Who Needs to File the New Foreign National Registration?

Starting April 11, 2025, the U.S. Citizenship and Immigration Services (USCIS) will begin enforcing a new Foreign National Registration Requirement (Alien Registration Requirement, ARR) for certain non-U.S. citizens staying in the U.S. for 30 days or longer. This move follows President Trump's executive order signed on the first day of his re-administration, "Protecting the American People Against Invasion", which directs stricter identity tracking and enforcement measures for foreign nationals.

With this policy change, many are wondering: Who will be affected? Could this impact other visa holders? What steps should be taken? Let's break it down.

Who Will Be Affected?

If you haven’t already completed fingerprinting or formal registration through a U.S. visa or ESTA authorization, you may be required to register under the new rule. This mainly impacts:

• Canadians who entered via land borders without an I-94
• Foreign nationals who entered without inspection (EWI) and haven’t been fingerprinted via any immigration application
• Children turning 14 in the U.S. (must update registration and submit fingerprints within 30 days)
• DACA & TPS applicants who lack alternative proof of registration
• Foreign nationals who submitted immigration benefit requests (e.g., asylum or work permits) but haven’t received an official registration document

If you fall into one of these categories, you may need to register through USCIS’s new Form G-325R.

Who Does NOT Need to Register?

Many non-U.S. citizens will not need to go through additional registration because they already have proof of registration. This includes:

• Green Card holders
• Those who entered with a valid U.S. visa or ESTA authorization
• Non-U.S. citizens with an I-94 or I-94W record
• Individuals granted parole into the U.S., even if expired
• Those in removal proceedings (already tracked by DHS)
• Holders of valid work authorization (EAD card)
• Applicants with pending or previously submitted Green Card applications (I-485, I-687, I-698, etc.)

Normally international students follow the path from If you are an H-1B, F-1, O-1, or another visa holder, or are in a grace period. you generally don't need to worry. However, make sure to follow all timelines while waiting for your new status or if it is still pending.

What Are the Risks for Visa Holders?

Although this registration doesn’t directly impact visa validity, it could raise enforcement risks for certain groups:

• More Scrutiny for Extensions & Change of Status: Those on F-1, H-1B, or other nonimmigrant visas may face stricter background checks when applying for extensions or status changes.
• Increased Risk of "Unlawful Presence" Issues: Those who overstay beyond their allowed period or fail to register could face removal proceedings.
• Higher Chance of Workplace Compliance Checks: Employers hiring foreign workers (H-1B, L-1, etc.) may be subject to more audits to verify legal work status.
• Stronger Tracking for Adjustment of Status Applicants: If you apply for a Green Card (PERM, EB-2, EB-3, etc.), USCIS will already have your fingerprints and registration details—making any inconsistencies more visible.

What Are the Registration Steps?

• Step 1 - Check If You Need to Register: Log in to USCIS MyAccount and see if your status requires additional registration.
• Step 2 - Submit Form G-325R: If required, submit the new Alien Registration Form (G-325R) through your individual USCIS online account.
• Step 3 - Schedule a Biometrics Appointment: If fingerprinting is required, USCIS will notify you of a biometrics appointment. (Note: Canadians & children under 14 are generally exempt.)
• Step 4 - Download & Carry Proof of Registration: If you’re 18 or older, you must carry your proof of registration at all times.

What Are the Penalties for Not Registering?

• Failure to register or carry proof
  • Fines up to $5,000
  • Up to 6 months in jail (misdemeanor charge)
• Failure to report a change of address within 10 days
  • Fines up to $5,000
  • Deportation risk (unless excused by USCIS)
• Failure to register your child (if applicable)
  • Parents or guardians may face misdemeanor charges and penalties.

What You Should Do Now

To prevent any penalties, we recommend first verifying whether you already possess proof of registration (such as a Green Card, I-94, EAD, etc.). If you hold a visa, ensure you print and carry your I-94 or work permit. F-1 or H-1B holders should keep an eye on updates from USCIS. Finally, remain informed about policy changes.

This new enforcement marks a significant tightening of immigration control, potentially impacting how foreign nationals maintain their legal status in the U.S. If you have concerns, consult an immigration attorney for personalized guidance.

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