PHILADELPHIA, JUNE 19 -- The new amnesty program for illegal immigrants is "antialien" because its stringent requirements are discouraging many immigrants from coming forward, the new president of the American Immigration Laywers Association said today.

Speaking to about 800 immigration lawyers from across the county, Ira J. Kurzban said the amnesty program has failed to draw the expected numbers of applicants because the Immigration and Naturalization Service has created "a bewildering array of detailed, complicated regulations which are essentially incomprehensible to the layman and, in the final result, antialien."

Kurzban, a prominent Miami immigration lawyer, said the extensive documentation the immigration service requires of an illegal immigrant's proof of having lived here since 1982 "is designed to discourage rather than encourage persons to come forward. Many applicants are barred from eligibility because they are unable to obtain cooperation from their previous employers, who often exploited the applicant and does not now want that known to the government."

Kurzban also said the 2,500-member organization would seek legislation to extend the amnesty program to all illegal immigrants who have been in this country since Nov. 6, 1986, when the law was signed by President Reagan.

The immigration law now grants amnesty -- a legalization program for undocumented immigrants that leads to permanent residency -- only to illegals immigrants who have lived in the United States since Jan. 1, 1982. The law's critics have charged that the cutoff date effectively bars from the amnesty

program hundreds of thousands of illegal Central Americans who arrived here since then.

Kurzban said some aliens are reluctant to apply for fear that it would expose a spouse or child not eligible for amnesty to deportation.

Immigration officials who attended the one-week conference here said they have received about 114,000 applications for amnesty since the program began May 5. Although the number of undocumented workers applying at the 107 legalization centers has risen to about 6,000 a day, it is still below the expected 10,000-a-day processing capacity of the centers, the officials said.

INS Associate Commissioner Richard E. Norton said about 98 percent of the applicants so far have received their temporary work permits and now are waiting to hear if they will also be granted temporary residency. Eighteen months after receiving temporary residency, an illegal immigrant is eligible to apply for permanent residency and eventually citizenship.

Initially, INS said as many as 3 million would apply for amnesty but now the agency expects only about 2 million to apply, Norton said.

He also said agency officials are disappointed by the few numbers being processed by about 500 specially selected voluntary agencies. The immigration service had hoped most of the amnesty applicants would come through voluntary agencies that are allowed to charge up to $100 to process an application.

Instead, Norton said, 60 percent of the applicants are being brought in by lawyers, 30 percent are walk-ins and 10 percent are coming through the voluntary agencies.

Norton said the voluntary agencies probably are holding back on filing many cases "because they think {the applicant} needs to provide two suitcases full of documents. We will accept reasonable evidence in any form," he said. "Although we expect it to be the best available."