Introduction
The U.S. Department of Homeland Security announced on July 23, 2026, that it has issued more than $84 billion in civil fines to individuals with final orders of removal who have not departed the United States. The announcement — which centers on a $998-per-day fine for noncompliance with removal orders — marks one of the largest civil penalty enforcement actions in immigration history. Moreover, it carries direct consequences for a significant population currently living in the country under unresolved immigration status.
Background
Federal immigration law has long authorized civil fines against individuals who fail to depart after receiving a final order of removal. For much of recent history, however, these fines were rarely enforced at scale. In addition, procedural requirements — including a 30-day notice period before fines could be issued — slowed the process considerably. The current administration began prioritizing this enforcement tool early in its term. In June 2025, DHS and the Department of Justice jointly announced a streamlined fining process that eliminated the 30-day advance notice requirement. The new process permitted immigration officers to deliver fine notices by regular mail and compressed the timeline for contesting fines. The July 2026 announcement reflects the aggregate result of nearly 18 months of enforcement under that accelerated framework.
What Is Changing
DHS is not announcing a new legal authority with this release — the $998-per-day fine rate and the underlying statutory authority already exist. What this announcement signals is the scale at which enforcement is now operating. More than 103,000 individual fines have been issued since the start of the current administration, totaling approximately $84 billion. DHS framed the announcement as a direct warning to individuals with final removal orders. It explained that voluntary departure through the CBP Home app would result in full forgiveness of accumulated fines, a free return flight, and a $2,600 departure incentive. Those who do not depart voluntarily face arrest, removal, and a permanent bar from returning to the United States.
DHS specifically cited Title 8, Section 1325 of the U.S. Code as the basis for potential criminal penalties alongside the civil fines, making clear that the agency views these as parallel — not alternative — enforcement tools.
Who Is Affected
The individuals most directly affected are those who have received a final order of removal from an immigration court and have not yet departed. A final order of removal is a formal legal determination — it means the immigration court process has concluded and all available appeals have been exhausted or waived. This is a legally distinct status from someone who is undocumented but has never appeared before an immigration judge. Likewise, it is distinct from someone whose case remains pending.
Individuals in removal proceedings who have not yet received a final order are not the immediate targets of this fine program, though their cases may accelerate in the current enforcement environment. Family members, employers, and communities connected to individuals with final removal orders are indirectly affected — both by the financial magnitude of potential fines and by the increased urgency the administration is placing on removal compliance.
Practical Implications
For individuals with a final order of removal, the practical stakes of inaction have increased substantially. An accumulated fine of $998 per day compounds quickly — 90 days of noncompliance generates nearly $90,000 in civil liability. The streamlined process DHS put in place in 2025 means that individuals may receive fine notices by regular mail. In addition, they have a shortened window to contest them, which raises serious concerns about whether all affected individuals are receiving timely notice and understanding their options.
The CBP Home app pathway that DHS is promoting offers fine forgiveness in exchange for voluntary departure. This is a material legal distinction — individuals who use that pathway are told their civil penalties will be waived — but anyone considering this route should understand what other immigration consequences voluntary departure may or may not carry. This includes any impact on future visa eligibility or reentry bars. Those consequences depend heavily on individual case history and are not addressed in DHS’s announcement.
For immigration attorneys and legal representatives, this enforcement landscape means that clients with final removal orders face a narrow and shrinking window to explore any remaining legal options. These options include motions to reopen, stays of removal, or other relief. The window is closing before the financial and legal consequences of remaining in the country become significantly more severe.
Employers and HR professionals should also be aware that employees with uncertain immigration status may be facing removal-related pressures that could affect workforce stability, even if those individuals have not disclosed their situation. This is not a call for employers to investigate employees’ immigration cases, but rather a prompt to ensure that any existing I-9 compliance programs and internal HR protocols are current.
What to Watch For Next
DHS has not announced a cap on total fines or a deadline after which the voluntary departure incentive will no longer be available, so stakeholders should monitor official DHS communications for any changes to the CBP Home app program terms. The administration’s continued emphasis on fine enforcement suggests that additional announcements — potentially including collections actions or further procedural changes — are likely. Individuals and organizations with interest in this policy area should also watch for any legal challenges to the streamlined fining process established in June 2025. That procedural framework has not yet been extensively tested in federal court.
How Immigration Professional Association Can Help
Immigration Professional Association works with individuals at every stage of the immigration process, including those who have received final orders of removal and are trying to understand what realistic legal options remain available to them. Motions to reopen, applications for stays of removal, and other forms of post-order relief are complex and time-sensitive. The current enforcement environment makes that timeline more urgent than ever.
If you or someone you know has a final order of removal and is trying to understand the full picture — including what the CBP Home app departure pathway means legally, whether any relief options remain, and what the actual financial exposure looks like — Immigration Professional Association is ready to have that conversation. This is not a situation where waiting produces better outcomes. Reach out to our team today to discuss the specific circumstances of your case and what steps, if any, can still be taken.
