Trump's AEWR will transfer billions from H-2A and U.S. farmworkers to employers: Annual wage losses for U.S. and H-2A farmworkers combined at the current size of the H-2A program (2025$)
| H-2A skill level scenarios | Fully enforced state minimum wage |
Housing deduction can push wage below state minimum |
||
|---|---|---|---|---|
| Level 1 = 92%, Level 2 = 8% | $4.4 billion | (9.9%) | $5.4 billion | (12.1%) |
| Level 1 = 100%, Level 2 = 0% | $4.6 billion | (10.3%) | $5.6 billion | (12.6%) |
| Level 1 = 0%, Level 2 = 100% | $2.3 billion | (5.1%) | $2.6 billion | (5.8%) |

Notes: Wage losses are the difference in 2026 annual wages under the October 2, 2025 Adverse Effect Wage Rate (AEWR) interim final rule, as compared to the previous AEWR methodology. Estimates assume the current size of the H-2A program and that that 92% of H-2A workers are paid skill level 1 wages and 8% are paid skill level 2 wages.
Source: Authors' analysis of Zachariah Rutledge, Marcelo Castillo, Timothy J. Richards, and Philip Martin, “H-2A Adverse Effect Wage Rates and U.S. farm wages,” American Journal of Agricultural Economics, pp. 1–24, 2025; Bureau of Labor Statistics, Quarterly Census of Employment and Wages [2024 data files, annual averages], U.S. Department of Labor, accessed November 13, 2025; Office of Foreign Labor Certification, Performance Data [H-2A Disclosure Data, FY 2024, Q4] accessed November 18, 2024.
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