An Updated NAICS Framework for Transparency and Accountability
In 2025–2026, noncitizen workers represented approximately 19–20% of the U.S. civilian labor force. Noncitizen workers — including green card holders, temporary visa holders, humanitarian authorizations, and those working via OPT/CPT — continue to play a significant role across key sectors such as professional and business services, manufacturing, trade/transportation, leisure & hospitality, construction, and agriculture (Bureau of Labor Statistics, February 2026).
Meanwhile, approximately 1.18 million international students (F-1, J-1, and related categories) were enrolled in U.S. institutions, with roughly 900,000 participating in work authorization programs.
These activities generated an estimated $44–55 billion in direct and indirect economic activity (IIE Open Doors 2025/2026; NAFSA estimates).In addition, artificial intelligence and automation systems are rapidly substituting for human labor, with an estimated 5.5 million AI labor equivalents already impacting U.S. workplaces in 2026 — a figure projected to grow significantly in the coming years.
Despite their massive economic footprint, noncitizen labor, international student enrollment, and AI-driven workforce substitution currently operate largely within a regulatory and statistical blind spot. Unlike established industries such as finance, manufacturing, or healthcare, these sectors lack dedicated NAICS classification, standardized reporting, and structured oversight.
OnShoringAmerica’s Proposed NAICS Framework
OnShoringAmerica proposes a pragmatic, non-legislative solution to bring transparency and accountability to these three major economic activities by creating three new NAICS codes:
- NAICS 561399 — Foreign Labor Placement and Management Services
- NAICS 611319 — International Student Enrollment and Compliance Services
- NAICS 518219 — Workforce Automation and AI Substitution Services
Important:
These classifications require zero Congressional approval. They can be implemented immediately through administrative action by the U.S. Census Bureau and the Economic Classification Policy Committee (ECPC) under the Office of Management and Budget (OMB). A Presidential Executive Order can prioritize their adoption for the 2027 NAICS revision.
What This Achieves
Adopting these three NAICS codes would establish:
- Structured, standardized data reporting across federal and state agencies
- Full visibility into the scale and sectoral distribution of noncitizen labor, international student enrollment, and AI substitution
- The statistical foundation needed to enforce targeted, fair accountability measures
These codes serve as the critical Phase 1: Transparency foundation for three companion accountability measures (Phase 2):
- U.S. Foreign Labor Levy (4-Pillar, 4-Tier framework)
- U.S. Foreign Student Enrollment Levy (tiered per-student levy on universities)
- U.S. AI Utilization Levy (escalating levy on AI-driven cost savings and labor equivalents, with strong reversal incentives for rehiring qualified American citizen workers)
Conclusion
Noncitizen labor placement, international student enrollment, and AI workforce substitution are multi-billion-dollar economic activities that significantly influence American job opportunities and educational access.
By formally classifying them under NAICS 561399, 611319, and 518219, the United States can bring much-needed transparency, data-driven oversight, and balanced accountability to sectors that have long operated with limited visibility — while strongly prioritizing opportunities for qualified American citizen workers and students.
These NAICS changes can be enacted quickly via Executive Order. Congressional support can help accelerate the adoption and passage of the three companion levy bills, but the industry classification itself does not require legislative approval.