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USCIS Implements New Alien Registration Rule

On March 12, 2025, the U.S. Citizenship and Immigration Services (USCIS) issued an Interim Final Regulation (IFR) introducing a new registration form to comply with existing statutory alien registration and fingerprinting requirements. This regulation, which goes into effect on April 11, 2025, reinforces the legal obligation for certain noncitizens to register with the federal government and maintain updated records.



Who Is Already in Compliance


If you have already filed any of the following USCIS forms, you are considered registered and do not need to register again:


  • Form I-94 (Arrival-Departure Record, including ESTA travelers).

  • Form I-95 (Crewman’s Landing Permit).

  • Form I-181 (Record of Lawful Permanent Residence).

  • Form I-485 (Application for Permanent Residence).

  • Form I-590 (Refugee Registration).

  • Form I-687, I-691, I-698, I-700, I-817 (Various applications for temporary or permanent status).

  • Employment Authorization Document (EAD) or Green Card (I-551).


Who Must Register


  • Noncitizens aged 14 and older who were not registered and fingerprinted (if required) when applying for a visa and remain in the U.S. for 30 days or more.

  • Parents or legal guardians must ensure that children under 14 years old who remain in the U.S. for 30 days or more are registered.

  • Noncitizens turning 14 while in the U.S. must register within 30 days of their 14th birthday.

  • Noncitizens present in the U.S. without inspection, admission, or parole who have not previously registered.

  • Canadian visitors who entered through land ports of entry without receiving Form I-94.

  • Noncitizens who applied for benefits not listed in 8 CFR 264.1(a) (such as Deferred Action for Childhood Arrivals (DACA) or Temporary Protected Status (TPS)) but were not issued proof of registration, such as an EAD.


Exemptions: Certain groups, including some Indigenous populations, such as specific American Indians born in Canada, are exempt from this registration requirement.​


Penalties for Noncompliance: An alien's 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.


Registration Process


1. Complete Form G-325R Online


  • The Department of Homeland Security (DHS) has designated Form G-325R as the official registration document for previously unregistered noncitizens.

  • Parents and legal guardians must register minors under 14.


2. Attend a Mandatory Biometrics Appointment


Those completing Form G-325R must schedule and attend a biometrics appointment at a USCIS Application Support Center (ASC).This appointment includes:

  • Fingerprinting

  • Photographs

  • Signature collection (for identity verification and background checks)


3. Obtain and Carry Proof of Registration

  • After successful registration, DHS will issue a Proof of Alien Registration document, which can be downloaded from myUSCIS.

  • Noncitizens aged 18 and older must carry this proof at all times.


Employer Impact


The new USCIS rule introduces compliance requirements for employers, particularly in I-9 verification, DHS enforcement, and workforce management. Key areas of impact include:


  • I-9 Verification Updates: Employers should expect to see the Proof of Alien Registration document as an acceptable document for Form I-9 verification. HR teams must update compliance procedures to avoid document rejection issues.

  • Increased DHS Audits & Enforcement: The rule prioritizes enforcement against undocumented workers, increasing the likelihood of DHS audits and worksite inspections. Employers should ensure proper record-keeping and compliance with federal hiring laws.

  • Legal & Policy Compliance: Potential legal challenges or state-level adaptations may affect enforcement. Employers should stay informed about changes that could impact hiring and compliance procedures.


If you have questions about the new USCIS regulation and how it affects you or your business, please contact our immigration team at contact@consultils.com for a consultation.


Check out the related articles to stay ahead of changing policies:


Disclaimer: The materials provided on this website are for general informational purposes only and do not, and are not intended to, constitute legal advice. You should not act or refrain from acting based on any information provided here. Please consult with your own legal counsel regarding your specific situation and legal questions.


 
The image of Anna Sun, Esq.

Anna is the Partner and Head of Immigration at ILS. She has over a decade of experience in business immigration, transactions, and foreign investment.


She provides comprehensive guidance on U.S. business immigration, assisting global employers in recruiting and retaining foreign executives and skilled professionals. Anna specializes in H, L, E2, TN, O, EB1, and PERM cases, serving clients in technology, biotech, telecommunications, entertainment, animation, education, and logistics.


Email: contact@consultils.com | Phone: 626-344-8949


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