On February 25, 2025, the U.S. Department of Homeland Security (DHS) announced it was implementing a registration requirement, requiring certain foreign nationals to register their presence in the United States as part of the directives in Executive Order 14159. DHS has since published an Interim Final Rule (IFR) on March 12, 2025, amending the immigration regulations to designate the form to be used for this registration and documents that may serve as evidence of registration.
In short, the IFR requires certain foreign nationals (exceptions discussed below) over the age of 14 who will remain in the United States for 30 days or longer to register their presence in the United States and be fingerprinted within 30 days of their arrival. The IFR also requires parents and legal guardians ensure their children under the age of 14 re-register the child’s presence in the United States and be fingerprinted within 30 days after reaching their 14th birthday.
The IFR becomes effective on Friday, April 11, 2025.
More information is broken down below.
- What is the Alien Registration Requirement?
According to the IFR, the registration requirement applies to the following individuals:
- Foreign nationals above the age of 14 who are not registered and remain in the United States for 30 days or more. They must register their presence and be fingerprinted within 30 days of their arrival;
- Parents or legal guardians of foreign national children under the age of 14 who are not They must also re-register the child’s presence in the United States, and the child must be fingerprinted within 30 days after their 14th birthday.
The registration requirement can therefore be thought of in terms of two overall groups:
- Who is already considered registered?
It is important to emphasize that the IFR identifies instances where certain individuals are already considered to be registered.
More specifically, the IFR identifies the below items as constituting evidence of registration. This means that if a foreign national has one of the documents listed below, and that document is current and valid, it should generally be considered proof of registration and it is not necessary to register (unless it pertains to a child who will turn 14 while in the United States):
- I-94, Arrival-Departure Record – Aliens admitted as nonimmigrants;
- Aliens paroled into the United States under section 212(d)(5) of the INA; aliens whose claimed entry prior to July 1, 1924, cannot be verified, they having satisfactorily established residence in the U.S. since prior to July 1, 1924; and aliens granted permission to depart without the institution of deportation proceedings.
- I-95, Crewmen’s Landing Permit – Crewmen arriving by vessel or aircraft.
- I-184, Alien Crewman Landing Permit and Identification Card – Crewmen arriving by vessel.
- I-185, Nonresident Alien Canadian Border Crossing Card – Citizens of Canada or British subjects residing in Canada.
- I-186, Nonresident Alien Mexican Border Crossing Card – Citizens of Mexico residing in Mexico.
- I-221, Order to Show Cause and Notice of Hearing – Aliens against whom deportation proceedings are being instituted.
- I-221S, Order to Show Cause, Notice of Hearing, and Warrant for Arrest of Alien – Aliens against whom deportation proceedings are being instituted.
- I-551, Permanent Resident Card – Lawful permanent resident of the United States.
- I-766, Employment Authorization Document (EAD).
- Form I-862, Notice to Appear – Aliens against whom removal proceedings are being instituted.
- Form I-863, Notice of Referral to Immigration Judge – Aliens against whom removal proceedings are being instituted.
- In addition, a valid, unexpired nonimmigrant DHS admission or parole stamp in a foreign passport constitutes evidence of registration.
If an individual who is required to be registered does not have one of the documents listed above, then they must register by following the steps listed below.
Under the IFR, every registered alien 18 years of age and over must at all times carry and have in their personal possession any certificate of alien registration or alien registration receipt card. Noncompliance is a misdemeanor punishable by a fine of up to $5,000 or imprisonment for not more than thirty days, or both.
- How does someone register?
To register, the IFR explains the following:
- Foreign nationals must create their own unique account, or an account for their child, in myUSCIS at https://my.uscis.gov/.
- Complete and submit G-325R Biographic Information (this is the registration form), which initiates the process for a biometrics (fingerprint) appointment at a USCIS Application Support Center (ASC). USCIS contacts the registrant regarding the appointment and the collection of biometrics, including fingerprints, photo and signature. USCIS uses this information for identity verification and background/security checks, including a check of criminal history records maintained by the Federal Bureau of Investigation (FBI).
- USCIS sends an appointment notice with the date, time, and location of the registrant’s biometric (fingerprint) appointment.
- Once the biometrics (fingerprint) appointment is completed, the Electronic Immigration System (ELIS) will trigger the creation of “Proof of Alien Registration” with a unique identifier.
For foreign nationals such as children under the age of 14 required to register but for whom the fingerprint requirement is waived, the ELIS case management system will trigger the creation of the “Proof of Alien Registration” upon receipt of the submitted Form G-325R.
- The Proof of Alien Registration document will be posted to the foreign national’s myUSCIS account, and can be printed and carried on person as evidence of registration.
Currently, there is no fee to register though it is likely that DHS may soon require a fee of at least $30 in the future.
- What are potential consequences stated in the IFR of not registering?
The IFR states that a willful failure or refusal to register or be fingerprinted is punishable by a fine up to $5,000 or imprisonment for up to 6 months, or both. There would also be immigration consequences. The same applies to a parent/legal guardian’s willful failure or refusal to register a foreign national child under the age of 14. As stated above, every registered foreign national 18 and over must at all times carry and have in their personal possession any certificate of alien registration or alien registration receipt card. Noncompliance is a misdemeanor punishable by a fine of up to $5,000 or imprisonment for not more than thirty days, or both.
- What do I do if I change my address while in the United States?
The IFR also states that foreign nationals required to register must also notify DHS in writing of each change of address within 10 days from the date of such address change. This is done by completing form AR-11 (Alien Change of Address Card), which can be filed through an individual’s USCIS online account.
Failure to comply with the change of address requirement may result in a criminal violation punishable by a fine of up to $5,000 or imprisonment for not more than thirty days, or both; and could render an individual deportable unless the individual can establish that such failure was reasonably excusable or was not willful.
- Are there particular considerations for Canadians?
Yes. Canadians who receive a valid I-94 entry record upon their admission to the United States satisfies the registration requirement under the IFR.
However, not all Canadians receive an I-94 card upon their entry. For them, they will need to complete the registration requirement. This could be a Canadian B1/B2 visitor, for example, who visits the United States for over 30 days and did not receive an I-94 at a land port of entry.
There can sometimes be a distinction in I-94 documentation for Canadians, depending on whether they enter the United States by airplane or by a land port of entry. Canadians traveling to the United States by airplane typically will receive an I-94 record (one of the recognized registration documents under the Rule) are typically automatically issued by U.S. Customs & Border Protection (CBP). This is not necessarily the case at a U.S. land port of entry where an I-94 may not be automatically generated or perhaps a Canadian visitor was waived in. Therefore, it is possible in this situation that a Canadian citizen may not receive an I-94 to prove registration.
A few options may be available if traveling via land port of entry and will be in the United States for 30 days or longer in an effort to receive evidence of registration. This could include requesting a Form I-94 in advance of travel and/or requesting an admission stamp from CBP as applicable.
Regardless of whether seeking admission to the U.S. by plane, land, sea, or ferry, it is extremely important to check the I-94 record and any admission stamp carefully for accuracy with each trip.
The registration requirements impose significant penalties for failure to comply. For this reason, individuals who intend to travel to the United States for more than 30 days should speak with a reputable immigration attorney to ensure they are taking the required steps necessary to ensure compliance.
