United States: New Online Registration Requirement Takes Effect for Some Foreign Nationals on April 11

Longstanding U.S. laws and rules require foreign nationals in the United States to register with the federal government. For many, registration occurs when a foreign national applies for a visa (immigrant or nonimmigrant) outside the United States and is fingerprinted, or receives a Form I-94 arrival record, an employment authorization document, a permanent residence card (green card), or another qualifying immigration document. Those who enter the United States without a visa must register if they are in the United States for 30 days or more. Children who enter before they turn 14 may be required to re-register within 30 days after their 14th birthday. (See below for more information about children and registration.)

On January 20, 2025, President Trump issued an executive order that, among other things, directs the Department of Homeland Security to strictly enforce the established registration requirements and ensure that foreign nationals are complying with them. In fulfillment of the executive order, DHS issued an interim final regulation (IFR) – which allows the federal government to implement a rule without advance notice to the public or an opportunity to comment before the rule’s implementation – and created a new online process for those who are unregistered, obligating them to register and have their fingerprints collected.

A coalition of advocacy groups filed a lawsuit asserting that the government failed to follow proper regulatory procedures when issuing the rule without an opportunity for public notice and advance comment, but their request to stay the implementation of the new regulation was denied today. The case is Coalition for Humane Immigrant Rights v. DHS, Case No. 1:25-cv-00943 (D.D.C., filed March 31, 2025). As such, the regulation will take effect on April 11, as scheduled.

Many foreign nationals will not need to take any action because they already possess a document or have filed an application that meets the registration requirements. This includes foreign nationals who entered the United States after turning 14 and either entered on a visa or were issued any of the following documents:

• A lawful permanent residence card (green card);
• A border crossing card;
• A USCIS employment authorization document (EAD);
• An I-94 or I-94W arrival record for nonimmigrants and parolees;
• A valid, unexpired DHS nonimmigrant admission stamp or parole stamp in a foreign passport; or
• A Notice to Appear (NTA) or other type of document issued when a foreign national is placed into removal (deportation) proceedings.

Foreign nationals who have filed one of the following types of applications have also met the registration requirement and generally should not need to take further action:

• A Form I-485 adjustment of status application;
• A Form I-590 application for Registration for Classification as a Refugee; or
• Certain applications for temporary residence status.

Some foreign nationals are exempt from the registration:

• Foreign nationals in the United States who were issued a nonimmigrant or immigrant visa before they arrived and who entered the country after turning 14;
• Individuals who have applied for or who hold an A or G visa; and
• Foreign nationals who are in the United States for less than 30 days.

The following three groups of foreign nationals are not covered by existing registration procedures or exempt and therefore must complete the online registration process:

• Canadian visitors of any age who (1) are traveling visa-free for business or tourism, (2) entered the United States by land, (3) were not issued an I-94 arrival record, and (4) remain in the United States for 30 days or more.
• Foreign nationals who are in the United States for 30 days or more and turn 14 in the United States generally must register within 30 days after their 14^th birthday and be fingerprinted, with certain possible exceptions; see Question 5 for details.
• Foreign nationals of any age who entered the United States without inspection and
  • Remain in the United States for 30 days or longer; and
  • Do not have a registration document (see Question 2); and
  • Have not applied for adjustment of status, refugee status, or temporary residence status. This includes foreign nationals who entered without inspection and have applied for DACA, TPS, or asylum but who have not been issued an EAD, NTA, or other document that qualifies as evidence of registration (see Question 2).

Children who have been in the country for 30 days or more and are turning 14 – whether previously registered or not – are generally required to register or re-register within 30 days after turning 14 and to undergo fingerprinting. Specific guidance for children turning 14 is as follows:

• If your child entered on a visa, they are considered registered at the time of the visa application. However, even children who are considered registered must re-register when they turn 14, unless they are eligible for an exemption. As such, your child is likely subject to the requirement to re-register, and it is therefore recommended that they undergo the online registration process upon turning 14.
• If your child entered by land as a visa-exempt Canadian visitor and was not issued an I-94, they must register within 30 days of entry and re-register within 30 days after turning 14.
• If your child entered in a nonimmigrant status like H-4, L-2, or TD and was issued an I-94, they are considered to be registered upon entry, based on the issuance of the Form I-94. However, as noted above, even children who are considered already registered generally must re-register when they turn 14, unless some exception applies.
• If your child entered in a nonimmigrant status but is visa-exempt (including most Canadians), your child is likely subject to the requirement to re-register, and it is therefore recommended that they undergo the online registration process upon turning 14.
• If your child is a U.S. lawful permanent resident, they are generally required to apply for a new green card within 30 days after they turn 14 using USCIS Form I-90. It is not clear whether the I-90 application for the new green card serves to re-register the child with DHS. Therefore, after Form I-90 is filed on your child’s behalf, you may wish to register your child even if it is not clearly required.

Children under 14 years old who entered the United States without a visa and who were not issued an I-94 are required to be registered by their parent or guardian, but they are not required to provide fingerprints. This includes Canadian children traveling visa-free for business or tourism who entered the United States by land, were not issued an I-94 arrival record, and will be in the United States for 30 days or more. It also includes children under 14 who entered the United States without inspection (EWI), will remain in the United States for 30 days or more, and do not have a qualifying registration document or a qualifying pending application, listed above. See below for further information and important risk considerations.Children in these two groups will also need to re-register after they turn 14, and at that point, they will be required to undergo fingerprinting.  

Children under 14 years old who entered the United States with a visa or were issued an I-94 are not required to register. Please see the preceding question regarding whether such children would need to register upon turning 14.

If you are subject to registration in the USCIS system, you will need to:

• Create a personal account in myUSCIS; if the registrant is a child under 14, a parent or guardian must create the account for the child;
• Complete and submit USCIS Form G-325R, the online registration form; and
• If age 14 or older and not a Canadian visitor, appear at a USCIS Application Support Center for fingerprinting and photographing.

In general, for those subject to the registration or re-registration requirement, the deadline to register is within 30 days of entry, or within 30 days after turning 14, as applicable.

On April 11, DHS Secretary Kristi Noem posted an announcement on the DHS website stating that the deadline to register for foreign nationals who are subject to registration and who have already been in the United States for 30 days or more is April 11 – the first day on which the Interim Final Rule (IFR) on registration takes effect. According to the announcement, such foreign nationals must register “immediately.” Before April 11, neither the IFR nor DHS guidance made clear how that 30-day deadline would be applied to individuals subject to registration who entered the U.S. or turned 14 more than 30 days before the April 11 effective date of the new rule.

Registration should be focused on children who turned 14 on their current stay in the United States; if a child turned 14 on a prior stay, they should not need to undergo registration, provided they were issued an I-94 for their current stay.

No, you must submit the registration on your own behalf. Attorneys or other third parties cannot create a myUSCIS account for you, submit the G-325R form for you from within your myUSCIS account, or log into your account even if you give your permission. However, if the registrant is a child under 14, the child’s parent or guardian can complete and submit the form on the child’s behalf. 

Even though most foreign nationals must complete the registration process themselves, they can seek assistance from a third party. If a third party helps you complete the registration form, you must disclose the name of that person and other information about them when completing the G-325R form, and they must sign a document concerning their role as a preparer, which must be uploaded into the myUSCIS system.

Form G-325R asks registrants to provide their biographic data, contact information, and immigration information, their date of last entry to the United States, their current and future activities in the United States, how long they plan to stay, when they plan to depart, information on their spouse (if any) and parents, and any criminal history.

The information a foreign national provides in their registration must be truthful; false or misleading information can have serious consequences. At the same time, disclosing information about criminal history or immigration violations – including entry to the United States without inspection – can pose significant risks. See below for more information.

After a foreign national submits Form G-325R online, the system will review the application. If USCIS records show that the foreign national is already registered (other than a child required to re-register after their 14th birthday), the system will inform the foreign national and the application will be closed with no further action necessary.

If the foreign national’s Form G-325R is accepted, USCIS will schedule the foreign national for biometrics, unless the registrant is under 14 or is a Canadian visitor, in which case biometrics are waived. The foreign national must then appear for in-person biometrics collection at a local USCIS Application Support Center. Once fingerprints and a photograph are collected, USCIS initiates security and background checks.

Finally, once registration processing is complete, the online system will produce a “Proof of Alien Registration” document bearing a unique identifier. The foreign national must print this document and carry it with them at all times.

Yes. This requirement is mandatory for all foreign nationals in the United States who are age 18 or older, including those who are not required to register in the new online system.

Those who register in the new system will be issued a document entitled “Proof of Alien Registration” in their myUSCIS account. Each registrant must print that document out and carry it with them at all times. See Question 13 for the penalties for failure to carry a registration document.

Those who are deemed to have already registered because they entered on an immigrant or nonimmigrant visa, are lawful permanent residents, or on some other basis (see above) are also required to carry proof of registration. A list of documents acceptable for this purpose is here.

Registration is an essential legal obligation of foreign nationals in the United States. Foreign nationals who are required to register in the new system and are found to be noncompliant face serious consequences:

• Willful failure or refusal to register is a misdemeanor punishable by a maximum fine of $5,000 or up to six months in jail, or both.
• Failing to carry proof of registration is a misdemeanor punishable by a maximum fine of $5,000 or up to 30 days in jail, or both.
• Failing to file a timely change of address with DHS is a misdemeanor punishable by a maximum fine of $5,000 or up to 30 days in jail, or both; it also renders the foreign national subject to detention and removal unless the failure was reasonably excusable or not willful.

Foreign nationals who have a criminal history, or who entered the United States without inspection (EWI) or are otherwise not in lawful immigration status, face additional risks and consequences. See the following question.

As discussed above, registration is a legal obligation of foreign nationals in the United States, and failing to register can subject an individual to serious penalties.

However, for some foreign nationals, registering with DHS will mean disclosing activities that may violate immigration or criminal laws. Those who entered the United States without inspection or who are otherwise not in lawful immigration status and who register with DHS will be making themselves known to the U.S. government.  In either circumstance, the foreign national could be subject to enforcement proceedings and penalties up to and including imprisonment and/or removal (deportation) from the United States.

Therefore, individuals with any criminal history, or those who entered without inspection or are otherwise not in lawful immigration status, and who are subject to the registration requirement should consult with an immigration attorney, and in some cases, a criminal attorney, to be fully apprised of the risks and consequences associated with the DHS registration obligation.