Project 2025 and Immigration

By Katheryn Olmos, Luc Thomas, Ernesto Castañeda, & Robert Albro*

October 30, 2024

Project 2025 – Mandate for Leadership: The Conservative Promise is a government policy agenda developed by the right-wing think tank, the Heritage Foundation, intended for implementation within the first 180 days of Donald Trump’s potential second presidential term, should he win the 2024 election. This manifesto is 922 pages long and divided into five sections, the first of which is titled “Taking the Reins of the Government.” If enacted, this plan has the potential to fundamentally transform the structure of the federal government and reshape the country as a whole. 

Trump’s Ties 

On July 5th, former President Trump stated on his Facebook account, “I know nothing about Project 2025. I have no idea who is behind it.” (Trump). He reiterated this sentiment during the presidential debate on September 10, asserting that he has “nothing to do with Project 2025” (NBC). 

However, behind the scenes, the situation appears quite different. In a leaked recording by the Centre for Climate Reporting, Russell Vought, former Director of the Office of Management and Budget during Trump’s administration, a member of the RNC’s platform committee, and a co-author of Project 2025, revealed that Trump has “blessed” the Heritage Foundation and that “[Trump] is very supportive of what we do.” Vought also indicated that he is “not worried” about Trump publicly distancing himself from the initiative and indicates that this should not be taken seriously. “[Trump’s] been at our organization. He’s raised money for our organization”.  

Furthermore, several high-ranking officials from Trump’s administration have been instrumental in shaping Project 2025. Among these contributors are former White House adviser Peter Navarro, former Housing and Urban Development Secretary Ben Carson, former chief of staff at the Office of Personnel Management (OPM) Paul Dans – now the Project 2025 Director – and Spencer Chretien, a former Special Assistant, who currently serves as the Project 2025 Associate Director.  

What are its implications for U.S. immigration policy? 

Project 2025 has major implications for immigration policy, including: 

Completion of Trump’s Wall

“Mandatory appropriation for border wall system infrastructure. The monies appropriated would be used to fund the construction of additional border wall systems, technology, and personnel in strategic locations in accordance with the Border Security Improvement Plan (BSIP).” (Page 147) 

What it says: Project 2025 proposes increased funding for expanding the U.S.-Mexico border wall, increasing border surveillance, and hiring more border patrol. 

Impact: The completion of the border wall may only push determined migrants to go after more dangerous border-crossing methods, leading to increased abuse and violence towards immigrants. Trump’s wall expansions currently stand 30 feet tall and have already resulted in a rise in deaths and serious injuries from migrants falling from the wall (NIH). In El Paso alone, within seven months of the increase in the height of the wall, Border Patrol and healthcare workers have responded to 229 injuries from border wall falls, including broken legs and brain or spinal injuries (NBC). With the construction of the additional wall segments, determined undocumented immigrants coming across the border will face these risks. More wall segments could push even more people to the Sonoran Desert, increasing migrant mortality (UCLA). Expanding Trump’s wall deepens tensions between the U.S., Mexico, and other Latin American countries, as the wall is perceived as a symbol of division rather than cooperation. Instead of deadly borders, humane and effective immigration policies could better protect human rights and foster positive international relations. 

Increased Militarization of the Border  

“Department of Defense: Assist in aggressively building the border wall system on America’s southern border. Additionally, explicitly acknowledge and adjust personnel and priorities to participate actively in the defense of America’s borders, including using military personnel and hardware to prevent illegal crossings between ports of entry and channel all cross-border traffic to legal ports of entry.” (Page 166-167) 

What it says: Project 2025 calls for increased military presence at the U.S.-Mexico border that will likely be used to enforce immigration protocol. 

Impact: There will be an increased military presence at the U.S.-Mexico border, with more direct authorization for the use of military force, potentially leading to more violent encounters with immigrants regardless of the circumstance. This places migrants at a higher risk for extreme and violent encounters with border patrol. Additionally, there is uncertainty about how detention centers may change in response to these measures. The militarization of the border could result in the further militarization of detention centers, which increases the likelihood of hostile and abusive situations for migrants in detention centers. 

Expedited Removal of Immigrants & Mass Deportations 

“To maximize the efficient use of its resources, ICE should make full use of existing Expedited Removal (ER) authorities. The agency has limited the use of ER to eligible aliens apprehended within 100 miles of the border. This is not a statutory requirement.” (Page 142) 

“ICE Enforcement and Removal Operations (ERO) should be identified as being primarily responsible for enforcing civil immigration regulations, including the civil arrest, detention, and removal of immigration violators anywhere in the United States, without warrant where appropriate, subject only to the civil warrant requirements of the INA where appropriate.” (Page 142) 

What it says: The current ICE policy of Expedited Removal (ER) within 100 miles of the border would be expanded under Project 2025 to allow ICE to apprehend suspected undocumented migrants without a warrant anywhere in the country. 

Impact: The ER process is already controversial, as it allows immigration officers to arrest and deport undocumented immigrants without a warrant or a hearing. Additionally, “unlike other removal orders, an expedited removal order cannot normally be appealed and carries a five-year bar to reentry in most circumstances” (American Immigration Council). The ER process is unconstitutional since it violates the right to due process (HoustonLawReview). ICE officers would be able to decide the fate of asylum seekers and other immigrants with special circumstances, instead of an immigration judge, who should be making the decision. As ICE and immigration enforcement grow more powerful, there are growing fears about the impact on already marginalized communities, where this unchecked authority could result in widespread harm and inequality. 

Bring Back Title 42 

“Title 42 authority in Title 8. Create an authority akin to Title 42. Public Health authority that has been used during the COVID-19 pandemic to expel illegal aliens across the border immediately when certain nonhealth conditions are met, such as loss of operational control of the border.” (Page 147) 

What it says: Title 42 was a policy enforced during the COVID-19 pandemic that restricted immigration to help prevent the spread of infectious diseases, specifically COVID-19. Project 2025 calls for the same process as Title 42, but not for exceptional circumstances of public health emergencies. Rather it would be applied to any circumstance where immediate removal of immigrants is deemed necessary. 

Impact: While Title 42 was in effect, the government called for the immediate removal of immigrants and asylum seekers arriving at the border without a hearing, which violated the constitutional right to due process. The policy specifically mentions its application in cases of “loss of operational control of the border,” which could be interpreted broadly and used whenever authorities feel it is necessary, regardless of facts on the ground. The vagueness around the circumstances of enforcing such a policy could lead to the end of asylum at the border. 

Removal of “Sensitive Zones” 

“All ICE memoranda identifying “sensitive zones” where ICE personnel are prohibited from operating should be rescinded. Rely on the good judgment of officers in the field to avoid inappropriate situations.” (Page 142) 

What it says: Project 2025 clearly states that they want to get rid of “sensitive zones” and ICE-free zones.  

Impact: The protected areas exist to ensure access to essential services for community members, such as (but not limited to) schools, medical facilities, places of worship, or religious study (CBP). ICE is not allowed to enter these areas without proper permission, or to carry out typical enforcement actions such as arrests, civil apprehensions, searches, inspections, seizures, service of charging documents or subpoenas, interviews, and immigration enforcement surveillance. The removal of “sensitive zones” will allow raids in such places that immigrants consider safe havens from fear of deportation.  

Increased Space in Detention Centers 

“Congress should mandate and fund additional bed space for alien detainees. ICE should be funded for a significant increase in detention space, raising the daily available number of beds to 100,000.” (Page 143) 

What it says: Project 2025 aims to more than double the number of migrants held in detention centers (up to 100,000). At this time, the daily bed space quota for immigrants in detention who are facing deportation is 41,500 (Congress). 

Impact: By increasing detention capacity, Project 2025 seeks to further expand and institutionalize the detention of undocumented immigrants or asylum seekers. With increased capacity, enforcement practices may use “national security” as a justification to increasingly racially profile and detain innocent migrants to fill the detention centers. Furthermore, as the number of migrants in detention centers increases, so does the risk of overcrowding, inadequate health services, and limited access to legal advisors. This can also result in a longer detainment process, where people are incarcerated in these detention centers without any clear end. These detention centers, many of which were previously private prisons (ACLU), isolate undocumented immigrants and hold them in inhumane conditions. This section of policy reflects that Project 2025 plans to oversee a significant increase in the number of people detained in inhumane detention centers and then potentially deported. 

Remove Protections for Unaccompanied Minors 

“Congress should repeal Section 235 of the William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA), which provides numerous immigration benefits to unaccompanied alien children and only encourages more parents to send their children across the border illegally and unaccompanied. These children too often become trafficking victims, which means that the TVPRA has failed.” (Page 148) 

What it says: Section 235 of the William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA) currently provides protection and assistance to unaccompanied minors, children who cross the border without a parent or guardian, who are at risk of human trafficking, and vulnerable to exploitation. Its repeal would remove these important safeguards for unaccompanied minors. 

Impact: Without these protections children detained at the border will no longer benefit from a policy of safe return to their home country. Furthermore, these children and youth would lose access to safe housing placements, healthcare services, legal attorneys and advocates, immigration status adjustments, asylum protections, and other types of social assistance that protects them from exploitation, including human trafficking. Furthermore, removing legal protections for unaccompanied minors would make it more difficult for authorities to investigate crimes or prosecute human trafficking schemes. The government should instead focus on creating a system that efficiently processes children, protects human rights, and minimizes further trauma so that unaccompanied children are kept out of further danger.

Removal of Visas for Survivors of Human Trafficking and Other Crimes 

“Eliminate T and U visas. Victimization should not be a basis for an immigration benefit. If an alien who was a trafficking or crime victim is actively and significantly cooperating with law enforcement as a witness, the S visa is already available and should be used. Pending elimination of the T and U visas, the Secretary should significantly restrict eligibility for each visa to prevent fraud.” (Page 141) 

“Emphasis also has been placed on removing legal barriers to immigration, such as the use of public benefits.” (Page 143) 

What it says: Project 2025 proposes to remove current visas given to victims of human trafficking (T visa) and other serious crimes (U visa) who assist law enforcement in investigating and prosecuting those committing such crimes. This document argues that victimization is not a legitimate way to qualify for immigration benefits, instead maintaining that these types of visas are an easy route to fraud. 

Impact: The T and U visas exist so that undocumented victims of crimes in the U.S. will not be afraid to report crimes due to fear of persecution and deportation. Eliminating these visas would increase the likelihood of reprisals against already vulnerable undocumented people, perpetuating a cycle of violence.  Project 2025 proposes using the currently available S visa in place of the T and U visas. The S visa is a temporary visa that allows immigrants who have witnessed a crime to reside in the U.S. while assisting in criminal or terrorist investigations. While the S visa sounds similar to the T and U visas, this visa disregards the circumstances of the victimization of migrants and does not acknowledge the protection of human rights. The T and U visas additionally aim to assist victims who have had crimes committed against them in rebuilding their lives by providing access to healthcare, legal aid, or any other care in light of their situation, while the S visa does not. Additionally, T and U visas encourage cooperation and trust with law enforcement, while S visas are much more restrictive and potentially increase the vulnerability of victims since perpetrators of crimes know that their victims cannot prosecute their perpetrators through “normal” legal routes.  

Prioritize “High-Skilled” Immigrants 

“The oft-abused H-1B program should be transformed into an elite program through which employers are vying to bring in only the top foreign workers at the highest wages so as not to depress American opportunities.” (Page 145) 

“H-1B reform. Transform the program into an elite mechanism exclusively to bring in the “best and brightest” at the highest wages while simultaneously ensuring that U.S. workers are not being disadvantaged by the program.” (Page 150) 

What it says: The government should use the H-1B program to further prioritize high-skilled immigrants. People who already don’t have distinguished merit and availability depress American opportunities and should not be allowed to immigrate.  

Impact: The H1-B program allows American companies to temporarily hire workers from other countries for “specialty occupations.” In order to meet the criteria for a specialty occupation, one must have specialized knowledge or expertise in a particular field and at least a bachelor’s degree or its equivalent (U.S. Department of Labor). The H1-B program is most commonly used for hiring professionals in engineering, mathematics, technology, and medical sciences (American Immigration Council). Project 2025 argues that the H1-B program be transformed into an “elite mechanism” that hires high-skilled immigrant workers at the highest wages while simultaneously ensuring that U.S. workers are not being disadvantaged by the program. This is misleading, as research shows that H1-B workers do not earn more than U.S.-born workers nor does it lower American wages (American Immigration Council). Additionally, there is an annual cap on how many H1-B visas are granted. Further restrictions on worker visas may actually reduce the overall talent pool and diversity, limiting opportunities for skilled workers who may not yet have demonstrated elite levels of success but possess high potential. Furthermore, a significant proportion of the US economy is powered by workers who might not be categorized as “high skilled,” such as agricultural and construction workers, but who are nevertheless essential to the success of these industries. Focusing on only “high-skilled” immigrants can lead to harmful consequences for industries that rely on a broad range of workers, including mid-skill and entry-level positions, and lead to labor shortages, higher wages, or higher costs for consumers. 

Reduce Student Visas 

“Prioritize national security in the Student and Exchange Visitor Program (SEVP). ICE should end its current cozy deference to educational institutions and remove security risks from the program. This requires working with the Department of State to eliminate or significantly reduce the number of visas issued to foreign students from enemy nations.” (Page 141) 

What it says: There should be tighter restrictions on education institutions for allowing student visas, including decreasing the number of available student visas to protect national security. 

What this means: The Student and Exchange Visitor Program (SEVP) is a program administered by the Department of Homeland Security (DHS) that provides temporary visas for nonimmigrant students and exchange visitors from other countries seeking an education in the U.S. Project 2025 implies that the SEVP program provides too much leniency in admitting foreign students and that the process should be tightened to reduce security risks. This claim dismisses the fact that the DHS uses a secure system, called the Student and Exchange Visitor Information System (SEVIS), which collects information about students and visitors eligible for the SEVP program to ensure national security. Additionally, Project 2025 proposes to significantly decrease the number of visas given to “enemy nations.” This could fuel geopolitical tensions with other countries, and create social divisions and tensions in the U.S., such as increasing xenophobia (dislike of or prejudice against people from other countries), as only those coming from Western countries would be accepted to study in the U.S. This could also create a needless barrier to the entrance into the U.S. of potential high-skilled students that are in a position to contribute to the U.S. economy.  

Strict Asylum Restrictions & Reduction of Accepted Refugees 

“The standard for a credible fear of persecution should be raised and aligned to the standard for asylum. It should also account specifically for credibility determinations that are a key element of the asylum claim.” (Page 148) 

“Congress should eliminate the particular social group protected ground as vague and overbroad or, in the alternative, provide a clear definition with parameters that at a minimum codify the holding in Matter of A-B that gang violence and domestic violence are not grounds for asylum.” (Page 148) 

What it says: These two statements from Project 2025 recommend stricter restrictions on who is eligible for asylum status, including raising the standards for cases of credible fear of persecution. Project 2025 adds that being part of a specific social group or a victim of gang violence or domestic violence should not qualify for asylum. 

Impact: This recommendation from Project 2025 would allow the government to turn away and potentially endanger the lives of asylum seekers who do not meet the extremely high standards of proving a credible fear of persecution (Human Rights First). The United Nations released a report in 2021 expressing that extreme regulations on asylum seekers are a violation of human rights (UN). Asylum seekers who met a credible fear of persecution under previous qualifications would then require high standards of evidence, which may not be easily available depending on the individual’s circumstances. With the restriction of what it means to be an asylum seeker, people who may have claimed credible fear of persecution may have more trouble with asylum claims leading to long administrative processes and violations of human rights. It would also seem to make it harder for a given administration to grant temporary asylum to specific categories of migrants, in response to natural disasters, forced displacements, and other large-scale threats to life and livelihood.  

No More Deferred Action for Childhood Arrivals (DACA) 

“Currently, approximately 15 percent–20 percent of CISOMB’s workload consists of helping DACA applicants obtain and renew benefits, including work authorization. This is not the role of an ombudsman. In addition, the government should be a neutral adjudicator, not an advocate for illegal aliens.” (Page 166) 

What it says: Project 2025 claims that the Office of the Citizenship and Immigration Services Ombudsman (CISOMB) workload is overwhelmed from assisting Deferred Action for Childhood Arrivals (DACA) applicants obtain and renew benefits. Additionally, this document implies that the government is acting as an advocate for undocumented immigrants by assisting DACA applicants. 

Impact: Deferred Action for Childhood Arrivals (DACA) allows individuals who were brought to the U.S. by their parents before the age of 16, to be eligible to work, study, and serve in the army. DACA recipients must renew their benefits every two years to maintain temporary relief from deportation. The majority of DACA recipients have grown up as Americans, received American education, and are members of the community. Many of them only find out that they are not American citizens once they are adults and go through processes such as employment and university applications. 

The Office of the Citizenship and Immigration Services Ombudsman (CISOMB) serves as a liaison between the public and U.S. Citizenship and Immigration Services (USCIS), to help immigrants address issues and concerns with their experience with USCIS. CISCOMB is an independent office in the Department of Homeland Security (DHS) separate from USCIS which processes DACA renewal applications. The claim made by Project 2025 regarding CISOMB being overwhelmed by DACA application renewals is misleading, since the CISOMB does not have any authority to approve or deny DACA renewal applications. There is no evidence to inform the percentage of CISOMB’s workload as stated in Project 2025. Furthermore, this section from Project 2025 emphasizes that the government should not be providing any services for DACA recipients because it promotes empathy for undocumented immigrants. These sentiments directed towards helping individuals who were forced to migrate as children allow for more leeway in further depriving innocent undocumented immigrants of the right to education. 

Restrict Educational Resources for DACA Students

“Department of Education: Deny loan access to those who are not U.S. citizens or lawful permanent residents, and deny loan access to students at schools that provide in-state tuition to illegal aliens.” (Page 167) 

What it says: Project 2025 calls for the Department of Education to deny student loans to anyone who is not a U.S. citizen or permanent resident. This segment from Project 2025 also impacts non-immigrant students by advising the Department of Education to deny student loans to all students in schools that allow in-state tuition to undocumented immigrant students, such as DACA students. 

Impact: Currently, undocumented immigrants, such as DACA students, are not eligible for federal financial aid, except for refugees and some visa-holders (FAFSA). However, twenty-five U.S. states do allow undocumented immigrant students, such as DACA students, to pay in-state tuition (source). This would allow DACA recipients to receive a more accessible higher education in their states of residency, despite not being eligible for federal loans. This segment from Project 2025 also impacts non-immigrant students by advising the Department of Education to deny student loans to all students in schools that allow in-state tuition to undocumented immigrant students, such as DACA students. This can be understood as an effort to penalize schools that allow DACA students to pay in-state tuition and, ultimately, to limit DACA students from accessing a college education. 

Mandate E-Verify 

“Congress should also permanently authorize E-Verify and make it mandatory.” (Page 149) 

What it says: Project 2025 calls upon Congress to expand E-Verify, by enforcing permanent authorization and mandate of the system. 

Impact: E-Verify is a system voluntarily used by employers, with some state and local mandates, that verifies employees’ eligibility to work in the U.S. (USCIS). However, E-Verify is not as reliable as Project 2025 appears to suggest. E-Verify relies on records from the Department of Homeland Security (DHS) and the Social Security Administration (SSA), which are not always up to date, resulting in errors, or what E-Verify calls “mismatches.” Mistakes in the system could result in wrongfully identifying people, even American citizens, as unable to work in the U.S., which could lead to job loss or job delays until the error is corrected.   

Greater Transparency Regarding Tax Information from Undocumented Immigrants 

“Department of the Treasury: Implement all necessary regulations both to equalize taxes between American citizens and working visa holders and to provide DHS with all tax information of illegal aliens as expeditiously as possible.” (Page 167) 

What it says: The Department of Treasury must make American citizens and immigrants with work visas pay the same amount of taxes. Additionally, the Department of Treasury must provide the Department of Homeland Security with all tax information of all undocumented immigrants as soon as possible. 

Impact: Generally, people with work visas pay the same amount of income taxes as U.S. citizens, with some exemptions, such as paying Social Security and Medicare (IRS). This plan requires those with work visas to pay taxes for Social Security and Medicare, which is unfair since they are only living in the U.S. temporarily and will not receive such benefits. 

Furthermore, the Department of Treasury withholds all tax information collected in the U.S., including tax information from tax-paying undocumented immigrants. If the DHS has all the identifying information, border enforcement agents may use this sensitive information to determine who is undocumented and documented. They may use this information to execute plans to conduct mass deportations of undocumented immigrants, even those who pay taxes. Additionally, in 2022, undocumented immigrants paid $96.7 billion in federal, state, and local taxes (ITEP). Undocumented immigrants significantly contribute to their communities and the country as a whole. The federal budget, which has for some time struggled with a growing deficit (PGPF), would not benefit from deporting all undocumented immigrants who work and pay taxes in the U.S. Even threatening to hand all tax information to the DHS would discourage undocumented immigrants from paying taxes. This would also impact the Social Security system finances, which often enjoys a surplus for undocumented immigrants who contribute with payments but do not receive benefits after retirement. 

Lack of Checks and Balances at the Border 

“The President pursue legislation to dismantle the Department of Homeland Security (DHS).” (page 133). 

“U.S. Customs and Border Protection (CBP) be combined with Immigration and Customs Enforcement (ICE); U.S. Citizenship and Immigration Services (USCIS); the Department of Health and Human Services (HHS) Office of Refugee Resettlement (ORR); and the Department of Justice (DOJ) Executive Office for Immigration Review (EOIR) and Office of Immigration Litigation (OIL) into a standalone border and immigration agency at the Cabinet level (more than 100,000 employees, making it the third largest department measured by manpower)” (133) 

What it says: Immigration agencies will be consolidated into one centralized agency that will control all immigration policy implementation and action. 

Impact: The potential dismantling of the Department of Homeland Security and consolidation of immigration-related concerns under one agency raises concerns about decreases in accountability, transparency, and civil rights protections for migrants. Together with the further militarization of the U.S. immigration regime, it could become easier to sweep human rights abuses under the rug, leading to greater repression of migrants.  

Key Takeaways 

Contrary to common belief, immigration is essential to the U.S. economy. According to the Washington Post immigrants were responsible for 50% of the labor market’s growth in 2022. A decline in immigration to the U.S. will notably impact important industries where undocumented labor is frequently essential, like agriculture, construction, and the service sector, potentially leading to labor shortages and higher costs for consumers. Mass deportations of essential workers would decrease the labor force, which could lead to inflation, shortages of food and other products, and higher prices for basic necessities (Forbes). If Project 2025 were to be executed and enforced during a second Trump term, stricter immigration policies could contribute to an economic recession (AULA).  

The proposed immigration policy recommendations in Project 2025 aim to create a significant shift in border enforcement that promotes a system of strict enforcement without offering paths to legalization for those who entered the country undocumented, with the only plan being mass deportation and detention. Were a second Trump administration to adopt the policy recommendations promoted here, it would heighten the vulnerabilities faced by immigrants, both documented and undocumented. Instead of fostering a humane and effective immigration system, Project 2025 leans toward punitive measures that could jeopardize nationwide benefits. To conclude, Project 2025 would fundamentally transform the structure of the federal government in ways both deeply detrimental to migrants of all sorts but also to the flourishing of U.S. society as a whole. 

Katheryn Olmos is a Research Assistant at the Center for Latin American and Latino Studies and the Immigration Lab. She is in the master’s program in Sociology, Research, and Practice at American University.

Luc Thomas is an intern at the Center for Latin American and Latino Studies and the Immigration Lab. He is completing his Bachelor of Arts in Political Science at American University.

Ernesto Castañeda is Director of the Immigration Lab and the Center for Latin American and Latino Studies at American University. 

Robert Albro is Associate Director for Research at the Center for Latin American and Latino Studies.

Edited by Diana Garay, Program Coordinator, and Mackenzie Hoekstra, intern, both at the Center for Latin American and Latino Studies and the Immigration Lab.