A Guide for Hotel Owners and Managers
By Elsbeth Russell
The hospitality industry in the United States stands at a pivotal moment, as immigration enforcement and policy continue to evolve under the Trump administration’s second term. With labor shortages already straining operations and increased immigration enforcement generating new uncertainties, hotel owners and managers must remain vigilant, informed, and proactive.
Ensuring compliance is not only about avoiding fines or legal risk – it’s about sustaining business continuity, protecting valued workers, and advocating for a stable, legal labor pipeline.
Immigration Policy Under the Current Administration
President Donald Trump’s reelection has brought a renewed focus on immigration enforcement and restrictions. Executive Order 14159, titled “Protecting The American People Against Invasion” and issued in January 2025, expands expedited removal processes, increases employer audits, and strengthens enforcement in sanctuary jurisdictions. Simultaneously, the administration has promised to “secure the border” and is following through on pledges to intensify workplace raids and mass deportations.
“We see a really great opportunity to secure America’s workforce,” said Rebecca Shi, CEO of the American Business Immigration Coalition (ABIC). “Something we’re very happy about is just the president over the last several weeks, and on many occasions, both at cabinet meetings and then also on Fox News, saying that he wants to create legal paths for workers and agriculture and hotels.”
A Sector Under Strain
The hospitality industry depends heavily on immigrant labor, including undocumented individuals and those on temporary visas like H-2B. According to data from the Economic Policy Institute, roughly 7.6 percent of the hotel and restaurant workforce in the U.S. consists of undocumented immigrants. In the current climate, hotel owners are finding it more difficult to recruit and retain staff.
Shi highlights the dual impact of these policy shifts: “We’re going into a very busy summer tourism season, and I think for members of Congress and your local [leaders] to hear about your labor challenges… that you’re just not able to deliver the goods and services and grow businesses… because we don’t have an immigration solution.”
She added that many hoteliers “just want legal paths to fill their jobs,” noting that President Trump himself has acknowledged the importance of creating legal paths for workers in industries like agriculture and hospitality – sectors where he has deep ties.
Fear of Raids and Detentions
Recent Immigration and Customs Enforcement (ICE) raids have made headlines and shaken the industry. In well-publicized examples, dozens to hundreds of workers have been detained from hospitality venues – including in vacation hotspots like Martha’s Vineyard and the D.C. metro area.
The specter of mass deportations has created a climate of fear and disruption.
“You read it in the news stories… I saw Martha’s Vineyard… there was a raid and they detained about 40 workers,” Shi said. “These stories are out there in the public. And they’re going to continue, because [increased enforcement] was one of the key pillars of the president’s commitment.”
A Changing Landscape
In a significant policy shift, President Trump announced on June 14, 2025, that ICE would pause workplace raids in the agricultural, hotel, and restaurant sectors. This decision came amid mounting pressure from industry leaders and widespread protests against aggressive immigration enforcement tactics.
According to an internal ICE memo, regional leaders were instructed to “hold on all work site enforcement investigations/operations on agriculture (including aquaculture and meat packing plants), restaurants, and operating hotels” effective immediately. The Department of Homeland Security confirmed the guidance, emphasizing that efforts would prioritize the removal of criminal illegal immigrants.
President Trump acknowledged the economic implications of his previous policies, stating, “They’re not citizens, but they’ve turned out to be great. We have to do something about that. We can’t take farmers and take all of their people and send them back because they don’t have, maybe what they’re supposed to have. Maybe not.”
By Tuesday, June 17 it was reported by The Wall Street Journal that Trump officials reversed the guidance exempting farms and hotels from immigration raids. These pivots illustrate how important it is for hoteliers to recognize the fluid nature of immigration policies and the potential for rapid changes.
Employer Rights and Responsibilities
What can hotel owners and managers do to stay compliant, protect their teams, and maintain their business operations? The answer begins with preparation, education, and legal awareness.
- I-9 Compliance is Critical. Every hotel owner must ensure accurate and up-to-date I-9 employment eligibility verification forms for every employee, regardless of citizenship status.
“You do have the right and the responsibility to prepare and make sure that your I-9s… are filled out correctly,” Shi explained. “And that you have a correct and appropriate database. If there is a request to verify… you have 72 hours to share them.”
Be proactive in auditing your I-9s and work with a qualified immigration attorney or HR consultant to ensure all documentation is accurate and securely maintained. - Know How to Respond to an ICE Raid. Just like responding to a health inspection, hotel managers should be trained on what to do if immigration enforcement agents show up. Shi likens it to other forms of regulatory oversight.
“It is the same kind of protocol that you would conduct if the health inspector comes,” Shi said. “First and foremost, you should be courteous, respectful, and ensure that [you] collaborate while protecting your workers’ rights.”
Importantly, ICE must present a judicial warrant – not just an administrative subpoena – to enter private areas. Train your team to ask for and review warrants carefully and have legal counsel available to respond if enforcement occurs. - Train Your Managers and Staff. Many hotels operate across multiple sites, and owners can’t be everywhere at one time. That’s why training your managers is crucial.
“It’s really important that you do train your managers on their rights and responsibilities,” Shi emphasized. “We understand, some employers have multiple sites… and you can’t be at three or five sites at once.”
Resources are available from industry groups like AAHOA and legal advocacy organizations, including templates, webinars, and memos for staff training.
The Role of AAHOA and Industry Advocacy
One of the most effective ways for hoteliers to protect their interests is by staying actively engaged with organizations like AAHOA. These associations provide essential updates, host training sessions, and give members a voice in policymaking.
“Get active, stay active with AAHOA,” Shi advised. “We’ve partnered with AAHOA over the years because it’s such a strong association. We’ve done webinars, roundtables, trainings, updates on policy changes, etcetera, with AAHOA.”
She also urges hoteliers to participate in legislative advocacy efforts like the “Secure America’s Workforce” fly-in to Washington, D.C., taking place this October.
“Just know that your voices are really, really valuable,” she said. “Lawmakers are looking for that in order to help shape and influence policy. Because at the end of the day, this is a workforce issue.”
Supporting Workers Beyond Compliance
Beyond meeting legal requirements, hotel owners also have a moral responsibility to their employees – many of whom have worked loyally in their roles for years or even decades.
“There has to be a legal pathway,” Shi said. “Employers legally have to employ people who are legal. And our system has been just so broken and disrupted by politics for the last decade.”
She emphasized that protecting workers includes ensuring that hoteliers advocate for solutions that will stabilize the workforce long-term.
A Glimmer of Opportunity
Despite the anxiety and uncertainty, there may be room for progress. As Shi notes, President Trump – himself a hotelier – has repeatedly voiced support for creating legal paths for hospitality workers.
“He probably more than anybody… understands the contribution of our immigrant workers,” she said. “He could be the Nixon-to-China, the person who could actually affect this.”
But that will require political will, employer voices, and sustained pressure from within the industry.
“This is the ability of American businesses and American hotels and restaurants being able to continue to sustain and also just prosper and continue to grow,” Shi said.
Immigration policy is no longer a distant issue – it’s one that lives within the walls of America’s hotels and the hearts of their employees. For hoteliers, staying informed, compliant, and compassionate is the best strategy for weathering this new era.
Practical Next Steps for Hoteliers
Here is a checklist of recommended actions:
- Conduct a full I-9 audit with legal counsel.
- Train all managers on how to handle ICE visits.
- Prepare and post “know your rights” flyers in multiple languages.
- Engage with AAHOA or similar associations for updates and training.
- Schedule time with an immigration attorney for a risk assessment.
- Participate in advocacy events to influence policy.
Image: Alisa/stock.adobe.com
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