Mandatory DHS Registration Now in Effect for Many Foreign Nationals

Key Takeaways

• An Executive Order taking affect today requires many foreign nationals in the U.S. to register with DHS and provide biometric data.
• USCIS has launched a new form (G-325R) and online process to facilitate compliance.
• Even individuals who previously interacted with immigration authorities may still need to register or re-register.

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In a move that becomes effective today (April 11, 2025), President Trump issued Executive Order 14159, Protecting the American People Against Invasion, on Jan. 20, 2025,  directing the Department of Homeland Security to ensure that aliens comply with their legal obligation to register with the government and ensure that failure to comply with the registration requirement is treated as a civil and criminal enforcement priority.

With limited exceptions, 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. Similarly, parents and legal guardians of aliens below the age of 14 must ensure that those aliens are registered. Within 30 days of reaching his or her 14th birthday, all previously registered aliens must apply for re-registration and be fingerprinted.

Once an alien has registered and appeared for fingerprinting (unless waived), DHS will issue evidence of registration, which aliens over the age of 18 must carry and keep in their personal possession at all times.

USCIS has established a new form, G-325R, Biometric Information (Registration), and an online process by which unregistered aliens may register and comply with the law.

Those Already Registered

Foreign nationals who have already registered include:

• Lawful permanent residents;
• Some who have been paroled into the United States;
• Those 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 who are present in the United States who were issued immigrant or nonimmigrant visas before their last date of arrival;
• Those whom DHS has placed into removal proceedings;
• Those issued an employment authorization document;
• Those 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
• Those issued Border Crossing Cards.

Proof of Registration:

• I-94, Arrival-Departure Record—including those who have:
  • Been admitted as nonimmigrants;
  • Been paroled into the United States under section 212(d)(5) of the Immigration and Nationality Act;
  • Claimed entry prior to July 1, 1924, cannot be verified, having satisfactorily established residence in the United States since prior to July 1, 1924; and
  • Been granted permission to depart without the institution of deportation proceedings.
• I-95, Crewmen’s Landing Permit
• I-184, Alien Crewman Landing Permit and Identification Card
• I-185, Nonresident Alien Canadian Border Crossing Card
• I-186, Nonresident Alien Mexican Border Crossing Card
• I-221, Order to Show Cause and Notice of Hearing
• I-221S, Order to Show Cause, Notice of Hearing, and Warrant for Arrest of Alien
• I-551, Permanent Resident Card
• I-766, Employment Authorization Document
• Form I-862, Notice to Appear
• Form I-863, Notice of Referral to Immigration Judge

In addition a valid, unexpired nonimmigrant DHS admission or parole stamp in a foreign passport constitutes evidence of registration.

Who is Not Registered?

Anyone who has not applied to the Department of State for a visa, has been issued one of the documents listed above, or has not submitted one of the following forms and provided fingerprints (unless waived) is not registered.

• I-67, Inspection Record (for Hungarian refugees from the 1950s)
• I-94, Arrival-Departure Record
• I-95, Crewmen’s Landing Permit
• I-181, Memorandum of Creation of Record of Lawful Permanent Residence
• I-485, Application for Status as Permanent Resident
• I-590, Registration for Classification as Refugee—Escapee
• I-687, Application for Status as a Temporary Resident
• I-691, Notice of Approval for Status as a Temporary Resident
• I-698, Application to Adjust Status from Temporary to Permanent Resident
• I-700, Application for Status as a Temporary Resident
• I-817, Application for Voluntary Departure under the Family Unity Program

Foreign Nationals Who Have Not Registered Include:

• Those present in the United States without inspection and admission or inspection and parole who have not otherwise registered (those 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
• Those who submitted one or more applications to USCIS not listed above, including applications for deferred action or Temporary Protected Status, who were not issued evidence of registration included under “Proof of Registration” above.

Anyone who submitted one of the forms included under “Who is not registered” above, provided fingerprints (unless waived), and was not issued one of the documents under the “Proof of Registration” has complied with the registration requirement.

How to Register

Step 1: Create a USCIS Online Account

To register, foreign nationals must first create a USCIS online account here.

Step 2: Submit Form G-325R

Complete and submit an electronic version of the Form G-325R, Biographic Information (Registration).

Step 3: USCIS Review of Form G-325R

Once submitted, USCIS will review Form G-325R, any information provided, and any DHS records that are available about the person. If it appears that he/she has already complied with the registration requirements in some other way and does not need to submit Form G-325R, USCIS will notify him/her that they have already complied with the registration requirement.

If it appears the person is required to register, USCIS will review their Form G-325R to determine if they are required to appear for a biometric services appointment. If not, USCIS will provide evidence of registration.

Step 4: Attend Appointment for Biometrics Collection

If the person is required to register and provide biometrics, USCIS will schedule a biometric services appointment at one of its Application Support Centers (ASCs).

Step 5: Receive Registration Documentation

Once the person has registered and provided biometrics (if required), USCIS will post a notice (Proof of G-325R Registration) to the person’s USCIS online account, where it can be downloaded and printed.

Criminal Penalties for Willful Failure or Refusal to Register or Provide Biometrics (If Required)

Any foreign national 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 and will, upon conviction, be fined up to $5,000 or be imprisoned up to six months, or both.

If you have any questions about the information in this alert, please contact Jim Aldrich or your Dykema relationship attorney.