New Alien Registration Requirements Effective April 11, 2025
Registration Requirements
The Department of Homeland Security (DHS) published an Interim Final Rule requiring certain non-US citizens in the US for 30 days or more to register with DHS and carry proof of registration. This new rule took effect April 11, 2025. Failure to register and/or carry proof of registration subjects one to possible deportation, criminal fines and/or imprisonment. The registration and fingerprinting requirement applies to individuals 14 and older.
Many foreign nationals legally present in the U.S. are already considered registered. This includes permanent residents (green card holders), EAD holders, and nonimmigrants who were issued a Form I-94 on admission as well as individuals issued nonimmigrant visas prior to last date of arrival. Registration documents include the following:
• I-94, Arrival-Departure Record—Aliens admitted as nonimmigrants; aliens paroled into the United States (assuming the individual submitted biometrics as part of their visa application, or upon admission/parole);
• I-551, Permanent Resident Card—Lawful permanent resident of the United States;
• I-766, Employment Authorization Document (“EAD”).
Per a notice posted on DHS’s website April 11, 2025: https://www.dhs.gov/news/2025/04/11/secretary-noem-reminds-foreign-nationals-register-or-face-legal-penalties, the requirement applies immediately for certain foreign nationals, and applies within 30 days for other foreign nationals:
• Present in the U.S. for 30 days or more as of April 11, 2025, without registration evidence: Register immediately via USCIS.
• Entering on or after April 11, 2025, without registration evidence: Register within 30 days of arrival.
• Turning 14 in the U.S.: Re-register and submit fingerprints within 30 days of your 14th birthday, even if previously registered.
• Parents or guardians of minors under 14: Register minors if they remain in the U.S. for 30 days or longer.
A willful failure or refusal to apply to register or to be fingerprinted is punishable by a fine of up to $5,000 or imprisonment for up to six months, or both.
In addition, all foreign nationals 18 and older must carry documentation of their registration at all times. Noncompliance is a misdemeanor punishable by a fine of up to $5,000 or imprisonment for not more than thirty days, or both.
If you are a foreign national client of Jackson & Hertogs and desire additional guidance regarding this requirement, please contact our office to schedule a consultation. If you have questions about whether you have maintained your status as you prepare to register, please seek counsel immediately. Our consultation fees and policies are available at:
Please refer to this website, which provides links and instructions on registration: https://www.uscis.gov/alienregistration
We highlight below specific components of the “Alien Registration” requirement:
Children Required to Register
Children who were admitted to the U.S. before age 14 and later turn 14 within the U.S. will still be required to complete registration. This is true even if, when admitted to the US, these children had a valid visa and were issued a Form I-94. Note that children who became permanent residents prior to the age of 14 must also register, since they did not complete biometrics during the green card process. The existing process to complete biometrics is to submit a Form I-90 application for a replacement green card. This new registration requirement may be in addition to that application.
Parents and legal guardians are responsible for registering children who have not yet been registered, and who remain in the US for 30 days or more. Children under 14 are not required to complete fingerprinting before they reach the age of 14 and then have 30 days to provide fingerprinting through the appropriate process at that time.
As of April 11, 2025, individuals must create a USCIS online account and submit Form G-325R “Biographic Information (Registration)” to complete registration. For individuals 14 years of age or older, submission will trigger the scheduling of a biometrics appointment notice to a USCIS Application Support Center.
Business Visitors, Tourists and Canadians
Visitors who enter the US using ESTA, and Canadian citizens who enter the US pursuant to USMCA, who remain in the US for 30 or more days, must make sure they are issued a Form I-94 to prove their registration. The new rule specifically states that “Canadian visitors who entered the United States at land ports of entry and were not issued evidence of registration” must register. Canadian citizens may not be subject to the fingerprinting requirements.
Required to Carry Documents
United States law requires all foreign nationals aged 18 and over to carry with them (i.e., in their personal possession) evidence of their lawful visa status at all times. Failure to comply with this requirement is a misdemeanor and is punishable by deportation, fines, imprisonment, or any combination of these.
Foreign nationals (including permanent residents) in the United States should therefore carry with them documents appropriate to their US visa status. While the documents to carry vary depending on visa status, they can include (note that some of these documents, such as a foreign passport, do not also document registration) green cards (Form I-551) or similar evidence, such as I-551 ADIT stamp in passport, Form I-90 receipt, Form I-751 receipt, etc. (if applicable), current passports, latest visa stamp in the passport (if applicable), current USCIS I-797 approval notice for current nonimmigrant status (if applicable), current Form I-94, current Form I-20 (for F-1 visa status holders, if applicable), current Form DS-2019 (for J-1 visa status holders, if applicable), and/or current Form I-766 Employment Authorization Document (if applicable).
It is unclear whether a hard copy of the registration document(s) will be sufficient, as ICE/CBP may demand to see original documents. Presenting a digital copy on your phone may subject your phone to further search, so hard copies may be preferable if not presenting originals. We strongly recommend that you carry original documents.
Please see information on passport validity:
Required to Notify USCIS of Changes of Address
In addition to this new registration requirement, all foreign nationals in the United States must continue to notify USCIS of changes of residential addresses within 10 days of any move. This is done by either notifying USCIS online (“Enterprise Change of Address”, or “E-COA”) via each foreign national’s My.USCIS account, or by mailing in a paper Form AR-11. Form AR-11 can no longer be submitted electronically. Keep in mind that you must submit a separate E-COA or AR-11 for each foreign national family member.
Foreign nationals should keep copies of dated submissions. Form G-325R requires address history by specific date.
Potential Penalties for Failure to Register/False Statements:
Any alien who willfully fails or refuses to apply to register or be fingerprinted (if required), and any parent or legal guardian who is required to apply for the registration on behalf of an alien less than 14 years of age, and who willfully fails or refuses to file an application for the registration of such alien, will be guilty of a misdemeanor. If convicted, they may be fined up to $5,000 or imprisoned for up to 6 months, or both. Also, any individual who files a registration application containing false statements or attempts to procure their own registration or another individual’s registration by fraud is subject to criminal prosecution. Conviction for fraudulent registration constitutes grounds for deportability.
There is no option for attorney representation in submitting Form G-325R. If guidance beyond this notice is desired, we are available for a consultation to review and provide counsel on specific situations; our standard consultation fee would apply.
Additional Resources
Please refer to this FAQ published by the National Immigration Law Center: https://www.nilc.org/resources/faq-the-trump-immigration-registration-requirement/