On March 12, 2025, the U.S. Department of Homeland Security (“DHS”) issued an Interim Final Rule (“IFR”) implementing a new registration requirement (“Registration Requirement”) for certain foreign nationals to be filed with the United States Citizenship and Immigration Service (“USCIS”). The Registration Requirement took effect on April 11, 2025, and stems from President Trump’s Executive Order 14159, titled “Protecting the American People Against Invasion,” issued on January 20, 2025. Executive Order 14159 directs DHS to enforce 8 U.S.C. § 1302, a statute based on the Alien Registration Act of 1940, which mandates the registration of certain foreign nationals who have not already done so. To implement this requirement, DHS has designated Form G-325R as the official form for registration and biometric data collection.
Who Is Already Registered?
While the new rule has raised concerns, most nonimmigrants and immigrants are already considered registered and do not need to take further action. However, there are notable exceptions—particularly non-US citizen born minors who turn 14 while in the United States and certain foreign nationals who entered the United States without inspection by an immigration officer.
In general, foreign nationals are considered registered if they were:
- Issued an immigrant or nonimmigrant visa;
- Inspected at a United States port of entry; and
- Issued a Form I-94 (either paper or electronic).
According to USCIS, the following categories of foreign nationals are considered already registered:
- Lawful permanent residents (also known as green card holders);
- Foreign nationals paroled into the United States under INA § 212(d)(5), even if the period of parole has expired;
- Foreign nationals admitted as nonimmigrants who were issued Form I-94 or I-94W (paper or electronic), even if the period of admission has expired
- For example, L-1, E-2, O-1, H-1B, F-1, J-1, and similar nonimmigrant statuses, and their dependents
- Foreign nationals present in the United States who were issued immigrant or nonimmigrant visas before their last date of arrival;
- Foreign nationals in removal proceedings;
- Foreign nationals issued an employment authorization document;
- Foreign nationals who applied for lawful permanent residence using Forms I-485, I-687, I-691, I-698, or I-700, and provided fingerprints (unless waived), even if the applications were denied [1]; and
- Foreign nationals issued Border Crossing Cards.
Who Must Register?
The following foreign nationals must register under the Registration Requirement:
- Canadian nationals who entered the U.S. at a land border and were not issued a Form I-94;
- Foreign nationals who entered without inspection (e.g., by crossing the border unlawfully) and have not previously registered;
- Minors who turn 14 while in the United States—even if previously registered upon admission to the United States—must register within 30 days of their 14th birthday.
Notably, this applies to minors who turn 14 while present in the United States. Even if the minor was registered upon admission under the age of 14, they must re-register within 30 days of their 14th birthday. For instance, this applies to dependents on nonimmigrant visas (L-1, E-2, O-1, H-1B, F-1, J-1, among others), who entered the United States before age 14. It also applies to lawful permanent residents who obtained their green cards under the age of 14.
Exemptions
The following groups are exempt from the new registration requirement:
- Visa holders who were fingerprinted and registered during the visa application process;
- A visa holders (diplomatic and government officials);
- G visa holders (representatives of international organizations);
- Foreign nationals present in the United States for less than 30 days;
- Lawful permanent residents who turn 14 while outside the United States, provided they register and submit a photograph within 30 days of reentry;
- American Indians born in Canada who entered the United States under Section 289 of the INA, and members of the Kickapoo Traditional Tribe of Texas who entered the United States under the Texas Band of Kickapoo Act.
Registration Process
Form G-325R, Biometrics Information (Registration), must be completed online through a USCIS online account. It cannot be filed by mail or in person. There is no government filing fee for this form.
After registering, foreign nationals will receive a certificate of alien registration or an alien registration receipt card. These documents must be carried at all times and kept in personal possession. Registered individuals are also required to notify DHS in writing of any change of address.
Importantly, all foreign nationals aged 18 or older are required to carry proof of registration at all times. This may include evidence of online registration or other documents that serve as proof of registration, such as Form I-94, Green Card, Employment Authorization Document, or a passport with a valid visa stamp.
Penalties for Noncompliance
Willful failure or refusal to comply with the registration and fingerprinting requirements may result in criminal penalties, including:
- A fine of up to $5,000;
- Imprisonment for up to six months; or
- Both.
Reminder: Existing Change of Address Requirement
The Registration Requirement does not replace the longstanding Form AR-11 requirement. All foreign nationals must still report any change of address to USCIS within 10 days of moving by filing Form AR-11. We recommend that such Form AR-11 be electronically filed.
