure for a specific CIO or enterprise is significant enough, and even if so, it would be a part of the geopolitical risk for the enterprise," Sarangan said.

Jain said CIOs can elevate the issue to the board and executive leadership by linking immigration risk to business continuity planning. Boards understand business continuity. They've seen supply chain disruptions, natural disasters and cybersecurity incidents. Framing immigration risk in those terms makes it tangible and urgent.

Collaborating across functions

Successfully managing immigration risk requires coordination across multiple departments that traditionally operate in silos.

IT must collaborate closely with HR, which owns most immigration processes; legal, which manages compliance; finance, which budgets for immigration costs and understands financial risk; and the enterprise risk management function, which maintains the overall framework.

The CIO's role is to ensure IT's voice is heard in that collaboration and that technology impacts are properly represented in policy decisions. This means educating other functions about how IT operations depend on visa-dependent talent, contributing data and analysis to risk assessments and participating actively in mitigation planning.

"Human resources typically handles the sponsorship of visas," Connolly said. "However, they can't do this without information from IT identifying specific needs, and it must all be done in compliance with regulations, which is where the legal team comes into play."

Positioning IT as proactive

IT is often seen as being reactive on immigration issues, responding to HR requests for headcount justifications or scrambling when processing delays threaten project timelines. Formalizing immigration as an enterprise risk creates an opportunity to reposition IT as a proactive risk manager.

The goal is for the board and executive team to view IT not as a function vulnerable to immigration policy disruptions, but as a function that has identified, quantified and is actively managing that vulnerability as part of its broader operational risk portfolio.

Sean Michael Kerner is an IT consultant, technology enthusiast and tinkerer. He has pulled Token Ring, configured NetWare and been known to compile his own Linux kernel. He consults with industry and media organizations on technology issues.