Introduction
I’ve already completed the first three steps in this process—drafting proposals, compiling evidence, and formally submitting them to the U.S. Census Bureau for consideration in the 2027 NAICS revision cycle.
This isn’t theory—it’s already underway.
Creating new official industry classifications—for NAICS 561399, NAICS 611319, and NAICS 518219 - requires a structured process led by the U.S. Census Bureau, the Office of Management and Budget (OMB), and the Economic Classification Policy Committee (ECPC).
Each step demands transparency, evidence, and public participation to ensure accuracy and accountability.
Important: This administrative process does not require congressional or Senate approval. However, congressional support and/or an Executive Order from President Trump can help accelerate adoption and ensure that the proposals are prioritized and implemented efficiently.
Executive Summary
Noncitizen labor, international noncitizen student enrollment, and AI-driven workforce substitution have become massive economic forces — impacting wages, job access, and national security — yet none of these three activities has ever been formally recognized as a distinct U.S. industry.
This plan proposes three new NAICS codes:
- NAICS 561399 – Foreign Labor Placement and Management Services
Captures the placement, management, and payroll handling of ~16.7 million documented non-citizen workers—including H-1B, H-2A/B, EAD, OPT/CPT, green card holders, and offshore contractors.
- NAICS 611319 – International Student Enrollment and Compliance Services
Recognizes the recruitment, admissions processing, SEVIS reporting, and visa compliance oversight of more than 1.5 million international students across U.S. universities.
- NAICS 518219 – Workforce Automation and AI Substitution Services
A framework to address the accelerating displacement of qualified U.S. citizen workers by artificial intelligence, machine learning, robotic process automation, and related technologies.
Classification is Phase 1. Once these sectors are defined, Congress can move to oversight and targeted taxation—ensuring corporations finally bear the true cost of displacing U.S. citizens.
10-Step NAICS Classification Process
1–3 Completed
Step 1: Identify the Classification Gaps
DONE: The process began by recognizing that foreign labor placement and international student enrollment are both large-scale, economically significant activities.
However, these areas are not captured under any current NAICS code. This gap leaves major blind spots in the U.S. workforce, education, and economic data, weakening transparency, accountability, and policymaking.
Step 2: Draft the Proposals
DONE: Detailed proposals were drafted defining NAICS 561399, NAICS 611319, and NAICS 518219. Supporting evidence was compiled from BLS, USCIS, SEVIS, IIE, Pew, and other sources, along with legal and economic references. Proposals were formatted to meet Census Bureau and OMB standards.
Step 3: Submit to the ECPC
DONE: Completed proposal packets were formally submitted to the U.S. Census Bureau, administered through the ECPC, and logged into the 2027 revision cycle.
4–10 Remaining Steps
Step 4: Census Bureau Review & Acknowledgement
The Census Bureau reviews proposals for completeness and scope. Once acknowledged, the proposals officially enter the NAICS revision process.
Step 5: ECPC Analysis & Public Consultation
The ECPC undertakes detailed technical, economic, and statistical analysis. Public consultation allows stakeholders—corporations, universities, economists, and advocacy organizations—to comment.
Step 6: Draft Recommendations
ECPC prepares preliminary recommendations to support, modify, or reject proposals, balancing economic accuracy, coverage, and policy alignment.
Step 7: Public Review & Feedback
Draft recommendations are published in the Federal Register for wider public comment.
Step 8: OMB Final Determination
OMB issues a binding decision on approval, which is then recognized across all federal agencies.
Step 9: Publication in the Federal Register
Approved codes are announced and incorporated into the next NAICS Manual (e.g., 2027 Edition), making them official classification standards.
Step 10: Implementation & Data Integration
Agencies such as BLS, DOL, DHS, IRS, and DoE integrate the new classifications into surveys, workforce tracking, compliance, and enforcement systems. This ensures standardized data collection, more accurate revenue modeling, and stronger transparency in monitoring the impact of foreign labor and international student enrollment on the U.S. economy.
What This Achieves
Formally classifying noncitizen labor placement and international noncitizen student enrollment under NAICS ends the statistical invisibility of these massive sectors and brings them into clear view for the first time.
- Establishes a factual, government-recognized basis for oversight, regulation, and taxation.
- Equips policymakers with the tools to make informed decisions and close loopholes.
- Supports policies that prioritize and protect U.S. citizen workers and students.
Remember: This is a technical, administrative process—no congressional or senate vote is required—but congressional advocacy helps ensure timely adoption and support for future legislation.