New USCIS guidance will require young nonimmigrants who turn 14 while in the U.S. to "re-register" with USCIS within 30 days of their birthday, even if previously registered when entering the country. This may affect, for example, F-2, J-2, H-4 dependents and young F-1/J-1 students who entered before age 14. Most nonimmigrants who entered the U.S. at age 14+ are already automatically registered (as evidenced by their Form I-94) and DON'T need to re-register.

  • Read the USCIS page: Alien Registration Requirement (February 25, 2025, updated March 12, 2025); The USCIS guidance references statutes and regulations as well as Executive Order 14159 of January 20, 2025: Protecting The American People Against Invasion (see 90 FR 8443 (January 29, 2025)) as the legal basis for the agency action.
  • Read the USCIS interim final rule published at 90 FR 11793 (March 12, 2025), Alien Registration Form and Evidence of Registration, effective April 11, 2025 that:
    • Designates a new registration form, Form G-325R, Biographic Information (Registraton) for subject individuals to comply with statutory alien registration and fingerprinting provisions.
    • Amends the Code of Federal Regulations (CFR) at 8 CFR 264.1(a) and (b) to include the G-325R among the acceptable registration forms and types of evidence of registration.
    • Describes in the preamble:
      • The biometric collection process initiated by the filing of Form G-325R
      • Who does and does not have to register or re-register, i.e., the principal population who would use Form G-325R to register and be fingerprinted
      • The legal background of the registration and fingerprinting requirements of the Immigration and Nationality Act and DHS implementing regulations and the penalties for not complying with the requirements
    • Note that this is a USCIS interim final rule (IFR) with request for comments. Although the rule will still go into effect on April 11, 2025 and the Form G-325R is available now, USCIS will receive comments on the changes to 8 CFR until April 11, 2025, and comments on the G-325R until May 12, 2025.
  • This is also a good time to remind noncitizens to carry their registration document and timely report address changes. See NAFSA's page Requirements to Carry Immigration Registration Document and Report Change of Address for information on these separate but related requirements.

Quick reference

What is the new DHS "Alien Registration" program? On February 25, 2025, USCIS published a web page called Alien Registration Requirement, that goes into procedural detail regarding who and how certain individuals must "register" or "re-register" with the U.S. Government as required by longstanding provisions of the Immigration and Nationality Act. USCIS then updated that page on March 12, 2025.

Most nonimmigrants and immigrants are already registered. Most nonimmigrants (for example, F-1, J-1, H-1B, O-1, etc. as well as their dependents) who were aged 14 or over when they entered the United States were likely already registered with the U.S. government when they first arrive. When you receive a visa, are inspected at a U.S. port of entry, and receive a Form I-94 (either on paper or electronically), this automatically counts as your registration, and you will not have to re-register under this new DHS program. You will generally not need to re-register if:

  • You entered the U.S. at age 14 or older; and
  • You received an I-94 form when you entered

The USCIS Alien Registration Requirement page states under the "Who is already registered?" heading:

"Anyone who has been issued one of the documents designated as evidence of registration under 8 CFR 264.1(b) has already registered. Also, anyone who submitted one of the forms designated at 8 CFR 264.1(a) and provided fingerprints (unless waived) and was not issued one of the pieces of evidence designated at 8 CFR 264.1(b), has complied with the registration requirement of INA 262. Aliens who have already registered include:

  • Lawful permanent residents;
  • Aliens paroled into the United States under INA 212(d)(5), even if the period of parole has expired;
  • Aliens admitted to the United States as nonimmigrants who were issued Form I-94 or I-94W (paper or electronic), even if the period of admission has expired;
  • All aliens present in the United States who were issued immigrant or nonimmigrant visas before their last date of arrival;
  • Aliens whom DHS has placed into removal proceedings;
  • Aliens issued an employment authorization document;
  • Aliens who have applied for lawful permanent residence using Forms I-485, I-687, I-691, I-698, I-700, and provided fingerprints (unless waived), even if the applications were denied; and
  • Aliens issued Border Crossing Cards."

New requirement for young people. There is, however, an important rule that affects young people who turn 14 while staying in the United States:

  • If you turn 14 years old while in the U.S., you must register again within 30 days of your birthday; the USCIS Alien Registration Requirement page states that those who must register include: "Any alien, whether previously registered or not, who turns 14 years old in the United States, within 30 days after their 14th birthday."
  • This applies even if you were properly registered when you first entered the country under age 14
  • For example, this rule affects dependents with F-2, J-2, and H-4 status, as well as young students with F-1 and J-1 status (such as boarding school students) who entered the United States under age 14; it also affects immigrants (green card holders) who acquired their lawful permanent residence under age 14 when they turn 14 years old

Regarding the 14 year old requirement the USCIS Alien Registration Requirement page states: "This includes:

  • "All aliens 14 years of age or older who were not registered and fingerprinted (if required) when applying for a visa to enter the United States and who remain in the United States for 30 days or longer. They must apply before the expiration of those 30 days;
  • The parents or legal guardians of aliens less than 14 years of age: Parents or legal guardians must apply for the registration of aliens less than 14 years of age who have not been registered and remain in the United States for 30 days or longer, before the expiration of those 30 days; and
  • Any alien, whether previously registered or not, who turns 14 years old in the United States, within 30 days after their 14th birthday."

Individuals who have not be registered must also now register. In addition to the requirement for 14 year olds to re-register, the USCIS Alien Registration Requirement page states: "Anyone who has not applied to the Department of State for a visa, been issued one of the documents designated as evidence of registration under 8 CFR 264.1(b), or has not submitted one of the forms designated at 8 CFR 264.1(a) and provided fingerprints (unless waived) is not registered. Aliens who have not registered include:

  • Aliens present in the United States without inspection and admission or inspection and parole who have not otherwise registered (that is, aliens who crossed the border illegally);
  • Canadian visitors who entered the United States at land ports of entry and were not issued evidence of registration; and
  • Aliens who submitted one or more benefit requests to USCIS not listed in 8 CFR 264.1(a), including applications for deferred action or Temporary Protected Status who were not issued evidence of registration listed in 8 CFR 264.1(b)."

How to complete the re-registration. See the USCIS Alien Registration Requirement page for instructions on filing Form G-235R. Form G-325R must be filed online through a USCIS online account. It cannot be filed by mail or in person.

Why this matters. Failing to register could result in penalties, including fines and even imprisonment. This requirement comes from longstanding laws that are now being enforced through a new process.

Where can I get advice on my or my family's obligations to register or re-register? Individuals with questions about their and their family's legal obligations to provide information to the U.S. government can contact an experienced immigration lawyer.

Must all individuals carry their "registration document?" - Yes! It has always been the case that all "aliens" (the legal term for individuals who are not U.S. citizens or nationals) 18 years old and older must carry on their person their proof of being registered. Acceptable documents to carry include a print-out of your Form I-94, an EAD card issued to you for employment authorization, or your green card (for lawful permanent residents). All of those documents count as adequate proof of registration. Failure to carry your registration document is a separate offense from not being registered, but is equally important. See NAFSA's page Requirements to Carry Immigration Registration Document and Report Change of Address for information on this separate requirement.

What happens if I move my residence in the United States? Related to the requirements to be registered and carry your registration document is another separate rule that requires all "aliens" to update the Department of Homeland Security within 10 days of moving. Consult USCIS's page How to Change Your Address for details on the process. F-1 and M-1 students and J-1 exchange visitors must report any address changes to their Designated School Official (DSO, for F and M students) or Responsible Officer (RO, for exchange visitors), who then update SEVIS with that information. See NAFSA's page Requirements to Carry Immigration Registration Document and Report Change of Address for more information on this separate requirement.

For more information, visit the USCIS website or contact an immigration adviser at your school or organization.

More details

General background

For nonimmigrants, registration usually takes place automatically at the port of entry as a normal part of the inspection and entry process. Having been issued a Form I-94 (paper or electronic) is evidence of registration under the INA and DHS regulations. See NAFSA's page Requirements to Carry Immigration Registration Document and Report Change of Address for background on this long-standing requirement.

The USCIS Alien Registration Requirement page clarifies that most nonimmigrants who obtained a visa and entered the United States in nonimmigrant status at age 14 and above will likely already have been properly registered automatically, and would not have to re-register at this time. The USCIS page lists "Aliens who have already registered" as including:

  • Lawful permanent residents;
  • Aliens paroled into the United States under INA 212(d)(5), even if the period of parole has expired;
  • Aliens admitted to the United States as nonimmigrants who were issued Form I-94 or I-94W (paper or electronic), even if the period of admission has expired;
  • All aliens present in the United States who were issued immigrant or nonimmigrant visas prior to arrival;
  • Aliens whom DHS has placed into removal proceedings;
  • Aliens issued an employment authorization document;
  • Aliens who have applied for lawful permanent residence using Forms I-485, I-687, I-691, I-698, I-700, even if the applications were denied; and,
  • Aliens issued Border Crossing Cards."

Individuals who turn 14 while inside the United States

Although Section 7 of the executive order referenced on the USCIS Alien Registration Requirement page focuses generally on an effort to register unregistered "aliens" (the technical term for non-U.S. citizens/nationals) present in the United States, the new USCIS guidance appears to take the executive order several steps beyond that by stating:

"Any alien, whether previously registered or not, who turns 14 years old in the United States, within 30 days after their 14th birthday" must also register.

and

"all aliens 14 years of age or older who were not registered and fingerprinted (if required) when applying for a U.S. visa and who remain in the United States for 30 days or longer, must apply for registration and fingerprinting."

This means that DHS also wants F-2, J-2, H-4 and other dependents, even lawful permanent residents, who are in the United States to register again if they turn 14 in the United States, through a new DHS registration process, even if they had properly been registered upon entering the United States with a visa and were given an I-94 or green card.

The USCIS Alien Registration Requirement page states:

"It is the legal obligation of all unregistered aliens (or previously registered aliens who turn 14 years old) who are in the United States for 30 days or longer to comply with these requirements. Failure to comply may result in criminal and civil penalties, up to and including misdemeanor prosecution, the imposition of fines, and incarceration."

Why age 14?

The basis for this move by the administration is that generally, even though all nonimmigrants are generally registered (i.e., inspected and issued an I-94) at the time of admission, minors may not have been fingerprinted at that time. Several old provisions are at work that have never really had INS or DHS mechanisms to implement and enforce them:

The Immigration and Nationality Act at INA 262 [8 USC 1302] establishes that:

"It shall be the duty of every alien now or hereafter in the United States, who (1) is fourteen years of age or older, (2) has not been registered and fingerprinted under section 1201(b) of this title or section 30 or 31 of the Alien Registration Act, 1940, and (3) remains in the United States for thirty days or longer, to apply for registration and to be fingerprinted before the expiration of such thirty days."

Likewise, DHS regulations at 8 CFR 264.1(g) state:

"(g) Registration and fingerprinting of children who reach age 14. Within 30 days after reaching the age of 14, any alien in the United States not exempt from alien registration under the Act and this chapter must apply for registration and fingerprinting, unless fingerprinting is waived under paragraph (e) of this section, in accordance with applicable form instructions.

(1) Permanent residents. If such alien is a lawful permanent resident of the United States and is temporarily absent from the United States when he reaches the age of 14, he must apply for registration and provide a photograph within 30 days of his or her return to the United States in accordance with applicable form instructions. The alien, if a lawful permanent resident of the United States, must surrender any prior evidence of alien registration. USCIS will issue the alien new evidence of alien registration.

(2) Others. In the case of an alien who is not a lawful permanent resident, the alien's previously issued registration document will be noted to show that he or she has been registered and the date of registration."

Also, DOS regulations at 22 CFR 41.103(b)(4) provide:

"(4) Registration. The Form DS-160 or the Form DS-156, when duly executed, constitutes the alien's registration for the purposes of INA 221(b)."

DOS regulations at 22 CFR 41.105(b) provide:

"(b) Fingerprinting. Every applicant for a nonimmigrant visa must furnish fingerprints, as required by the consular officer.

Note that the second clause of the fingerprinting provision, "as required by the consular officer," must be read in the context of the Federal Register notice that added that provision, 73 FR 49091 (August 20, 2008), Documentation of Nonimmigrants Under the Immigration and Nationality Act, as Amended: Fingerprinting, effective August 20, 2008. In the preamble to that 2008 final rule, DOS stated:

"Must all applicants be fingerprinted? As described in the Federal Register notice, the majority of nonimmigrant visa applicants are required to be finger-scanned as part of the application process. There are currently some exceptions to the fingerprint requirement, including most applicants under the age of 14 years or over the age of 79.

It is unclear to what "Federal Register notice" DOS is referring it does reference a simple earlier notice of the transition to ten fingerprints published at 72 FR 25351 (May 4, 2007), but there is also a DOS notice published at 69 FR 78515 (December 30, 2004), Deployment of the Biometric Visa Program for the Collection of Biometric Identifiers of Nonimmigrant and Immigrant Visa Applicants. The December 30, 2004 notice stated that:

"Certain exemptions to the fingerscans under the Biometric Visa Program were also coordinated with the Department of Homeland Security to coincide with the exemptions to fingerscans under the US-VISIT Program. Under the Biometric Visa Program, applicants for diplomatic or official visas, for visas to represent their governments at recognized international organizations such as the United Nations or for visas to serve as employees of such organizations, for NATO visas, or for government officials on official transit through the U.S. are exempt from the fingerscans. The aforementioned are represented by visa categories: A-1, A-2, G-1, G-2, G-3, G-4, NATO-1, NATO-2, NATO-3, NATO-4, NATO-5, NATO-6 and C-3 (except for attendants, servants, or personal employees of accredited officials). In addition, persons under age 14 and persons age 80 or above are exempt from the fingerscans, unless the person is applying for a nonimmigrant visa at a consular post in Mexico. In Mexico, we have been requiring fingerscans for applicants age 7 and above under the program for issuance of biometric Border Crossing Cards (commonly known as “laser visas”), which began in 1998. We will continue to require fingerscans for any nonimmigrant visa applicant age 7 and above at our posts in Mexico. These age exemptions are being put into effect for operational efficiencies; however, the Secretary of State retains the authority to require fingerscans of children under age 14 or adults age 80 or above. All visa applicants are required to submit a photograph with the visa application, except at consular posts in Mexico where most nonimmigrant visa applicants have a live-capture photo taken at post. "

Other individuals who must now register

In addition to the requirement for 14 year olds to re-register, the USCIS Alien Registration Requirement page states: "Anyone who has not applied to the Department of State for a visa, been issued one of the documents designated as evidence of registration under 8 CFR 264.1(b), or has not submitted one of the forms designated at 8 CFR 264.1(a) and provided fingerprints (unless waived) is not registered. Aliens who have not registered include:

  • Aliens present in the United States without inspection and admission or inspection and parole who have not otherwise registered (that is, aliens who crossed the border illegally);
  • Canadian visitors who entered the United States at land ports of entry and were not issued evidence of registration; and
  • Aliens who submitted one or more benefit requests to USCIS not listed in 8 CFR 264.1(a), including applications for deferred action or Temporary Protected Status who were not issued evidence of registration listed in 8 CFR 264.1(b)."

Procedures

A USCIS interim final rule published at 90 FR 11793 (March 12, 2025), Alien Registration Form and Evidence of Registration, effective April 11, 2025:

  • Designates a new registration form, Form G-325R, Biographic Information (Registraton) for subject individuals to comply with statutory alien registration and fingerprinting provisions.
  • Amends the Code of Federal Regulations (CFR) at 8 CFR 264.1(a) and (b) to include the G-325R among the acceptable registration forms and types of evidence of registration.
  • Describes in the preamble:
    • The biometric collection process initiated by the filing of Form G-325R
    • The legal background of the registration and fingerprinting requirements of the Immigration and Nationality Act and DHS implementing regulations and the penalties for not complying with the requirements
    • The principal population who would use Form G-325R to register and be fingerprinted

The USCIS Alien Registration Requirement page provides the following instructions under "How to Register":

"Step 1: Create a USCIS Online Account

To register, you must first create a USCIS online account. See our How to Create a USCIS Online Account page for more information.

Each alien submitting Form G-325R must have their own individual USCIS online account. This includes aliens under the age of 14. If you are the parent or legal guardian of an alien under the age of 14 who needs to register, you will need to set up an individual USCIS online account on your child’s behalf and in their name.

Step 2: Submit Form G-325R

Once you create your or your child’s (if you are the parent or legal guardian of an alien under 14 years of age) USCIS online account, fill out an electronic version of the Form G-325R, Biographic Information (Registration). Form G-325R must be filed online through a USCIS online account. It cannot be filed by mail or in person.

Each alien who needs to register must submit Form G-325R from the alien’s individual USCIS online account. Form G-325R can only be submitted by the named owner of the USCIS online account. If you are the parent or legal guardian of an alien under the age of 14 who needs to register, you will need to submit Form G-325R on the alien’s behalf through their individual USCIS online account.

As you fill out Form G-325R, please carefully consider whether you have already registered. For example, if you have an Arrival-Departure Record number to provide in response to the question “What is your Form I-94 Arrival-Departure Record Number,” then DHS already issued you evidence of registration. Anyone issued Form I-94 or I-94W upon their admission or parole to the United States is already registered. Only aliens who were previously registered but were not previously fingerprinted and who attained their 14th birthday in the United States should submit Form G-325R within 30 days of attaining their 14th birthday.

Step 3: USCIS review of Form G-325R

Once you have submitted Form G-325R, USCIS will review the information you provided and any DHS records that are available about you. If it appears that you have already complied with the registration requirements in some other way and do not need to submit Form G-325R, USCIS will notify you that you have already complied with the registration requirement. If you have already registered as required under INA 262, USCIS will not schedule you for a biometric services appointment or provide you with evidence of registration. If it appears that you are required to register, USCIS will review your Form G-325R to determine if you are required to appear for a biometric services appointment. If you are not required to appear for a biometric services appointment (for example, Canadian visitors and aliens under 14 years of age), USCIS will provide you with evidence of registration (see Step 5 below).

Step 4: Attend appointment for biometrics collection

If you are required to register and provide biometrics, USCIS will schedule you for a biometric services appointment at one of our Application Support Centers (ASCs). Registrants are not required to pay a biometric services fee under the Interim Final Rule.

See our Preparing for Your Biometric Services Appointment for more information about what to expect.

A willful failure or refusal to attend your biometric services appointment (if required) may result in a determination that you have failed to register under INA 266(a), 8 U.S.C. 1306(a), and may result in criminal penalties.

Step 5: Receive registration documentation

Once you have registered and provided your biometrics (if required), we will post a notice (USCIS Proof of G-325R Registration) that provides proof of your registration to your USCIS online account. In your USCIS online account, you will be allowed to download a PDF version of the notice and can print it."

Remember, this NAFSA page if for information purposes only. It does not constitute legal advice. Individuals with questions about their legal obligations to provide information to the U.S. government should contact an experienced immigration lawyer.

Citations
The USCIS Alien Registration Requirement Page